TRIUMPH CAPITAL MANAGEMENT

TRIUMPH CAPITAL MANAGEMENT FORM ADV PART 2A BROCHURE August 15, 2025 This brochure provides information about the qualifications and business practices of Triumph Capital Management (hereinafter referred to as “TCM”, “us”, “Firm”, or the “Advisor”). If you have any questions about the contents of this brochure, please contact us by telephone at (720) 399-5555 or by email at info@TriumphCapitalManagement.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about Triumph Capital Management is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD # 282814. Please note that the use of the term “registered investment adviser” and description of Triumph Capital Management and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees. Triumph Capital Management Headquarters: 1610 Wynkoop Street, Suite 550, Denver, CO 80202 Phone: (720) 399-5555 E-Mail: Info@TriumphCapitalManagement.com Website: www.TriumphCapitalManagement.com  ADV Part 2A - Firm Brochure ITEM 2: MATERIAL CHANGES Triumph Capital Management is required to advise you of any material changes to the Firm Brochure (“Brochure”) from our last annual update. Since our last annual amendment, we have the following material change(s) to disclose: Item 5: Fees and Compensation – Several changes were made to better define our services to clients and the fees associated with those services. Item 12: Brokerage Practices – Several changes were made to provide a clearer description of the custodian/broker responsible for holding your assets and executing transactions, along with the addition of Fidelity Investments as a recommended custodian for client accounts. Item 15: Custody – Several revisions were made to clarify how custody applies to the deduction of advisory fees from client accounts, as well as to money movement capabilities. Page 2 of 25  ADV Part 2A - Firm Brochure ITEM 3: TABLE OF CONTENTS ITEM 2: MATERIAL CHANGES ........................................................................................................... 2 ITEM 3: TABLE OF CONTENTS .......................................................................................................... 3 ITEM 4: ADVISORY BUSINESS ........................................................................................................... 4 ITEM 5: FEES AND COMPENSATION ................................................................................................. 8 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ..................................... 13 ITEM 7: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ......................................................... 13 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS .......................... 14 ITEM 9: DISCIPLINARY INFORMATION ........................................................................................... 17 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................ 17 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ....................................................................................................................... 19 ITEM 12: BROKERAGE PRACTICES .................................................................................................. 20 ITEM 13: REVIEW OF ACCOUNT ..................................................................................................... 22 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION .......................................................... 22 ITEM 15: CUSTODY ......................................................................................................................... 23 ITEM 16: INVESTMENT DISCRETION .............................................................................................. 24 ITEM 17: VOTING CLIENT SECURITIES ............................................................................................ 24 ITEM 18: FINANCIAL INFORMATION .............................................................................................. 25  ADV Part 2A - Firm Brochure ITEM 4: ADVISORY BUSINESS Firm Description TCM is dedicated to providing individuals and other types of clients with a broad range of investment advisory services. We are committed to helping clients build, manage, and preserve their wealth through strategic guidance tailored to their stated financial goals. The firm was established in the State of Colorado and has been in business since 2016. TCM’s principal owner is Derek Eichenwald. Investment Management Services Our Investment Management service provides discretionary asset management for a fee. It is designed to help clients meet their financial goals through the use of investment strategies tailored to their individual circumstances. We conduct at least one meeting—often more—either in person (when possible) or by telephone or video conference, to gain an understanding of the client’s financial situation, resources, goals, and risk tolerance. This information enables TCM to determine an appropriate investment approach and portfolio composition. Once the client agrees to the proposed investment plan, we assist with establishing or transferring investment accounts so that TCM can manage the portfolio. After accounts are under our management, we review them on a regular basis and at least annually. We may periodically rebalance or adjust accounts as needed. Clients may request reasonable restrictions on the types of investments held in their portfolio; however, restrictions on certain securities or categories of securities may not always be feasible given the practical challenges of managing the account under such limitations. Clients are responsible for promptly notifying us of any significant changes in their financial or personal circumstances so that we may take them into account when managing their investments. While performing services, TCM is not required to verify information provided by the client or by other professionals engaged by the client. Third-Party Asset Managers TCM may utilize the investment strategies of Third-Party Asset Managers (“TPAMs”). TPAMs are evaluated and selected on a discretionary basis pursuant to the client’s investment advisory agreement with our firm. Before selecting TPAMs, we ensure they are properly licensed or registered and consider factors such as their experience, assets under management, performance record, level of client service, investment style, and overall investment process. A copy of the TPAM’s disclosure brochure will be provided to the client. The terms and conditions under which a client engages a TPAM will be set forth either in the client’s agreement with our firm or in a separate written agreement between the client and the TPAM. Clients may terminate these agreements at any time with written notice. Managed by Triumph Capital Management at Security Benefit The Managed by TCM at Security Benefit Program utilizes investment models to manage client accounts opened and held at Security Benefit. The mutual funds available on the Security Benefit Page 4 of 25  ADV Part 2A - Firm Brochure platform are the only options that may be included in the allocation mix of these models. The models are reviewed monthly, and the investments within them may be reallocated. However, reallocations will not occur if it is determined that no changes are appropriate. Tactical Model at Security Benefit: The Tactical Model seeks to provide absolute returns during any market cycle by employing a strategic rotation across commodities, REITs, bonds and other fixed- income investments, international equities, domestic equities, and cash. Using funds available on the Security Benefit platform, the model emphasizes asset classes that TCM believes are demonstrating strength while avoiding those that appear to be in decline or show limited growth potential. Conservative Model at Security Benefit: The Conservative Model seeks to preserve principal rather than maximize appreciation. It focuses on capital preservation and risk minimization through a diversified and balanced allocation across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. Moderate-Conservative Model at Security Benefit: The Moderate-Conservative Model emphasizes principal preservation while allowing for a modest degree of risk and volatility in pursuit of limited appreciation. This model accepts lower returns in exchange for reduced risk, utilizing a diversified and balanced allocation across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. Moderate Model at Security Benefit: The Moderate Model seeks to balance risk and return equally. It accepts moderate risk in pursuit of higher long-term returns and may incur short-term losses to achieve long-term growth. Allocations are diversified across commodities, REITs, bonds and other fixed- income investments, international equities, domestic equities, and cash. Aggressive-Moderate Model at Security Benefit: The Aggressive-Moderate Model emphasizes higher long-term returns and accepts significant risk, including the potential for large losses. It maintains a diversified allocation across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. Aggressive Model at Security Benefit: The Aggressive Model seeks to maximize returns and accepts substantial risk, including the potential loss of principal, in pursuit of higher results. Allocations are diversified across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. All models involve risk, including the potential loss of principal. Past performance is not a guarantee of future results. The Managed by TCM at Security Benefit models may not achieve their stated objectives. Market and economic conditions could adversely affect performance and may result in capital losses. Clients should carefully consider the charges, risks, expenses, limited investment options, and their overall objectives before investing. The models are limited to the funds, ETFs, and/or sub-accounts available on the Security Benefit platform. They are not intended to manage all client assets or address every financial need. Accounts enrolled in the Managed by TCM at Security Benefit Program will be managed according to the model selected in the client agreement, though allocations may change over time to reflect updated client objectives. Model allocations are not personalized to individual investors. Accounts are custodied at Security Benefit, which provides at least quarterly statements. Clients are encouraged to review these Page 5 of 25  ADV Part 2A - Firm Brochure statements carefully and compare them to any reports provided by TCM. Verify that account transactions align with your stated investment goals and objectives. Contact your IAR or TCM’s Chief Compliance Officer with any questions or concerns. The Managed by TCM at Security Benefit Program is limited in scope and not intended to address all advisory needs. Additional services are available through separate agreements. Participation is subject to TCM’s discretion, and TCM may restrict or prohibit participation at any time, for any reason. Triumph Turnkey Asset Management Program Similar to outside TPAMs, TCM offers the Triumph Turnkey Asset Management Program (“TTAMP”) as an investment option for its IARs. The TTAMP provides model portfolios and other portfolio management solutions that are managed by TCM and made available for use by IARs. The services provided, along with the roles and responsibilities of the client, the IAR, and TCM, are outlined in the client agreement. Clients retain the ability to direct their account in a manner that aligns with their objectives, including