TRIPLE SUMMIT ADVISORS, LLC

PART 2A ITEM 1: COVER SHEET Triple Summit Advisors, LLC P.O. Box 95141 Newton, MA 02495-0141 (917) 574-2670 info@triplesummit.com www.triplesummit.com www.triplesummitadvisors.com April 7, 2026 This brochure provides information about the qualifications and business practices of Triple Summit Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number and/or e-mail address above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Our e-mail for regulatory compliance is info@triplesummit.com. Triple Summit Advisors, LLC is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. The verbal and written communications of an investment advisor provide you with information you need to determine whether to hire or retain the advisor. Additional information about Triple Summit Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The Firm’s CRD number is 282764.  PART 2A ITEM 2: MATERIAL CHANGES Triple Summit Advisors, LLC Since our previous filing on February 24,, 2025 there have been the following material changes: • We have updated our minimum account size to $250,000. • We are registering with the SEC. • We have updated Global Compounding Quality to Global Compounding Quality. Please contact us at (917) 574-2670 or info@triplesummit.com if you would like a copy of our updated Part 2. Additional information about us is also available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 3 TABLE OF CONTENTS Item 1: Cover Sheet Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business ........................................................................................................................... 1 Item 5: Fees and Compensation ................................................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management .............................................................. 8 Item 7: Types of Clients ............................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss........................................................ 9 Item 9: Disciplinary Information ............................................................................................................... 11 Item 10: Other Financial Industry Activities and Affiliations ................................................................... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11 Item 12: Brokerage Practices ..................................................................................................................... 12 Item 13: Review of Accounts..................................................................................................................... 15 Item 14: Client Referrals and Other Compensation ................................................................................... 16 Item 15: Custody ........................................................................................................................................ 16 Item 16: Investment Discretion .................................................................................................................. 17 Item 17: Voting Client Securities............................................................................................................... 17 Item 18: Financial Information .................................................................................................................. 17 Item 19: Requirements for State-Registered Advisors............................... Error! Bookmark not defined. Part 2B: Dan Kanivas Part 2B: Wei Wang  ITEM 4: ADVISORY BUSINESS Who we are Triple Summit Advisors, LLC (referred to as “we,” “our,” “us,” or “Triple Summit”), was formed in September 2015 and has been registered as an investment advisor since April 2016. Triple Summit will maintain registration in additional states as necessary. Our principals are Wei Wang, Chief Compliance Officer and Dan Kanivas, both Managing Members responsible for the day-to-day management of the firm and all investment advice. In addition, YingTing Yang is also a member of the Firm who does not provide investment advice to client. Investment Advisory Services Global Asset Allocation Strategy The Global Asset Allocation strategy invests in a basket of Exchange Traded Funds ("ETFs") in order to provide the client with exposure to a diversified set of securities across multiple quantitative and qualitative factors, including: geography, industry, market capitalization, value, and momentum. Such wide diversification is intended to both provide exposure to multiple sources of return and to decrease the probability that any single security will have an outsized negative impact on the client's portfolio. The goal of this strategy is to provide returns commensurate with the indices tracked by the selected ETFs, less investment management and advisory fees. Triple Summit may utilize the services of a subadvisor to manage the portion of the client assets allocated to this strategy. Currently, Triple Summit has an agreement with JustInvest, LLC, CRD #285366 to act as the subadvisor. Washington clients who utilize JustInvest, LLC’s services will be required to sign an agreement with them directly. Additional information regarding this relationship may be found in Item 10. Global Compounding Quality Strategy The Global Compounding Quality strategy invests in undervalued securities across asset classes, with a focus on purchasing the equity securities of high quality companies with wide economic moats and strong competitive advantages. They are typically characterized by: a) high Returns on Invested Capital and Equity; b) exceptional and consistent historical growth of sales, earnings and cash flows; c) high operating margins, and d) prudent and unbiased capital allocation decisions. The goal of this strategy is to exceed the returns of the S&P 500 Index over a market cycle. This strategy is intended for investors with a long investing time horizon and the ability to endure near-term mark-to-market volatility in the pursuit of long-term profits. Global Opportunistic & Event Driven Strategy The Global Opportunistic & Event-Driven strategy invests primarily in deep value, event-driven, and special situations investments, including: turnarounds, shareholder activism, liquidations, carve-outs, divestitures, spin-offs, tender offers, going-private transactions, merger arbitrage, and corporate restructuring. The goal of this strategy is to exceed the returns of the S&P 500 index over a market cycle, while also providing returns that have a low correlation with the movements of the S&P 500 Index. This strategy is intended for tax-advantaged investors with a medium-to-long investing time horizon and the ability to endure near-term mark-to-market volatility in the pursuit of attractive risk-adjusted returns.  Triple Summit Advisors, LLC Brochure Supplement Wei Wang Global Quantitative Factor Investing Strategy The Global Quantitative Factor Investing strategy invests using a combination of asset allocation, Modern Portfolio Theory, and quantitative factor analysis to develop portfolio strategies for each client’s unique situation. Goals-based asset allocation is a method of analysis which considers a client’s current situation together with projected future goals and financials. In evaluating a client’s current situation, Triple Summit Advisors considers multiple variables, including but not limited to age, income level, current and projected liabilities, personal financial goals, and personal values. Modern Portfolio Theory is an investment approach that seeks to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by optimizing the portions of each asset class based on forecasted volatility and correlations to other assets classes or securities. Quantitative factor analysis involves assessing securities based on a set of measurable factors (as distinguished from qualitative considerations such as the character of management or the state of employee morale). Global Quantitative Factor Investing’s quantitative factor analysis may use, but not be limited to, statistical risk factors, published financial ratios, market data, and environmental, social, and governance (ESG) scores. Triple Summit will utilize the services of a subadvisor to manage the portion of the client assets allocated to this strategy. Currently, Triple Summit has an agreement with JustInvest, LLC, CRD #285366 to act as the subadvisor. Washington clients who utilize JustInvest, LLC’s services will be required to sign an agreement with them directly. Additional information regarding this relationship may be found in Item 10. Held Away Accounts Triple Summit provides advisory services to assets held in accounts by custodians that are not directly accessible to us (e.g., 401(k) plans, HSA accounts) ("Held Away Accounts"). In order to provide this service, the client must sign an agreement with Pontera Solutions, Inc. ("Pontera") and provide Pontera with the log in information for those accounts. Pontera provides an interface which allows Triple Summit a view to the account holdings and place trading instructions We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our Global Asset Allocation Strategy strategies in the same way we do other accounts, though using different tools as necessary. At no time will Triple Summit have direct access to these accounts. Triple Summit will not utilize the services of Pontera for clients that reside within Washington State. Financial Planning Services To the extent requested by a client, Triple Summit may provide its clients with a broad range of comprehensive financial planning and consulting services. These services include some or all of the following, depending on the needs of the client. A) Cash flow and debt management: we evaluate the income and expenses of the client and give advice on tax withholdings, budget building, expense management, and optimal debt paydown strategies B) Insurance Planning: we evaluate a client’s health and age and give recommendations on types of life insurance (term, whole, universal…etc.), disability insurance, auto insurance, homeowner’s Page 2  Triple Summit Advisors, LLC Brochure Supplement Wei Wang or renter’s insurance, umbrella insurance, as well as other insurance applicable to the client’s unique situation C) Employee Benefits: we analyze the employee benefits of the client, such as FSA, HSA, gym membership reimbursements, etc., to make sure that the client is taking full advantage of what they have at their disposal D) Retirement Planning: we analyze the existing retirement plans of the client and make suggestions on contributions, withdrawals, and asset allocation strategies E) Tax Planning Strategies: we analyze the existing financial situation of each client and give advice on ways to maximize income tax and capital gains tax savings via contributions to tax-deferred accounts, tax loss harvesting, and other pertinent techniques F) Education Planning: we lay out the options available to clients with children on ways to save and borrow for their children’s educational expenses (i.e. 529 plans, Coverdell Education Savings Accounts, federal and private student loans) With respect to estate planning and actual annual income tax preparation, our role shall be that of a facilitator between you and your designated professional advisers(s). Investment Consulting Service To the extent requested by a client, Triple Summit may provide its clients with a broad range of comprehensive investment consulting services. These services include some or all of the following, depending on the needs of the client. A) Portfolio Construction and Asset Allocation: using a top-down approach, we help clients decide on the allocation of assets between the major types of investments as well as which type of accounts in which these assets should be held. If requested, we further drill down into specific security recommendations that fit within the broader asset allocation B) Risk and Volatility Analysis: we analyze the historical volatility of the existing portfolio and try to optimize the portfolio to a target volatility based on the client’s goals, preferences, and risk tolerance C) Financial Modeling: using Excel and other