determining asset allocation, selecting models, and placing reasonable restrictions on the account. Full model allocation may be limited by account size, and smaller account values may result in allocation variances that differ from the intended TTAMP model. By enrolling in TTAMP, clients grant TCM discretionary authority to place trades in their account and, when appropriate, to adjust asset allocation or model selection in line with the client’s stated investment objectives or restrictions. Once an account is established, TCM monitors the asset allocation and model selections, executing trades as needed. The IAR continues to service the client relationship by meeting with the client at least annually and communicating any necessary updates or changes to TCM. Retirement Plan Advisory Services Retirement Plan Advisory Services consist of assisting employer plan sponsors with the establishment, monitoring, and review of their company’s retirement plan. Depending on the needs of the plan sponsor, advisory areas may include investment selection and monitoring, plan structure, and participant education. TCM will help identify your plan’s needs and objectives through an initial meeting to gather data, review plan information, and assist in developing or updating plan provisions. Ongoing services may include recommendations regarding the selection and review of unaffiliated mutual funds, ETFs, and other investment products that, in TCM’s judgment, are suitable for plan assets. TCM will periodically review the investment options selected and provide recommendations to retain or replace them as appropriate. Additionally, TCM may conduct a comprehensive review of potential service providers or vendors and assist with the conversion process should you choose to change providers. You are under no obligation to implement any recommendations made by TCM. Under an investment advisory agreement, TCM may also provide financial education to plan participants at the plan sponsor’s request. The scope of such education will not constitute “investment advice” within the meaning of ERISA, but will instead focus on general investment principles and information regarding the investment options available in the plan. TCM may participate in initial enrollment meetings, periodic workshops, and future enrollment sessions for new participants, as agreed upon with the plan sponsor. All Retirement Plan Advisory Services are provided in compliance with applicable federal and state laws Page 6 of 25  ADV Part 2A - Firm Brochure regulating such services. This section applies to accounts that are pension or other employee benefit plans governed by ERISA. If your account is part of a qualified plan and TCM accepts the appointment to provide services, TCM acknowledges that it acts as a fiduciary within the meaning of Section 3(21) of ERISA and Section 4975 of the Internal Revenue Code. Furthermore, TCM agrees to comply with the Department of Labor’s Impartial Conduct Standards, as implemented and enforced through TCM’s Code of Ethics. Self-Directed Brokerage Accounts A Self-Directed Brokerage Account (“SDBA”) is a brokerage window that allows participants to select investment options outside of their employer’s core plan offerings, while still remaining within the retirement plan and maintaining the associated tax advantages. An SDBA provides greater flexibility and control, enabling more diversified, targeted, and strategic retirement investing. This option is intended for investors who acknowledge and understand the risks associated with many of the investments available through an SDBA. Your IAR will work with you to identify your investment goals, objectives, and risk tolerance, and will assist in creating a portfolio allocation designed to meet your objectives while complying with any plan-specific restrictions. Advisory accounts within an SDBA may involve the purchase and/or sale of securities. These accounts can be managed on either a discretionary or non-discretionary basis, depending on the plan and the participant’s needs. Many SDBAs restrict or prohibit certain activities, including but not limited to: • Selling short or using margin • Trading in foreign securities (stocks, bonds) • Trading in bulletin board or pink sheet stocks • Trading real estate/property outside of approved REITs • Trading currencies • Trading limited partnerships • Trading futures/commodities • Trading promissory notes • Trading collectibles • Trading municipal bonds Financial Planning and Consulting Services TCM provides financial planning and consulting services on a limited-scope basis in one or more areas such as financial and retirement planning, money management, tax, real estate, and insurance planning. TCM is not an attorney, insurance agent, or certified public accountant. Our financial planning and consulting services may include an analysis of your financial situation and assistance in identifying and implementing appropriate financial planning and investment management techniques to help you achieve your goals. Services generally include a written financial analysis along with specific and/or general investment and planning recommendations. In preparing your financial plan, TCM may address up to five areas of planning: financial, money management, tax, estate, and insurance. Our services in preparing your plan may include: Page 7 of 25  ADV Part 2A - Firm Brochure • Review and clarification of your financial goals and objectives • Assessment of your overall financial position, including cash flow, balance sheet, investment strategy, risk management, and estate planning • Creation of a tailored plan for each of your goals, such as real estate (personal or business), education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal objectives • Development of a goal-oriented investment plan that considers tax strategies, asset allocation, expenses, risk, and liquidity factors, including IRA and qualified plans as well as taxable and trust accounts requiring special attention • Design of a risk management plan addressing risk tolerance, avoidance, mitigation, and transfer, along with liquidity, insurance, and potential company benefits • Collaboration with your estate and/or corporate attorneys and tax advisors to craft and implement an estate plan that provides for you and your heirs in the event of incapacity or death • Generation of a benefits plan, risk management plan, and succession plan for your business, if applicable Should you choose to implement the recommendations provided in the plan, TCM encourages you to work closely with your attorney, accountant, insurance agent, and IAR/stockbroker. Implementation of financial plan recommendations is entirely at your discretion. Client Information Provided to Portfolio Managers and Client Contact Non-public information is information about you not accessible to the public. Your social security number, net worth, and annual income are examples of non-public information. Public information is information about you readily accessible to the public. Public information may include your name, phone number, and address. For all accounts, including those in the programs described in this brochure, your IAR will have access to the non-public information provided by you in the account opening process. This information is protected in accordance with TCM’s Privacy Policy. TCM’s Privacy Policy is available on TCM’s website and is provided upon opening your account and annually thereafter. Wrap Fee Programs Some of TCM’s portfolio management services utilize a wrap fee program. Wrap fee programs allow the client to pay a comprehensive fee for management, brokerage, clearing, custody, and administrative services. TCM will receive a portion of the wrap fee for its services. Assets As of August 15, 2025, TCM has $529,969,948 in discretionary assets under management. TCM does not have any non-discretionary assets under management. ITEM 5: FEES AND COMPENSATION Investment Management Fees and Compensation TCM charges a fee as compensation for providing investment management services on your account. These services include advisory and consulting services, trade execution, investment supervision, and Page 8 of 25  ADV Part 2A - Firm Brochure other account maintenance activities. In addition, TCM’s custodian may charge transaction costs, custodial fees, redemption fees, retirement plan fees, alternative asset fees, and other administrative fees or commissions. Please see “Additional Fees and Expenses” below for further details. Certain assets (e.g., mutual funds, ETFs, alternative investments, UITs, MLPs, etc.) deposited or purchased in your accounts may also be subject to separate management and administrative fees, as described in the applicable prospectus or agreement. These fees are independent of TCM’s fees and should be disclosed by the custodian or contained in the investment’s offering documents. Clients should be aware that fees for comparable services vary, and lower fees may be available from other sources. The annual fee for portfolio management services is billed quarterly or monthly, either in arrears or in advance. The fee is based on the average daily market value of the account(s) during the billing period, or on the prior quarterly or monthly ending balance. Fees are calculated on a calendar-year basis (including leap years). Because of deposits or unsettled trades, the prior quarterly or monthly ending balance used for fee calculation may differ from the account value shown on the custodian’s statement. Fees are assessed on all assets under management—including securities, cash, and money market balances—unless otherwise noted in the client agreement. TCM may exclude certain positions for billing purposes. Margin balances do not reduce the value of assets under management. For accounts held at Charles Schwab, clients can view both average daily balances and end-of-period balances through Black Diamond and Schwab portals. TCM’s maximum annual investment advisory fee is 3.00%. The specific fee applicable to each client is outlined in the investment advisory agreement. Fees may vary depending on account size, portfolio complexity, account activity, or other factors agreed upon by TCM and the client. In some cases, fees and billing arrangements may be negotiated. TCM also charges a minimum fee of $180 annually for accounts held at Charles Schwab, though this fee may be waived or reduced at TCM’s discretion. In certain cases, TCM may aggregate household account balances to determine the applicable advisory fee. This consolidation allows clients to benefit from a higher combined asset total, which may reduce the effective advisory fee under the applicable schedule. The independent qualified custodian holding client assets will debit the advisory fee directly from the account and remit payment to TCM. Clients provide written authorization permitting fees to be deducted directly from their custodial account. Custodians provide independent account statements at least quarterly, showing account balances, transaction history, and all fees deducted, including TCM’s advisory fees. Clients are encouraged to carefully review these statements for accuracy. At TCM’s discretion, advisory fees may also be paid by check. Clients with questions about their management fee calculation or the data inputs used are encouraged to contact the TCM Compliance Department, which will provide full details regarding fees. Either TCM or the client may terminate the management agreement upon written notice to the other party. Upon termination, the management fee will be prorated through the effective date of termination for the quarter or month in which notice was given, and any unearned fees will be refunded or additional fees billed. After termination, clients are solely responsible for monitoring and managing the securities in their account, and TCM will have no further obligation to act on or advise regarding those assets. Page 9 of 25  ADV Part 2A - Firm Brochure Managed by Triumph Capital Management at Security Benefits Fees Advisory fees for the Managed by TCM program at Security Benefit range from 1.0% to 1.5%, depending on the Security Benefit option selected. Fees are charged quarterly in advance, based on the prior quarter’s ending account balance. Because of deposits or unsettled trades, the balance used for fee calculation may differ from the account value shown on the custodian’s statement. Clients can access prior quarter account balances through their quarterly Security Benefit statement. If you have any questions about the accuracy of your management fee or the data inputs used to calculate it, please contact the TCM Compliance Department. The independent qualified custodian, Security Benefit, debits advisory fees directly from your account and remits payment to TCM. Written client authorization is required to permit these fee deductions. Security Benefit will provide an account statement at least quarterly, showing all amounts deducted from your account. Security Benefit determines the values of the assets in your portfolio. In addition to advisory fees, Security Benefit charges an annual custodial fee of 0.25%. Accounts with balances under $50,000 are subject to an additional $35 annual fee (waived for balances of $50,000 or more). These fees are separate from, and in addition to, the TCM advisory fee of 1.0% to 1.5%. Please review the Security Benefit Mutual Fund Program Brochure and the applicable prospectuses for further details on fees and expenses. In addition, securities used in the Managed by TCM program at Security Benefit (e.g., mutual funds, ETFs, sub-accounts, etc.) may be subject to separate management and administrative fees as described in each prospectus. These fees are independent of the TCM advisory fee and Security Benefit custodial fees. Clients should be aware that fees for comparable services may vary and lower-cost alternatives may be available from other sources. If a sales load was paid on a Security Benefit purchase, TCM does not permit its IARs to enroll clients into the Managed by TCM program at Security Benefit. If your IAR did not sell the Security Benefit program to you, this restriction may not apply. Security Benefit provides quarterly statements detailing fees and expenses. Clients should carefully review these statements and verify the calculation of all fees. Please note that the custodian does not verify the accuracy of TCM’s fee calculations. Either TCM or the client may terminate the Managed by TCM at Security Benefit advisory agreement at any time by providing written notice to the other party. Financial Planning Fees / Consulting Services TCM provides planning and consulting services for clients seeking advice on a limited scope of work. Fees for these services are negotiated with each client. Under a fixed-fee arrangement, the fee will be agreed upon in advance of services being performed. Fees generally range from $100 to $10,000 and may vary depending on the extent and complexity of the planning or consulting project. Typically, TCM will complete a financial plan within 30 days and present it to you within 90 days of the contract date, provided that all required information has been received. Fees are never based on, or related to, the performance of your funds or investments. TCM does not require prepayment of more than $1,200 in fees per client, six or more months in advance of providing any planning or consulting services. Page 10 of 25  ADV Part 2A - Firm Brochure Financial planning and consulting services may be terminated by either party at any time without penalty upon written notice. Services are considered complete upon delivery and discussion of the financial plan. Variable Product Advisory Management Fees A TCM IAR may offer investment management services on the sub-account allocations within a variable product you own, such as a variable annuity or a variable universal life insurance policy. This service may be provided on a discretionary basis and will be detailed in your advisory agreement. When offering this service, your IAR may apply their own analysis, research methods, investment style/strategy, and ongoing management philosophy. If you engage your IAR to provide advice regarding your variable product, you will pay a separate advisory fee for this service. This fee is in addition to the internal costs of the variable product itself and is calculated as a percentage of your variable product account value, including any cash or cash equivalent positions. When provided directly by your IAR, the advisory fee will not exceed 2% annually. The specific advisory fee applicable to you will be clearly stated in the advisory agreement you sign with your IAR. If a commission was paid on the sale of a variable product, TCM prohibits its IARs from charging an advisory fee for this service for a period of two years following the sale. If your IAR did not sell the variable product to you, this two-year restriction may or may not apply. Alternative Product Advisory Management Fees If you engage your IAR to provide advice regarding your alternative investments, you will pay a separate advisory fee for this service. This fee is in addition to the internal costs associated with the alternative investment and is calculated as a percentage of the investment account value, as reported by the custodian where the investment is held. When provided directly by your IAR, the advisory fee will not exceed 3% annually. The specific advisory fee will be clearly stated in the advisory agreement you sign with your IAR. Because certain alternative investments involve commission payments and various purchase options, a conflict of interest may arise. This may create an incentive for your IAR to make recommendations based on compensation rather than solely on your needs. Alternative investments may also offer different share classes, including load and no-load options. Clients are strongly encouraged to review the prospectus carefully and discuss these considerations with their IAR. If a commission was paid on the sale of an alternative investment, TCM prohibits its IARs from charging an advisory fee for this service for a period of three years following the sale. If your IAR did not sell the alternative investment to you, this three-year restriction may or may not apply. Third Party Asset Manager Fees Fees may also be charged by TPAMs for services they provide to our clients, in addition to the fees assessed by our firm. The terms and conditions of a client’s engagement with a TPAM will be outlined in a separate agreement between the client and the designated third party. The fee you pay to your IAR is separate from, and in addition to, the fee you pay to the TPAM. In Page 11 of 25  ADV Part 2A - Firm Brochure addition to TCM’s client agreement and disclosure brochure, clients should carefully review the disclosure brochure of the selected TPAM for a detailed breakdown of their fees. Either party may terminate the TPAM agreement at any time with written notice to the other party. Triumph Turnkey Asset Management Program Fees TCM charges a monthly or quarterly fee that covers the costs of administering the TTAMP, as well as portfolio and model construction, trading, custody, and clearing. TCM offers flexibility in how and when the TTAMP fee is debited from client accounts. The fee may be calculated monthly or quarterly, in advance or in arrears, as a percentage of account value based either on the average daily balance during the billing period or on the prior month’s or quarter’s ending balance. Because of deposits or unsettled trades, the prior month’s or quarter’s ending balance used for fee calculation may differ from the value shown on the custodian statement. The specific calculation method will be clearly outlined in the client agreement under Management Fees and Charges. In most cases, the TTAMP fee is debited quarterly, based on the prior quarter’s ending balance, and is separate from the IAR/FP fee and any other applicable costs, such as internal fund expenses or custodian maintenance fees. However, if requested, the TTAMP fee and the IAR/FP fee may be combined and debited together. This arrangement will also be detailed in the client agreement under Management Fees and Charges. For clients with multiple accounts, unless otherwise specified in the client agreement, each account is treated separately for purposes of calculating and debiting the program fee. Through the account agreement, clients authorize TCM to debit the account and remit the IAR/FP fee as outlined in the agreement. This fee compensates the IAR/FP for introducing the client to TTAMP, gathering and communicating financial information, assisting with portfolio allocation and model selection, maintaining the account, communicating material changes in financial needs, and performing other administrative duties. The IAR/FP fee is negotiated directly between the client and the IAR/FP and documented in the client agreement. Clients should note that participation in TTAMP may present a conflict of interest, as lower-cost investment programs may be available outside of TCM and TTAMP. The standard annual tiered TTAMP fee schedule is presented in the chart below. Please note that actual fees may vary based on the agreement with the IAR/FP and the distribution platform. For full disclosure of program fees applicable to your account(s), please refer to your client agreement under Management Fees and Charges. Triumph Turnkey Asset Management Typical Tiered Fee (may vary) Account Value TTAMP Fee $0.00 - $100,000 0.90% $100,000 - $250,000 0.85% $250,000 - $500,000 0.80% Page 12 of 25  ADV Part 2A - Firm Brochure $500,000 - $1,000,000 0.75% $1,000,000 - $5,000,000 0.65% $5,000,000 - $10,000,000 0.55% Over $10,000,000 0.35% • TTAMP has a minimum annual fee of $180 for accounts held at Charles Schwab, which TCM may waive or reduce. In most cases, the TTAMP fee is separate from, and in addition to, the IAR/FP fee. • • Please refer to your client agreement, Section: Management Fees and Charges. Additional Fees and Expenses Depending on your account type or the advisory program selected, additional third-party fees may apply in addition to the advisory fees paid to TCM. These fees may include, but are not limited to: • Custodial or platform service charges • Brokerage or transaction fees • Regulatory fees (e.g., SEC fees) • Account activity, wire transfer, or electronic funds processing fees • ADR fees • Account maintenance or closure fees • Mutual fund operating fees and expenses • Markups/markdowns, bid-ask spreads, and selling concessions • Margin interest • Miscellaneous fees, including transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, legally required fees, and other similar charges Your account fee structure is outlined in your Client Agreement and in the disclosure documents provided by the custodian. These materials specify any additional fees that may apply to your account. If you have questions about your program type or potential costs, please contact TCM directly. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT TCM does not charge performance-based fees for its advisory services. All advisory fees are charged exclusively as described in Item 5 above. ITEM 7: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS TCM provides investment advice to individuals, high-net-worth individuals, families, small businesses, foundations, trusts, charitable organizations, and estates. We also advise on retirement accounts, including – but not limited to – IRAs, SEPs, SIMPLEs, Solo 401(k)s, retirement trusts, defined benefit plans, small business 401(k) plans, and corporate 401(k) plans. TCM does not impose minimum requirements for opening or maintaining accounts, or for engaging our services. Page 13 of 25  ADV Part 2A - Firm Brochure However, certain TPAMs may require a minimum account size, and these requirements can vary from one TPAM to another. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Investment Selection and Portfolio Management TCM determines investments and allocations based on each client’s predefined investment objectives, risk tolerance, time horizon, financial situation, liquidity needs, and other relevant suitability factors. Client-imposed restrictions and guidelines may affect portfolio composition, and TCM’s investment strategies and advice may vary depending on a client’s specific circumstances. TCM selects investments for client portfolios using a combination of fundamental, cyclical, and technical analysis, along with charting techniques. We gather information from a wide range of resources, including financial publications, independent research, corporate rating services, company press releases, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Asset allocation decisions are guided by the chosen investment strategy, prevailing economic conditions, and TCM’s assessment of the market’s position within the economic cycle. Risks and opportunities are evaluated to determine the portfolio’s level of investment. Market fluctuations may cause a portfolio to deviate from its target allocation. To maintain alignment with established guidelines, accounts are monitored continuously and rebalanced as needed – either back to the original allocation or to a revised allocation based on current market conditions and the selected investment strategy. Changes in allocation may also be triggered by broader market conditions or specific microeconomic factors affecting individual holdings. Analytical Methods Fundamental analysis evaluates a company’s intrinsic value by reviewing economic conditions, industry trends, financial statements, management quality, earnings, expenses, assets, and liabilities. The assessed value is compared to the current market price to guide buy, sell, or hold decisions. Cyclical Analysis examines the stages of an industry cycle to inform investment decisions. Technical analysis studies market-generated data such as historical prices and trading volumes, using charts and statistical tools to identify patterns that may indicate future price movements. Charting focuses on identifying recurring patterns that may indicate future price movements – such as line charts, bar charts, candlesticks, and point-and-figure charts – to spot trends and potential reversals that may signal buying or selling opportunities. Investment Strategies TCM’s strategies may involve long-term and short-term holdings, active trading (including securities sold within 30 days), and the use of options, margin, leverage, and short sales. Clients may place reasonable restrictions on the strategies used or the types of investments held in their portfolio. Page 14 of 25  ADV Part 2A - Firm Brochure Whenever possible, TCM seeks to: • Strategically diversify with non-correlating assets. • Maintain a balance between growth and value styles. • Diversify across markets and sectors. • Rebalance in response to market changes. • Manage portfolios for tax efficiency. Third Party Asset Manager Selection and Evaluation TCM evaluates TPAMs based on their experience, expertise, investment philosophy, and historical performance to assess whether they have demonstrated the ability to invest successfully across varying time periods and economic conditions. As part of our ongoing risk assessment, TCM monitors TPAMs underlying holdings, strategies, portfolio concentrations, and use of leverage. Investing with a TPAM who has achieved past success carries the risk that such results may not be repeated in the future. Because TCM does not control the specific investments within a TPAM’s portfolio, there is also the risk that the TPAM may deviate from the statement investment mandate or strategy, potentially making the portfolio less suitable for our clients. Furthermore, as TCM does not oversee TPAM’s daily business or compliance operations, we may not be aware of deficiencies in internal controls that could lead to business, regulatory, or reputational issues. Risk of Loss You are advised – and should understand – that TCM’s past performance does not guarantee future results. Market and economic risks may adversely affect your account’s performance and could result in a loss of capital. Investing in securities involves the risk of loss, which you should be prepared to bear. There are principal and material risks that may negatively impact your account’s value and total return. Additional risks, not described here, could also prevent your portfolio from achieving its investment objectives. It is important to review all disclosure information carefully and understand that you may lose money by investing in any of our strategies. Your account may be subject to the following risks: Alternative Investments: Alternative investments are generally illiquid and do not trade on a national securities exchange. They typically include direct participation program securities (such as partnerships, limited liability companies, business development companies, or real estate investment trusts), commodity pools, private equity, private debt, and hedge funds. These investments carry various risks, including illiquidity and potential devaluation due to adverse economic or real estate market conditions. They are not suitable for all investors. Alternative investments are generally considered speculative and may involve a high degree of risk – particularly when concentrated in one or a few such investments. These risks can be greater and substantially different from those associated with traditional equity or fixed-income investments. Additional details on these risks are provided in the product’s prospectus. You should read the prospectus carefully before investing. Page 15 of 25  ADV Part 2A - Firm Brochure Capitalization Risk: Small and mid-capitalization companies may face challenges due to limited resources or less diversified products and services. Their stocks have historically been more volatile than those of larger, more established companies. Cash and Cash Equivalents: A portion of your assets may be held in cash or cash equivalents to help meet your objectives, provide ongoing distributions, or take a defensive position. Holding cash may reduce market exposure and limit potential returns. Concentration Risk: A large position in a single security, sector, or industry can amplify losses and increase portfolio volatility. Concentrated portfolios are more vulnerable to sudden losses that can significantly impact performance. Credit Risk: Credit risk is the possibility that the issuer of a security will be unable to make interest or principal payments when due. Downgrades in an issuer’s credit rating, or perceived changes in its financial strength, can negatively affect security values and portfolio performance. Cryptocurrencies – Digital Assets: Cryptocurrencies are a relatively new and highly volatile asset class. Prices can swing rapidly, and the market is subject to uncertainty, fraud, theft, manipulation, security breaches, and operational failures. Most cryptocurrency trading venues are largely unregulated, increasing exposure to fraud and market manipulation. These investments are suitable only for clients wishing to have an allocation to an investment with a speculative objective who can bear the economic risk of the investment, who have no need for liquidity, understand the risks and are willing to accept those risks of loss of their entire investment in exchange for potential returns. Given the complexity of the products and technology that cryptocurrencies pose, investment decisions made with respect to the allocation of any portfolio to cryptocurrencies are subject to various potential risks including technical, legal, market, and operational risks, price volatility, illiquidity, valuation methodology, related-party transactions, and conflicts of interest, and that those investments decisions will not always be profitable. Derivatives: Derivatives, such as futures contracts, derive their value from other securities or indices. They can be used for hedging or speculative purposes. While hedging can help manage risk, it may increase expenses and does not guarantee success. Equity Securities: Equity prices tend to be more volatile than fixed-income securities. Prices fluctuate based on company-specific events, industry conditions, and broader market factors. Small and mid-cap stocks often have higher volatility, lower trading volume, and less liquidity than large- cap stocks. Exchange-Traded Funds (“ETFs”): ETFs face risks such as lack of an active trading market, potential losses from secondary market trading, or disruptions in the creation/redemption process. These factors may cause ETF shares to trade at a premium or discount to their net asset value. Fixed Income Securities: The value of bonds fluctuates with market conditions, interest rates, and credit quality. Rising interest rates generally lower bond prices, especially for those with longer maturities. Credit risk refers to the possibility that the issuer will fail to make timely interest or principal payments. High-yield (“junk”) bonds carry higher risks of principal and income loss than investment-grade bonds. Page 16 of 25  ADV Part 2A - Firm Brochure Foreign Securities and Currency Risk: International and emerging-market investments carry risks such as currency fluctuations, foreign taxes and regulations, illiquid markets, political instability, and the potential for total loss of the investment’s value. Interest Rate Risk: In a rising rate environment, the value of fixed-income securities typically declines, and equity values may also be negatively impacted. Market Risk: No investment approach can eliminate market risk. Economic, political, and company- specific events can cause security values to rise or fall. Your investment may lose value, and you may receive less than your original investment upon liquidation. Mutual Funds: Mutual funds may hold a variety of asset types, each with its own risks. Money market funds, while aiming to preserve principal, can lose value. Aggressive growth funds may be more volatile and are best suited for investors willing to accept price swings. Income from tax-free funds may still be subject to certain taxes. Mutual fund performance will vary based on the performance of the underlying assets, changes in interest rates, and market conditions. Risks may be magnified depending on how a fund invests or uses certain strategies. Additional information is available in the fund’s prospectus, which can be obtained from your IAR or the fund company. Options: Options trading can involve greater price volatility than the underlying securities. Buying and writing options are complex strategies that carry above-average investment risks. Securities