software platforms, we project out returns, dividends, interest income, expenses, and taxes of a specific portfolio to see how it reacts to various changing input factors and hypothetical scenarios D) Monte Carlo Simulations: when necessary, we will use probability models and random number generation to forecast a range of outcomes for the portfolio E) Cash Management Strategies: when necessary, we will give advice on how optimal ways to set up accounts, SIPC and FDIC insurance limits, on-shore/off-shore banking requirements, and cash- sweep procedures Page 3  Triple Summit Advisors, LLC Brochure Supplement Wei Wang Insurance Consulting Service Triple Summit has a relationship with DPL Financial Partners, LLC (“DPL”). By working with DPL, Triple Summit may provide insurance reviews/analyses, education, and insurance solutions in a conflict free manner. DPL is a third-party provider of a platform of insurance consultancy services to registered investment advisers (“RIAs”) that have clients with a current or future need for insurance products. DPL offers RIAs memberships to its platform for a fixed annual fee and, through its licensed insurance agents who are also registered representatives of The Leaders Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker-dealer and FINRA member, offers members a variety of services relating to fee- based insurance products. These services include, among others, providing members with analyses of their current methodology for evaluating client insurance needs, educating and acting as a resource to members regarding insurance products generally and specific insurance products owned by their clients or that their clients are considering purchasing, and providing members access to and product marketing support regarding fee-based products that insurers have agreed to offer to members’ clients through DPL’s platform. General Disclosures Triple Summit offers both financial planning services and portfolio management services. Clients may engage Triple Summit for both of these services or for each service individually. Financial planning services are tailored to the needs of each client and based on their financial situation and personal circumstances. When performing Financial Planning and/or Investment Consulting Services, we are neither your attorney nor your accountants and no portion of investment consulting services rendered by us should be interpreted by your as legal or accounting advice. We recommend that you seek the advice of a qualified attorney and accountant. Portfolio management services are based on the individual goals, time horizon, and risk tolerance of each client. Triple Summit creates an Investment Policy Statement for each portfolio management client, which outlines the client’s current situation (including factors such as income, time horizon, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. If desired, Triple Summit provides financial planning services for all clients who elect to receive portfolio management services. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Triple Summit from properly servicing the client account, or if the restrictions would require Triple Summit to deviate from its standard suite of services, Triple Summit reserves the right to terminate the relationship. We do not provide portfolio management services to a wrap fee program. Assets Under Management As of December 31, 2025, we manage assets of $108,473,568 on a discretionary basis and $0 on a non- discretionary basis. Page 4  Triple Summit Advisors, LLC Brochure Supplement Wei Wang ITEM 5: FEES AND COMPENSATION Global Asset Allocation Strategy Fees for this strategy are generally 0.65% per year of the assets under management, billed at the end of each quarter. If the fee is calculated by Interactive Brokers, it is done by multiplying the value of the account as of the end of each trading day by the annual fee, then dividing the result by the number of trading days in the year. If the fee is calculated by Charles Schwab, it is done based on the value of the account as of the last day of the calendar quarter. In the event a subadvisor is used, Triple Summit retains 0.50% and compensates the subadvisor 0.15% for its services. We may negotiate lower fees based on amount of managed assets. Global Compounding Quality Strategy Fees for this strategy are generally 1% per year of the assets under management, billed at the end of each quarter. If the fee is calculated by Interactive Brokers, it is done by multiplying the value of the account as of the end of each trading day by the annual fee, then dividing the result by the number of trading days in the year. If the fee is calculated by Charles Schwab, it is done based on the value of the account as of the last day of the calendar quarter. We may negotiate lower fees based on amount of managed assets. Global Opportunistic & Event Driven Strategy Fees for this strategy are generally 1.5% per year of the assets under management, billed at the end of each quarter. The fee is calculated by Interactive Brokers, our custodian/broker-dealer, by multiplying the value of the account as of the end of each trading day by the annual fee, then dividing the result by the number of trading days in the year. We may negotiate lower fees based on amount of managed assets. Qualified clients may elect to pay us a performance fee in lieu of the above asset-based fee. The performance fee is calculated as of the last day of each calendar quarter. Triple Summit uses a 20 quarter look back when determining the high water mark for performance fee calculation. When the account profits for the current quarter exceed the unrecouped net losses for the 20 quarters immediately prior to the quarter end, we will receive a performance fee of 15% of the profits generated. Solely for purposes of computing this fee, net profits and net losses include unrealized gains and losses. If you withdraw capital from your account, the performance fee for the amount withdrawn will be calculated as of the withdrawal date. Performance fee arrangements are not available to residents of Washington