Lending: Securities lending involves the risk that the borrower may fail to return the securities, or that the collateral provided may decline in value. These situations may also lead to adverse tax consequences for the fund. Special Purpose Acquisition Company (SPACs): SPACs, which raise capital through IPOs to acquire private companies, carry unique risks. They typically have no operating history, making it difficult to assess management performance. The timeline to complete a merger can be uncertain, leading to periods of illiquidity. Success depends heavily on management’s ability to identify and execute a profitable acquisition. Risks include potential dilution, regulatory changes, and market volatility. ITEM 9: DISCIPLINARY INFORMATION TCM has no legal, financial, or other disciplinary events to report. Additional information is available at www.FINRA.org or www.SEC.gov. • Triumph Capital Management CRD Number: 282814 • Triumph Capital Management SEC Number: 801-107312 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Insurance TCM’s IARs may be appointed as agents with various life, disability, or other insurance companies and may receive commissions, trails, or other compensation from product sponsors for insurance transactions conducted on behalf of clients. Insurance business is processed through Triumph Capital, LLC or other Page 17 of 25  ADV Part 2A - Firm Brochure approved third-party agencies. Clients are under no obligation to purchase insurance products through TCM or its IARs. In most cases, IARs spend less than 10% of their time on insurance-related business. You may review your IAR’s ADV Form 2B for details on their specific insurance activities. Derek Eichenwald owns Triumph Capital, LLC, an insurance agency that offers various insurance products and earns customary fees from insurance sales. This creates a potential conflict of interest, as these sales may provide an incentive to recommend products based on compensation earned by the advisor or other supervised persons. To address this conflict, our firm is committed to acting in the client’s best interest in accordance with our fiduciary duty. Triumph Capital Foundation Triumph Capital Foundation (the “Foundation”) is a nonprofit private foundation established in 2022 and managed by individuals who are also employed by TCM. The Foundation’s primary purpose is to facilitate charitable giving. Because the Foundation maintains an advisory relationship with TCM and compensates TCM for its services, a material conflict of interest exists when recommending the Foundation for charitable contributions. TCM has a financial incentive to recommend the Foundation over other nonprofit organizations. Individuals affiliated with the Foundation have disclosed this relationship in their ADV Form 2B. Outside Business Activity IARs of TCM may engage in Outside Business Activities (“OBAs”), which are fully described and disclosed in each IAR’s ADV Form 2B. OBAs can create a material conflict of interest if an IAR has an incentive to devote more time to their outside activities than to their advisory relationship with you. TCM monitors and approves all OBAs to help mitigate this potential conflict. More information about your IAR’s outside business activities can be found by visiting FINRA BrokerCheck at www.finra.org. If you would like a copy of your IAR’s most recent ADV Form 2B, please contact TCM’s Chief Compliance Officer, Brandon Drespling. Other Conflicts of Interest As a fiduciary, TCM and its IARs have an affirmative duty of care, loyalty, honesty, and good faith to act in the best interests of clients. This duty is fulfilled by striving to avoid conflicts of interest and by fully disclosing all material facts when a conflict does arise. A conflict of interest occurs when an IAR’s personal interests are inconsistent with the interests of TCM’s clients or with IAR’s service to the firm. IARs are also expected to avoid situations that could even appear to present a conflict or impropriety. Conflicts of interest may arise if TCM or its IARs have reason to favor one client over another—such as prioritizing larger accounts over smaller accounts, accounts in which employees hold material personal investments, or accounts belonging to close friends or relatives. TCM strictly prohibits favoritism that would constitute a breach of fiduciary duty. IARs are prohibited from using knowledge of pending or potential securities transactions for clients to profit personally—whether directly or indirectly—including by buying or selling such securities for their own accounts. Page 18 of 25  ADV Part 2A - Firm Brochure Mr. Brandon Drespling and Mr. Derek Eichenwald are both principals of TCM. While both are supervised by the Compliance Department, the Compliance Department ultimately reports to them. This structure may be considered a conflict of interest. If you have questions regarding the supervision of Mr. Drespling or Mr. Eichenwald, please contact the Compliance Department before engaging in advisory services with TCM. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING TCM and its associated persons may invest for their own accounts or hold financial interests in the same securities or other investments that TCM recommends or acquires for your account. They may also engage in transactions that are the same as—or different from—those recommended to or executed for your account. This presents a potential conflict of interest. TCM recognizes its fiduciary duty to place your interests first and has implemented policies to avoid or mitigate such conflicts. TCM has adopted a Code of Ethics that establishes the standards of conduct expected of our advisory personnel. The Code addresses, among other topics, personal trading, gifts, prohibitions on the use of inside information, recommendations involving account rollovers, and other situations where conflicts of interest may arise. The Code of Ethics is designed to: • Protect TCM’s clients by deterring misconduct. • Education personnel on our expectations and applicable laws. • Remind personnel of their position of trust and the need to act with complete propriety. • Safeguard TCM’s reputation. • Guard against violations of securities laws. • Establish procedures for monitoring compliance with TCM’s ethical principles. To ensure our fiduciary responsibilities are upheld, TCM has established the following restrictions: • Directors, officers, or employees may not buy or sell securities for their personal portfolios if the decision is based, in whole or in part, on information obtained through their employment—unless that information is also available to the public through reasonable inquiry. No one at TCM may place their own interests ahead of a client’s. • TCM maintains a list of all securities holdings of individuals with access to advisory recommendations. These holdings are reviewed regularly by an appropriate officer of TCM. • Clients have the unrestricted right to decline any advice provided, except in situations where TCM has discretionary authority over the account. • Clients have the unrestricted right to select any broker-dealer, except when TCM has discretionary authority. • TCM prohibits the use of leveraged and inverse intraday ETFs and ETNs in client accounts. • TCM prohibits cross trades in client accounts. • All personnel must comply with all applicable federal and state regulations governing registered investment advisory practices. You may request a complete copy of our Code of Ethics by contacting TCM. Page 19 of 25  ADV Part 2A - Firm Brochure ITEM 12: BROKERAGE PRACTICES We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are, overall, advantageous when compared to other available providers and their services. When evaluating custodians/brokers, we consider a broad range of factors, including but not limited to: • Ability to maintain the confidentiality of trading intentions • Timeliness of execution and trade confirmations • Liquidity of securities traded • Willingness to commit capital • Ability to place trades in challenging market conditions • Availability of research and investment ideas • Execution facilitation services • Recordkeeping and custody services • Frequency and correction of trading errors • Access to multiple market venues • Expertise with specific securities • Financial condition and business reputation Charles Schwab and Fidelity Investments Based on these considerations, our firm primarily recommends Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments (“Fidelity”)—both registered broker-dealers and members of the SIPC—as custodians for client accounts. These firms are independent and unaffiliated SEC-registered broker- dealers. Schwab and Fidelity will hold your assets in a brokerage account and execute securities transactions as instructed by you and/or us. While we recommend these custodians/brokers, the decision is yours, and you will open your account directly with the custodian/broker by entering into an account agreement with them. We do not open the account on your behalf, though we may assist you in the process. Schwab and Fidelity may make certain research and brokerage services available at no additional cost to our firm. These services may be directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by Schwab and Fidelity may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab and Fidelity to our firm in the performance of our investment decision-making responsibilities. As a result of receiving these services, we may have an incentive to continue using, or to expand our use of, Fidelity and Schwab. Our firm considered this potential conflict of interest when deciding to establish relationships with these custodians. We have determined that these relationships are in the best interest of our clients and are consistent with our fiduciary duty, including our obligation to seek best execution. Schwab and Fidelity charge brokerage commissions and transaction fees for certain securities transactions Page 20 of 25  ADV Part 2A - Firm Brochure (e.g., transaction fees for some no-load mutual funds and commissions for individual equity and debt securities). They also provide access to many no-load mutual funds without transaction charges, as well as other no-load funds at nominal transaction charges. Their commission rates are generally discounted from standard retail rates. However, the commissions and transaction fees charged by these custodians may be higher or lower than those charged by other custodians or broker-dealers. Additionally, our clients may pay a commission to Schwab and Fidelity that is higher than what another qualified broker-dealer might charge for the same transaction if we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. When seeking best execution, the determining factor is not the lowest possible cost, but rather whether the transaction provides the best overall qualitative execution. This includes consideration of the full range of a broker-dealer’s services, such as the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, while we strive to obtain competitive rates for the benefit of all clients, we may not always secure the lowest possible commission rates for specific transactions. Schwab and Fidelity do not charge transaction fees for U.S.-listed equities and exchange-traded funds. We do not receive soft dollar benefits in excess of what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The research products and services obtained by our firm will generally be used to service all of our clients, but not necessarily all at any one particular time. We do not acquire client brokerage commissions (or markups or markdowns). We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits. We do not receive brokerage for client referrals. We provide investment management services to a variety of clients. At times, portfolio transactions may be executed under concurrent authorizations to buy or sell the same security for multiple accounts with similar investment objectives. While such concurrent transactions could potentially be advantageous or disadvantageous to one or more accounts, we execute them only when we believe doing so is in the best interest of the accounts involved. When concurrent transactions occur, our goal is to allocate executions in a manner we deem equitable to all participating accounts. In each situation, we strive to allocate trades as fairly as possible, considering client objectives, current asset allocation, and the availability of funds. We use methods such as price averaging, proration, and other consistently applied, non-arbitrary allocation practices. Trade Errors TCM has implemented procedures to help prevent trade errors; however, errors in client accounts cannot always be avoided. In keeping with our fiduciary duty, it is TCM’s policy to correct trade errors in a manner that serves the best interest of our clients. If a client causes the trading error, the client will be responsible for any resulting loss. Depending on the circumstances, the client may also be unable to retain any gains that result from the correction. Page 21 of 25  ADV Part 2A - Firm Brochure If the client did not cause the trading error, the client will be made whole. When TCM is responsible, we will absorb any resulting loss. If the custodian or broker is responsible, they will be required to cover all costs related to the error. ITEM 13: REVIEW OF ACCOUNT The underlying securities within the investment supervisory services are regularly monitored. Reviews are conducted by your IAR and further overseen by the supervising principal. An annual review is typically conducted either in person or by telephone. The purpose of these reviews is to ensure that the investment plan continues to align with the client’s goals, objectives, and overall risk tolerance. More frequent reviews may be initiated if there are material changes in factors such as your personal circumstances, or shifts in the market, political, or economic environment. Clients are strongly encouraged to notify TCM of any changes in their personal circumstances. Statements and Reports Clients are urged to compare the reports provided by TCM with the account statements received directly from their account custodian. Upon request, TCM can provide performance and position summary reports, which may also be delivered at client meetings. In addition, the custodian/broker for each client account will provide official account statements at least quarterly. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Custodians TCM receives economic benefits from custodians in the form of support products and services that are made available to us and to other independent investment advisors whose clients maintain accounts on these custodial platforms. We benefit from these products and services because, if not provided, the cost would otherwise be borne directly by TCM. This creates a conflict of interest. Additionally, the amount of compensation TCM receives may vary depending on the custodian or broker recommended for client accounts. As a result, TCM has a conflict of interest in making such recommendations. Clients should carefully consider these conflicts when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are further described above in Item 12: Brokerage Practices. IAR Compensation The IARs of TCM often receive a portion of the investment advisory fees paid by clients. Additionally, some IARs may be licensed to offer insurance products and can receive customary commissions on the sale of such products. These commissions are separate from the advisory fee program. When selling insurance products, a conflict of interest may arise due to the commission or fee structure associated with the insurance business. As a result, your IAR may have an incentive to recommend an Page 22 of 25  ADV Part 2A - Firm Brochure insurance transaction for the purpose of generating compensation rather than basing the recommendation solely on your needs. TCM seeks to mitigate this conflict by monitoring its IARs’ outside business activities and reviewing their overall recommendations to clients. Expense Reimbursement TCM and its IARs may receive expense reimbursements for travel and/or marketing from distributors of investment and insurance products. Travel reimbursements generally result from attendance at due diligence or investment training events hosted by product sponsors. Marketing reimbursements typically arise from informal cost-sharing arrangements in which product sponsors underwrite certain marketing expenses, such as advertising, publishing, or seminar costs. Although these reimbursements are not contingent upon specific sales quotas, they are generally provided by sponsors for whom sales have been made or are anticipated. Outside Compensation TCM may enter into written referral agreements with third parties through which the third party may, from time to time, refer clients who establish accounts and enter into advisory relationships with TCM. In such cases, TCM agrees to pay the third party a referral fee equal to a percentage of the fees received by TCM from the referred client. Referral fees may also be shared among multiple third parties who jointly participate in referring a client. TCM discloses any such referral arrangement to the client prior to entering into an advisory agreement. All referral agreements are governed by Rule 206(4)-1 under the Investment Advisers Act of 1940. TCM refers clients only to professionals it believes are competent and qualified in their field. However, it is ultimately the client’s responsibility to evaluate the provider, and the decision whether to engage a recommended firm rests solely with the client. Clients are under no obligation to purchase any products or services from these professionals, and TCM has no control over the services provided by another firm. Clients who choose to engage these professionals will enter into a separate agreement with that firm. Any fees charged by the other firm are separate from, and in addition to, those charged by TCM. If the client wishes, TCM will coordinate with these professionals or with the client’s other advisors (such as an accountant or attorney) to help ensure that the provider understands the client’s investments and to support the coordination of services. TCM will never share information with an unaffiliated professional without the client’s prior authorization. ITEM 15: CUSTODY Custody, as it applies to investment advisors, is defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to the physical possession of client assets. If an investment advisor has the ability to access or control client funds or securities, they are considered to have custody and must implement appropriate procedures to safeguard those assets. Advisory Fees TCM is responsible for calculating and deducting advisory fees from client accounts held with the Page 23 of 25  ADV Part 2A - Firm Brochure qualified custodian. Written client authorization is always obtained before any fees are deducted, and all fees are reflected on the account statements provided directly by the custodian. The custodians we work with issue independent statements at least quarterly, detailing account balances, transaction history, and any fees debited from your account. Third Party Money Movement The SEC issued a no-action letter with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940. The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodians: • The client submits a written instruction to the qualified custodian that includes the client’s signature, the third party’s name, and either the third party’s address or the account number at the custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing—either on the custodian’s form or separately—to direct transfers to the third party, either on a specified schedule or as needed. • The qualified custodian verifies the instruction (e.g., through a signature review or other appropriate method) and promptly provides the client with a transfer-of-funds notice after each transfer. • The client retains the ability to terminate or amend the instruction at any time by notifying the qualified custodian. • The investment adviser has no authority to designate or change the identity, address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records confirming that the third party is not a related party of the adviser and is not located at the adviser’s address. • The qualified custodian sends the client a written initial confirmation of the instruction and an annual notice reconfirming it. We encourage clients to contact us with any questions regarding custody, safety, or security of their assets. ITEM 16: INVESTMENT DISCRETION Clients grant our firm investment discretion through an executed investment advisory agreement. By providing this discretion, clients authorize us to determine which securities are bought and sold, the amounts involved, and the prices at which transactions are executed. If a client grants our firm only non-discretionary authority, we must obtain the client’s permission before effecting any securities transactions. Clients may also impose limitations on our discretionary authority in the form of specific constraints, provided these limitations are documented with our firm’s written acknowledgment. ITEM 17: VOTING CLIENT SECURITIES Proxy Voting Authority Page 24 of 25  ADV Part 2A - Firm Brochure We do not, and will not, accept proxy authority to vote client securities. Clients will receive proxies and other solicitations directly from their custodian or transfer agent. If any proxies are sent to our firm in error, we will forward them to the client and request that the sender mail them directly to the client in the future. Clients are welcome to call, write, or email us with any questions regarding specific proxy votes or other solicitations. Class Action Claims TCM has engaged a third-party service provider, Chicago Clearing Corporation (“CCC”), to monitor and file securities class action litigation claims with claims administrators on behalf of TCM clients. To facilitate this service, it may be necessary to share client information—such as name, account number, and address—with CCC. TCM does not receive any fees or remuneration in connection with this service, nor does it receive any compensation from CCC or any other third-party provider. CCC charges a fee equal to seventeen and a half percent (17.5%) of all claims it collects on behalf of TCM clients. This fee is deducted and retained by CCC from the proceeds paid by the claims administrator. All claims are subject to this fee except SEC Fair Fund cases, in which CCC does not collect a fee. Clients may opt out of this service at any time. If a client chooses to opt out, TCM will not advise on or take any action regarding class action litigation related to investments held in, or previously held in, the client’s account. Clients should be aware that recoveries from class action settlements may be lower if not using CCC’s services. Additionally, fees for comparable services may vary, and lower-cost alternatives may be available from other providers. ITEM 18: FINANCIAL INFORMATION We are not required to provide financial information in this Brochure because we do not require the prepayment of more than $1,200 in fees six months or more in advance, we do not have any financial condition or commitment that would impair our ability to meet contractual and fiduciary obligations to clients, and we have never been the subject of a bankruptcy proceeding. Page 25 of 25 