state. In order to pay a performance fee you must meet certain requirements. Typically our new clients must meet one of the following criteria: • Have a net worth (or together with spouse have a net worth) of at least $2.2 million, excluding value of primary residence. • Have at least $1.1 million invested with us. Existing clients are subject to the standards in place at the inception of the relationship. Our Investment Management Agreement provides additional qualification standards. All performance fees will be charged in a manner that complies with applicable rules and regulations, including Section 260.234 of the California Code of Regulations. Page 5  Triple Summit Advisors, LLC Brochure Supplement Wei Wang Global Quantitative Factor Investing Strategy Fees for this strategy are generally 1% per year of the assets under management, billed at the end of each quarter. The fee is calculated by Charles Schwab based on the value of the account as of the last day of the calendar quarter. Triple Summit retains 0.80% and compensates the subadvisor 0.20% for its services. We may negotiate lower fees based on amount of managed assets. Held Away Accounts Per the fee for the Global Asset Allocation Strategy, Triple Summit will charge a fee of 0.65% per year of the assets under management. We may negotiate lower fees based on amount of managed assets. A portion of this fee (0.25% per year), is paid to Pontera to allow access to Held Away Accounts. These fees are billed quarterly, in arrears, based on the value of the account as of the last day of the calendar quarter and will be prorated for contributions and withdrawals made during the quarter. You may instruct us to deduct these fees from a taxable account being managed by us, or we can invoice via AdvicePay. Other Costs Involved In addition to our advisory fee shown above, you are responsible for paying fees associated with investing for your account. These fees include: • mutual fund loads (if applicable). These charges are paid to brokers as a form of commission. • management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF or mutual fund and are a portion of the expenses of the ETF or mutual fund. • brokerage costs and transaction fees for any securities or fixed income trades. These are generally charged by your custodian and/or executing broker. Additional information about brokerage costs and services is provided in “Item 12: Brokerage Practices.” We believe the fees mentioned above are competitive; however you may be able to obtain similar services from other sources at a lower price. Financial Planning Financial planning services are provided for a fixed fee ranging from $1,000 - $5,000, based on the scope and complexity of the services to be provided. This fee is based on the estimated time to complete the project, based on our hourly fee of $400. Fee(s) may be higher than normally charged in the industry and similar services may be offered by another adviser at a lower fee. To the extent there are other extraneous expenses, it will be explicitly stipulated in the contract. We require a deposit of 50% of the negotiated fee at the time of signing the Financial Planning Agreement. All financial planning services are completed within 6 months. You will receive an invoice upon completion of the financial plan or finished product for the balance of the fee due. You may pay for financial planning services by wire, check or cash. Page 6  Triple Summit Advisors, LLC Brochure Supplement Wei Wang You may cancel our financial planning agreement at any time by providing written notice. Upon cancellation, we will present you with an invoice for time spent, based on the hourly rate shown above, as well as any completed portions of the project. This invoice is payable upon receipt. If the invoiced amount is less than the deposit received, a refund will be provided with the invoice. Follow-up financial planning services are provided for a fee of $400 per hour. Investment Consulting Investment consulting services are provided for a fixed fee ranging from $5,000 - $150,000, based on the scope and complexity of the services to be provided. This fee is based on the estimated time to complete the project, based on our hourly fee of $400. Fee(s) may be higher than normally charged in the industry and similar services may be offered by another adviser at a lower fee. To the extent there are other extraneous expenses, it will be explicitly stipulated in the contract. We require a deposit of 50% of the negotiated fee at the time of signing of the Investment Consulting Agreement. You will receive an invoice upon completion of the finished product for the balance of the fee due. You may pay for investment consulting services by wire, check or cash. You may cancel our investment consulting agreement at any time by providing written notice. Upon cancellation, we will present you with an invoice for time spent, based on the hourly rate shown above, as well as any completed portions of the project. This invoice is payable upon receipt. If the invoiced amount is less than the deposit received, a refund will be provided with the invoice. Follow-up investment consulting services and ongoing monitoring services are provided for a fee of $400 per hour. Insurance Consulting Triple Summit pays an annual fee to DPL to allow client access to the platform. We do not pass this fee on to clients who utilize the service. For providing platform services to RIAs, DPL receives service fees from the insurers that offer their fee-based products through the platform. These service fees are based on the insurance premiums received by the insurers. DPL is licensed as an insurance producer in Kentucky and other jurisdictions where required to perform the platform services. Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering their products through the platform, and registered representatives of The Leaders Group. We do not directly or indirectly charge clients for assets that are invested in insurance products. General Disclosures Triple Summit may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Triple Summit recommends the services of itself. The client is under no obligation to act upon any of the recommendations made by Triple Summit under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Triple Summit itself. Clients retain absolute discretion over all such financial planning and consulting services and are free to accept or reject any of Triple Summit's recommendations. Note that there is a conflict of interest with the implementation of the financial plan or investment consulting advice; we may receive increased fees if you include us in the implementation of these plans/advice. You have the option to purchase recommended investment products or services through advisors or representatives that are not affiliated with Triple Summit. Page 7  Triple Summit Advisors, LLC Brochure Supplement Wei Wang We generally require that you provide authorization for us to deduct our investment management fees directly from your investment account. Following is important information about the deduction of management fees: • You must provide authorization for us to deduct fees by initialing the appropriate section of our contract. • You will receive a detailed invoice each quarter which includes the fee, the formula used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based. This invoice will be sent to you at the same time a request for payment is sent to the Custodian. • You will receive a statement from your custodian which shows all transactions in the account at least quarterly, including the deduction of our fees. We urge you to compare this information with the fees provided on your invoice. • You are responsible for reviewing the accuracy of the fees being billed, as the custodian will not do so. In limited circumstances we may agree to allow clients to pay by check rather than deducting payment directly from the client account. When a client relationship begins on other than the first day of a billing period, fees will be pro-rated based on the number of days the assets are managed, as described above. If this Part 2 was received less than 48 hours before signing of the advisory agreement, Client shall have the option to terminate this agreement without penalty or fees within five business days after the date of signing. You may end our advisory relationship by providing 30 days written notice. Triple Summit will prorate the advisory fees earned through the termination date and send you an invoice for the advisory fees due. Neither Triple Summit nor our affiliated persons receive compensation, other than the fees mentioned above, for the sale of securities or other investment products. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Our fee structure includes either an asset-based fee or performance based fee option but not both at the same time. There is no difference in the way money is managed for asset-based fee clients versus performance based fee clients within the Global Opportunistic & Event Driven Strategy because we use the same investment approach and portfolios for both and all trades within a given strategy are aggregated. There is no overlap in the securities traded for the Global Opportunistic & Event Driven Strategy and the other strategies utilized by Triple Summit. The receipt of performance fees could create an incentive for us to make investments that are riskier or more speculative than would be the case in the absence of the arrangement. In some circumstances, we may receive increased compensation as a result of unrealized appreciation as well as realized gains. Page 8  Triple Summit Advisors, LLC Brochure Supplement Wei Wang ITEM 7: TYPES OF CLIENTS Our clients are typically individuals, trusts and corporate entities. Generally we require that clients have a minimum opening balance of $250,000. However, we may waive that minimum at our sole discretion. Please see Item 5 for qualification standards related to clients who pay a performance fee. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Triple Summit’s method of analysis is fundamental analysis. Fundamental analysis involves the analysis of quantitative and qualitative factors affecting the value of securities, including the following: financial statements, management capabilities, competitive advantages, and macroeconomic factors. Triple Summit's investment strategy is long-term trading. Long-term trading is designed to permit ownership of a security for a sufficient time period for the market value of the security to meet or exceed the intrinsic value of the security. Fundamental analysis concentrates on factors such as asset values and expected future cash flows generated by a company or entity. This strategy would normally encourage purchases in securities that are undervalued or priced below their intrinsic value. The risks assumed are that the intrinsic value of a security may decline and/or the market value will fail to reach the intrinsic value of a security. Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long- term investment strategy can expose clients to different types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry developments, market conditions and general economic environments, carrying with it the risk of capital loss. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. Fixed income investments include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities. In general, the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities may also carry inflation risk, liquidity risk, call risk, credit risk, and default risks for both issuers and counterparties. Risks of investing in foreign fixed income securities also include the general risks of non-U.S. investing described below. Exchange Traded Funds (ETFs) are investment funds traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss. Areas of concern include the lack of transparency in certain ETF products, increasing complexity, possible conflicts of interest, and the possibility of inadequate regulatory compliance. Derivatives are investment instruments that consist of a contract whose value derives from and depends on the value of an underlying financial asset. Derivatives include instruments such as options and futures contracts. Derivatives may be used both to increase economic exposure to certain risk factors or to Page 9  Triple Summit Advisors, LLC Brochure Supplement Wei Wang mitigate risks. The risks of investing in derivatives include economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Triple Summit may use options including covered puts and calls and long puts and calls. For covered calls are when a client holds a long position in an asset then writes (sells) call options on that same asset to generate an income stream. The client's long position in the asset is the cover because it means the seller can deliver the shares if the buyer of the call option chooses to exercise. In a covered put strategy, you are selling the underlying stock and selling a put option against it. A long call option gives you the right to buy stock at a preset price in the future. A long put option lets you sell it. Risks of options include but are not limited to: Assignment Risk: Having a short call or put in a position can lead to an assignment and involuntary transaction, which cannot otherwise be avoided. In the case of a short call, being assigned can lead to a forced sale of stock, whether it is held long in the portfolio or not. Being short a put can lead to a forced purchase of the underlying stock for which capital will have to be provided by the account holder. Losses and Limited Gains: In the case of an option purchase (long call or long put), a Client’s entire initial investment of premium can be lost. In the case of a covered option short sale (short call or short put), upside gains can be limited by the sale of a short call against an underlying stock position and a forced purchase of stock can occur in the case of a short cash covered put sale. Lack of Liquidity: Some option markets are very thinly traded and highly illiquid, resulting in wide markets and limited trading opportunities. Should it be determined that an option trade will be attempted in such a market, there is the risk of a fill price that is either substantially higher (purchase) or substantially lower (sale) than mid-market. In addition, in such illiquid markets and despite best efforts there is the risk that no fill will occur at all for the intended order. Tax: Client should consult with their tax advisor to address the tax consequences of options trading strategies. For taxable accounts in the Global Opportunistic & Event Driven Strategy we have the option to sell securities short for arbitrage situations (i.e. merger arbitrage where Company A is buying Company B with shares of Company's A stock; in that situation we would go long Company B and short Company A at an appropriate ratio to capture the spread). We do not sell securities short in any of our other strategies. Non-U.S. securities present certain risks, such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting, and less disclosure of financial information. Clients may elect to establish a margin account with the Custodian. The usual settlement for stock trades is trade date + 2. If a client has a margin account, Triple Summit can immediately use the proceeds of the sale to buy a new stock. Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on Page 10  Triple Summit Advisors, LLC Brochure Supplement Wei Wang increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. All investments involve different degrees of risk. You should be aware of your risk tolerance level and financial situation at all times. We cannot guarantee the successful performance of an investment and we are expressly prohibited from guaranteeing accounts against losses arising from market conditions. Investing in securities involves risk of loss that clients should be prepared to bear. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of the investment advisor and each investment advisor representative providing investment advice to you. We have no information of this type to report. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS As a registered investment advisor, we are required to disclose when Triple Summit, or any of our principals, have any other financial industry affiliations. Neither Triple Summit nor our affiliated persons have material outside business affiliations, arrangements or registrations, pending or otherwise, with other companies, regulatory organizations or persons. Triple Summit may engage subadvisors to provide manage a portion of the client assets, as described in Item 4 and Item 5. In some cases, client may be able to obtain the services provided by the subadvisor for a lower fee by investing directly with the subadvisor rather than utilizing Triple Summit’s services. In some instances, the subadvisor provides services to Triple Summit for a lower fee because Triple Summit provides client support and reporting. There is no guarantee that the client would receive a lower fee by investing directly with the subadvisor. Triple Summit will confirm that any subadvisor recommended to client is appropriately licensed as an investment advisor. Triple Summit does not receive compensation of any kind from the subadvisors it recommends. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics We have adopted a set of enforceable guidelines (Code of Ethics), which describes unacceptable conduct by Triple Summit and our associated persons. Summarized, this Code of Ethics prohibits us from: • placing our interests before yours, • using non public information gathered when providing services to you for our own gains, or Page 11  Triple Summit Advisors, LLC Brochure Supplement Wei Wang • engaging in any act, practice or course of business that is, or might be considered, fraudulent, deceptive, manipulative, or in violation of any applicable law, rule or regulation of a governmental agency. Please contact us if you would like to receive a full copy of this Code of Ethics. Personal Trading for Associated Persons We may buy or sell some of the same securities for you that we already hold in our personal account. We may also buy for our personal account some of the same securities that you already hold in your account. Neither Triple Summit nor an associated person recommends to clients, or buys or sells for client accounts, securities in which Triple Summit or an associated person have a material interest. It is our policy not to permit our associated persons (or their immediate relatives) to trade in a way that takes advantage of price movements caused by your transactions. We may restrict trading for a particular security for our accounts or those of our associated person if there is a pending trade in that security in a client account. Trades for our accounts (and those of our associated persons) will be placed as part of a block trade with client trades, or individually after client trades have been completed. Additional information about block trades is provided in the Aggregation of Orders section of “Item 12: Brokerage Practices.” When our trades are placed after our client trades, we may receive a better or worse price than that received by the client. Triple Summit and its associated persons may purchase or sell specific securities for their own account based on personal investment considerations without regard to whether the purchase or sale of such security is appropriate for clients. The firm and advisory associates are prohibited from frontrunning or engaging in activities that would disadvantage client accounts. All persons associated with us are required to report all personal securities transactions to us quarterly. ITEM 12: BROKERAGE PRACTICES The Custodian and Brokers We Use We do not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see “Item 15: Custody”). Your assets must be maintained in an account at a “qualified custodian,” generally a broker/dealer or bank. We recommend and require that our clients use Charles Schwab & Co., Inc. (“Schwab”) or Interactive Brokers ("IB"), both FINRA-registered broker/dealers, members SIPC, as the qualified custodian ("Custodian"). We feel that the costs associated with trading with these Custodians are reasonable in relation to the services provided. However, by directing brokerage to Custodian, we may be unable to achieve most favorable execution for your transactions, and this practice may cost you more money. We are independently owned and operated and are not affiliated with Schwab or IB. Custodian will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we request that you use Schwab or IB as custodian/broker, you will decide whether to do so and will open your account with Custodian by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Schwab or IB, then we cannot manage your account. Not all advisors require their clients to use a Page 12  Triple Summit Advisors, LLC Brochure Supplement Wei Wang particular broker-dealer or other custodian selected by the advisor. We do not receive client referrals from Schwab or IB. How We Select Brokers/Custodians to Recommend We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our other clients • Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us From Schwab” and Item 14, Client Referrals and other Compensation for disclosures related to IB) Your Brokerage and Custody Costs For our clients’ accounts that Custodian maintains, Custodian generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your account. Certain trades (for example, many mutual funds and ETFs) may not incur commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. We have determined that having Custodian execute trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Brokers/Custodians”). Products and Services Available to Us From Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. We participate in a similar program with IB. They provide our clients and us with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. Custodian also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow Page 13  Triple Summit Advisors, LLC Brochure Supplement Wei Wang our business. Custodian's support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services That Benefit You. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services That May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting • Marketing consulting and support Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. Aggregation of Orders There are occasions on which portfolio transactions will be executed as part of concurrent authorizations to purchase or sell the same security for another client or one or more of our associated persons. When possible, we may choose to block (aggregate) trades for your account with those of other client accounts and personal accounts of persons associated with Triple Summit. When we place a block trade, all participants included in the block receive the same price per share on the trade. The price is calculated Page 14  Triple Summit Advisors, LLC Brochure Supplement Wei Wang by averaging the price of all of the shares traded. Due to the averaging of price over all of the participating accounts, aggregated trades could be either advantageous or disadvantageous. Commission costs are not averaged. You will pay the same commission whether your trade is placed as part of a block or on an individual basis. The objective of the aggregated orders will be to allocate the executions in a manner that is deemed equitable to the accounts involved. Soft Dollars The receipt of goods and/or services from the required custodian in connection with providing advice to clients is seen by the regulators as “soft dollars.” The additional services we receive from Interactive Brokers, as disclosed in Item 14 below and those we receive from Schwab, as disclosed in the section entitled “Products and Services Available to Us From Schwab” above, would fall under this description of soft dollars. ITEM 13: REVIEW OF ACCOUNTS We are available to meet with clients at any time. Investment Management Accounts Wei Wang and Dan Kanivas, Managing Members, are responsible for the management of all client accounts and perform weekly reviews of client accounts. This comprehensive review of the account's investment strategy and risk