TRIUMPH CAPITAL MANAGEMENT FORM ADV PART 2A APPENDIX 1 WRAP FEE BROCHURE August 15, 2025 This Wrap Fee Brochure provides information about the qualifications and business practices of Triumph Capital Management (hereinafter referred to as “TCM”, “us”, “Firm”, or the “Advisor”). If you have any questions about the contents of this brochure, please contact us by telephone at (720) 399-5555 or by email at info@TriumphCapitalManagement.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about Triumph Capital Management is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD # 282814. Please note that the use of the term “registered investment adviser” and description of Triumph Capital Management and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees Triumph Capital Management Headquarters: 1610 Wynkoop Street, Suite 550, Denver, CO 80202 Phone: (720) 399-5555 E-Mail: Info@TriumphCapitalManagement.com Website: www.TriumphCapitalManagement.com  ADV Part 2A Appendix 1 – Wrap Fee Brochure ITEM 2: MATERIAL CHANGES Triumph Capital Management is required to advise you of any material changes to this Wrap Fee Brochure from our last annual update. Since our last annual amendment, we have the following material change(s) to disclose: Item 4: Services, Fees and Compensation – Several changes were made to better define our services to clients and the fees associated with those services. Item 9: Additional Information – Several changes were made to provide a clearer description of the custodian/broker responsible for holding your assets and executing transactions, along with the addition of Fidelity Investments as a recommended custodian for client accounts. Item 9: Additional Information – Several revisions were made to clarify how custody applies to the deduction of advisory fees from client accounts, as well as to money movement capabilities. Page 2 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure ITEM 3: TABLE OF CONTENTS ITEM 2: MATERIAL CHANGES ........................................................................................................... 2 ITEM 3: TABLE OF CONTENTS .......................................................................................................... 3 ITEM 4: SERVICES, FEES AND COMPENSATION ................................................................................ 4 ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ......................................................... 12 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ..................................................... 12 ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ....................................... 16 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ............................................................. 16 ITEM 9: ADDITIONAL INFORMATION ............................................................................................. 17 Page 3 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure ITEM 4: SERVICES, FEES AND COMPENSATION Firm Description TCM is dedicated to providing individuals and other types of clients with a broad range of investment advisory services. We are committed to helping clients build, manage, and preserve their wealth through strategic guidance tailored to their stated financial goals. The firm was established in the State of Colorado and has been in business since 2016. TCM’s principal owner is Derek Eichenwald. Investment Management Services and Fees Our Investment Management service provides discretionary asset management for a fee. It is designed to help clients meet their financial goals through the use of investment strategies tailored to their individual circumstances. We conduct at least one meeting—often more—either in person (when possible) or by telephone or video conference, to gain an understanding of the client’s financial situation, resources, goals, and risk tolerance. This information enables TCM to determine an appropriate investment approach and portfolio composition. Once the client agrees to the proposed investment plan, we assist with establishing or transferring investment accounts so that TCM can manage the portfolio. After accounts are under our management, we review them on a regular basis and at least annually. We may periodically rebalance or adjust accounts as needed. Clients may request reasonable restrictions on the types of investments held in their portfolio; however, restrictions on certain securities or categories of securities may not always be feasible given the practical challenges of managing the account under such limitations. Clients are responsible for promptly notifying us of any significant changes in their financial or personal circumstances so that we may take them into account when managing their investments. While performing services, TCM is not required to verify information provided by the client or by other professionals engaged by the client. TCM charges a fee as compensation for providing investment management services on your account. These services include advisory and consulting services, trade execution, investment supervision, and other account maintenance activities. In addition, TCM’s custodian may charge transaction costs, custodial fees, redemption fees, retirement plan fees, alternative asset fees, and other administrative fees or commissions. Please see “Additional Fees and Expenses” below for further details. Certain assets (e.g., mutual funds, ETFs, alternative investments, UITs, MLPs, etc.) deposited or purchased in your accounts may also be subject to separate management and administrative fees, as described in the applicable prospectus or agreement. These fees are independent of TCM’s fees and should be disclosed by the custodian or contained in the investment’s offering documents. Clients should be aware that fees for comparable services vary, and lower fees may be available from other sources. The annual fee for portfolio management services is billed quarterly or monthly, either in arrears or in advance. The fee is based on the average daily market value of the account(s) during the billing period, or on the prior quarterly or monthly ending balance. Fees are calculated on a calendar-year basis (including leap years). Because of deposits or unsettled trades, the prior quarterly or monthly ending Page 4 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure balance used for fee calculation may differ from the account value shown on the custodian’s statement. Fees are assessed on all assets under management—including securities, cash, and money market balances—unless otherwise noted in the client agreement. TCM may exclude certain positions for billing purposes. Margin balances do not reduce the value of assets under management. For accounts held at Charles Schwab, clients can view both average daily balances and end-of-period balances through Black Diamond and Schwab portals. TCM’s maximum annual investment advisory fee is 3.00%. The specific fee applicable to each client is outlined in the investment advisory agreement. Fees may vary depending on account size, portfolio complexity, account activity, or other factors agreed upon by TCM and the client. In some cases, fees and billing arrangements may be negotiated. TCM also charges a minimum fee of $180 annually for accounts held at Charles Schwab, though this fee may be waived or reduced at TCM’s discretion. In certain cases, TCM may aggregate household account balances to determine the applicable advisory fee. This consolidation allows clients to benefit from a higher combined asset total, which may reduce the effective advisory fee under the applicable schedule. The independent qualified custodian holding client assets will debit the advisory fee directly from the account and remit payment to TCM. Clients provide written authorization permitting fees to be deducted directly from their custodial account. Custodians provide independent account statements at least quarterly, showing account balances, transaction history, and all fees deducted, including TCM’s advisory fees. Clients are encouraged to carefully review these statements for accuracy. At TCM’s discretion, advisory fees may also be paid by check. Clients with questions about their management fee calculation or the data inputs used are encouraged to contact the TCM Compliance Department, which will provide full details regarding fees. Either TCM or the client may terminate the management agreement upon written notice to the other party. Upon termination, the management fee will be prorated through the effective date of termination for the quarter or month in which notice was given, and any unearned fees will be refunded or additional fees billed. After termination, clients are solely responsible for monitoring and managing the securities in their account, and TCM will have no further obligation to act on or advise regarding those assets. Wrap Fee Some of TCM’s portfolio management services utilize a wrap fee program. Wrap fee programs allow the client to pay a comprehensive fee for management, brokerage, clearing, custody, and administrative services. TCM will receive a portion of the wrap fee for its services. Third Party Asset Managers and Fees TCM may utilize the investment strategies of Third-Party Asset Managers (“TPAMs”). TPAMs are evaluated and selected on a discretionary basis pursuant to the client’s investment advisory agreement with our firm. Before selecting TPAMs, we ensure they are properly licensed or registered and consider factors such as their experience, assets under management, performance record, level of client service, investment style, and overall investment process. A copy of the TPAM’s disclosure brochure will be provided to the client. The terms and conditions under which a client engages a TPAM will be set forth either in the client’s Page 5 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure agreement with our firm or in a separate written agreement between the client and the TPAM. Clients may terminate these agreements at any time with written notice. Fees may also be charged by TPAMs for services they provide to our clients, in addition to the fees assessed by our firm. The terms and conditions of a client’s engagement with a TPAM will be outlined in a separate agreement between the client and the designated third party. The fee you pay to your IAR is separate from, and in addition to, the fee you pay to the TPAM. In addition to TCM’s client agreement and disclosure brochure, clients should carefully review the disclosure brochure of the selected TPAM for a detailed breakdown of their fees. Either party may terminate the TPAM agreement at any time with written notice to the other party. Managed by Triumph Capital Management at Security Benefit Program and Fees The Managed by TCM at Security Benefit Program utilizes investment models to manage client accounts opened and held at Security Benefit. The mutual funds available on the Security Benefit platform are the only options that may be included in the allocation mix of these models. The models are reviewed monthly, and the investments within them may be reallocated. However, reallocations will not occur if it is determined that no changes