factors takes into account the client’s investment policies and risk tolerance levels. More frequent reviews may be triggered by material market, economic, or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, inheritance, etc.). Triple Summit does not send out periodic reports to clients. At times, Triple Summit will provide letters to clients with qualitative commentary on the performance of the various strategies, as well as general market trends and events. The custodian of the assets will provide statements not less often than quarterly detailing the client's account, including assets held, asset value, and transactions for the period. Held Away Accounts Wei Wang and Dan Kanivas, Managing Members, are responsible for the management of all client accounts and perform quarterly reviews of client accounts. More frequent reviews may be triggered by material market, economic, or political events, or by changes in client's financial situations. When deemed necessary, we will reblance the account taking into account the client's investment goals and risk tolerance. Triple Summit does not send out periodic reports to clients. At times, Triple Summit will provide letters to clients with qualitative commentary on the performance of the various strategies, as well as general market trends and events. The custodian of the assets will provide statements not less often than quarterly detailing the client's account, including assets held, asset value, and transactions for the period. Page 15  Triple Summit Advisors, LLC Brochure Supplement Wei Wang Financial Planning Services Clients are recommended (but not required) to have their financial plan reviewed on an annual basis. Reviews normally involve analysis and possible revision of the client's previous financial plan. A copy of the revised plans will be provided to the client upon request. Unless provided for in the engagement agreement (e.g. ongoing support), financial planning and investment consultation services reviews are conducted under a new or amended agreement and will be assessed at Triple Summit's then current fee rate. Clients are advised to contact our firm for an additional review when the client anticipates or has experienced changes in financial situation (i.e. employment or marital status, health issues, inheritance, child birth, etc.) Non-periodic reviews typically occur under a new or amended agreement unless previously stipulated in writing, and will be assessed at Triple Summit's then current fee rate. Financial planning reviews are performed by Wei Wang, Managing Member or Dan Kanivas, Managing Member. Triple Summit does not provide regular reports to clients who receive only financial planning services. If a client specifically requests annual updates of the financial plan, then it can be provided. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION We receive economic benefits from custodians that we use to execute trades in client accounts. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; • research related products and tools; • access to a trading desk serving investment advisor participants; • • access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly from client accounts; and • access to an electronic communications network for client order entry and account information. • We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12: Brokerage Practices”). We do not directly or indirectly compensate anyone for client referrals. ITEM 15: CUSTODY When you give Triple Summit authority to deduct our fees directly from your investment account, we are deemed to have custody of those assets. In order to avoid additional regulatory requirements related to custody, we follow the procedures outlined in “Item 5: Fees and Compensation.” You will also receive Page 16  Triple Summit Advisors, LLC Brochure Supplement Wei Wang quarterly statements directly from Custodian that detail all transactions in the account. We urge you to compare this information with the fees provided on your invoice. At no time do we accept physical custody of client assets. ITEM 16: INVESTMENT DISCRETION As one of the conditions of managing your account, you are required to provide discretionary authority for us to manage your assets. Discretionary authority means that you are giving us a limited power of attorney to place trades on your behalf. This limited power of attorney does not allow us to withdraw money from your account, other than advisory fees if you agree to give us that authority. You grant us discretionary authority by completing the following items: • Sign a contract with us that provides a limited power of attorney for us to place trades on your behalf. Any limitations to the trading authorization will be added to this agreement. • Provide us with discretionary authority on the new account forms that are submitted to the broker/dealer acting as custodian for your account(s). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Triple Summit from properly servicing the client account, or if the restrictions would require Triple Summit to deviate from its standard suite of services, Triple Summit reserves the right to terminate the relationship. ITEM 17: VOTING CLIENT SECURITIES We do not accept the authority to vote proxies on your behalf. You will receive proxies and other related paperwork directly from your custodian. Upon request we will provide guidance about voting a specific proxy solicitation. ITEM 18: FINANCIAL INFORMATION We do not charge or solicit pre-payment of more than $500 in fees per client six months or more in advance. We have never filed for bankruptcy and are not aware of any financial conditions that are reasonably likely to impair our ability to meet our contractual obligations to clients. California Disclosure Requirements In our opinion, all material conflicts of interest regarding Triple Summit, our representatives or any of our employees which could reasonably be expected to impair our rendering of unbiased and objective advice to an advisory client under Section 260.238(k) of the California Code of Regulations have been disclosed. Page 17