are appropriate. Tactical Model at Security Benefit: The Tactical Model seeks to provide absolute returns during any market cycle by employing a strategic rotation across commodities, REITs, bonds and other fixed- income investments, international equities, domestic equities, and cash. Using funds available on the Security Benefit platform, the model emphasizes asset classes that TCM believes are demonstrating strength while avoiding those that appear to be in decline or show limited growth potential. Conservative Model at Security Benefit: The Conservative Model seeks to preserve principal rather than maximize appreciation. It focuses on capital preservation and risk minimization through a diversified and balanced allocation across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. Moderate-Conservative Model at Security Benefit: The Moderate-Conservative Model emphasizes principal preservation while allowing for a modest degree of risk and volatility in pursuit of limited appreciation. This model accepts lower returns in exchange for reduced risk, utilizing a diversified and balanced allocation across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. Moderate Model at Security Benefit: The Moderate Model seeks to balance risk and return equally. It accepts moderate risk in pursuit of higher long-term returns and may incur short-term losses to achieve long-term growth. Allocations are diversified across commodities, REITs, bonds and other fixed- income investments, international equities, domestic equities, and cash. Aggressive-Moderate Model at Security Benefit: The Aggressive-Moderate Model emphasizes higher long-term returns and accepts significant risk, including the potential for large losses. It maintains a diversified allocation across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. Page 6 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure Aggressive Model at Security Benefit: The Aggressive Model seeks to maximize returns and accepts substantial risk, including the potential loss of principal, in pursuit of higher results. Allocations are diversified across commodities, REITs, bonds and other fixed-income investments, international equities, domestic equities, and cash. All models involve risk, including the potential loss of principal. Past performance is not a guarantee of future results. The Managed by TCM at Security Benefit models may not achieve their stated objectives. Market and economic conditions could adversely affect performance and may result in capital losses. Clients should carefully consider the charges, risks, expenses, limited investment options, and their overall objectives before investing. The models are limited to the funds, ETFs, and/or sub-accounts available on the Security Benefit platform. They are not intended to manage all client assets or address every financial need. Accounts enrolled in the Managed by TCM at Security Benefit Program will be managed according to the model selected in the client agreement, though allocations may change over time to reflect updated client objectives. Model allocations are not personalized to individual investors. Accounts are custodied at Security Benefit, which provides at least quarterly statements. Clients are encouraged to review these statements carefully and compare them to any reports provided by TCM. Verify that account transactions align with your stated investment goals and objectives. Contact your IAR or TCM’s Chief Compliance Officer with any questions or concerns. The Managed by TCM at Security Benefit Program is limited in scope and not intended to address all advisory needs. Additional services are available through separate agreements. Participation is subject to TCM’s discretion, and TCM may restrict or prohibit participation at any time, for any reason. Advisory fees for the Managed by TCM program at Security Benefit range from 1.0% to 1.5%, depending on the Security Benefit option selected. Fees are charged quarterly in advance, based on the prior quarter’s ending account balance. Because of deposits or unsettled trades, the balance used for fee calculation may differ from the account value shown on the custodian’s statement. Clients can access prior quarter account balances through their quarterly Security Benefit statement. If you have any questions about the accuracy of your management fee or the data inputs used to calculate it, please contact the TCM Compliance Department. The independent qualified custodian, Security Benefit, debits advisory fees directly from your account and remits payment to TCM. Written client authorization is required to permit these fee deductions. Security Benefit will provide an account statement at least quarterly, showing all amounts deducted from your account. Security Benefit determines the values of the assets in your portfolio. In addition to advisory fees, Security Benefit charges an annual custodial fee of 0.25%. Accounts with balances under $50,000 are subject to an additional $35 annual fee (waived for balances of $50,000 or more). These fees are separate from, and in addition to, the TCM advisory fee of 1.0% to 1.5%. Please review the Security Benefit Mutual Fund Program Brochure and the applicable prospectuses for further details on fees and expenses. In addition, securities used in the Managed by TCM program at Security Benefit (e.g., mutual funds, ETFs, sub-accounts, etc.) may be subject to separate management and administrative fees as described in each prospectus. These fees are independent of the TCM advisory fee and Security Benefit custodial fees. Clients should be aware that fees for comparable services may vary and lower-cost alternatives may be Page 7 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure available from other sources. If a sales load was paid on a Security Benefit purchase, TCM does not permit its IARs to enroll clients into the Managed by TCM program at Security Benefit. If your IAR did not sell the Security Benefit program to you, this restriction may not apply. Security Benefit provides quarterly statements detailing fees and expenses. Clients should carefully review these statements and verify the calculation of all fees. Please note that the custodian does not verify the accuracy of TCM’s fee calculations. Either TCM or the client may terminate the Managed by TCM at Security Benefit advisory agreement at any time by providing written notice to the other party. Triumph Turnkey Asset Management Program and Fees Similar to outside TPAMs, TCM offers the Triumph Turnkey Asset Management Program (“TTAMP”) as an investment option for its IARs. The TTAMP provides model portfolios and other portfolio management solutions that are managed by TCM and made available for use by IARs. The services provided, along with the roles and responsibilities of the client, the IAR, and TCM, are outlined in the client agreement. Clients retain the ability to direct their account in a manner that aligns with their objectives, including determining asset allocation, selecting models, and placing reasonable restrictions on the account. Full model allocation may be limited by account size, and smaller account values may result in allocation variances that differ from the intended TTAMP model. By enrolling in TTAMP, clients grant TCM discretionary authority to place trades in their account and, when appropriate, to adjust asset allocation or model selection in line with the client’s stated investment objectives or restrictions. Once an account is established, TCM monitors the asset allocation and model selections, executing trades as needed. The IAR continues to service the client relationship by meeting with the client at least annually and communicating any necessary updates or changes to TCM. TCM charges a monthly or quarterly fee that covers the costs of administering the TTAMP, as well as portfolio and model construction, trading, custody, and clearing. TCM offers flexibility in how and when the TTAMP fee is debited from client accounts. The fee may be calculated monthly or quarterly, in advance or in arrears, as a percentage of account value based either on the average daily balance during the billing period or on the prior month’s or quarter’s ending balance. Because of deposits or unsettled trades, the prior month’s or quarter’s ending balance used for fee calculation may differ from the value shown on the custodian statement. The specific calculation method will be clearly outlined in the client agreement under Management Fees and Charges. In most cases, the TTAMP fee is debited quarterly, based on the prior quarter’s ending balance, and is separate from the IAR/FP fee and any other applicable costs, such as internal fund expenses or custodian maintenance fees. However, if requested, the TTAMP fee and the IAR/FP fee may be combined and debited together. This arrangement will also be detailed in the client agreement under Management Fees and Charges. For clients with multiple accounts, unless otherwise specified in the client agreement, each account is treated separately for purposes of calculating and debiting the program fee. Through the account agreement, clients authorize TCM to debit the account and remit the IAR/FP fee as outlined in the Page 8 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure agreement. This fee compensates the IAR/FP for introducing the client to TTAMP, gathering and communicating financial information, assisting with portfolio allocation and model selection, maintaining the account, communicating material changes in financial needs, and performing other administrative duties. The IAR/FP fee is negotiated directly between the client and the IAR/FP and documented in the client agreement. Clients should note that participation in TTAMP may present a conflict of interest, as lower-cost investment programs may be available outside of TCM and TTAMP. The standard annual tiered TTAMP fee schedule is presented in the chart below. Please note that actual fees may vary based on the agreement with the IAR/FP and the distribution platform. For full disclosure of program fees applicable to your account(s), please refer to your client agreement under Management Fees and Charges. Triumph Turnkey Asset Management Typical Tiered Fee (may vary) Account Value TTAMP Fee $0.00 - $100,000 0.90% $100,000 - $250,000 0.85% $250,000 - $500,000 0.80% $500,000 - $1,000,000 0.75% $1,000,000 - $5,000,000 0.65% $5,000,000 - $10,000,000 0.55% Over $10,000,000 0.35% • TTAMP has a minimum annual fee of $180 for accounts held at Charles Schwab, which TCM may waive or reduce. In most cases, the TTAMP fee is separate from, and in addition to, the IAR/FP fee. • • Please refer to your client agreement, Section: Management Fees and Charges. Variable Product Advisory Management Fees A TCM IAR may offer investment management services on the sub-account allocations within a variable product you own, such as a variable annuity or a variable universal life insurance policy. This service may be provided on a discretionary basis and will be detailed in your advisory agreement. When offering this service, your IAR may apply their own analysis, research methods, investment style/strategy, and ongoing management philosophy. If you engage your IAR to provide advice regarding your variable product, you will pay a separate advisory fee for this service. This fee is in addition to the internal costs of the variable product itself and is calculated as a percentage of your variable product account value, including any cash or cash equivalent positions. When provided directly by your IAR, the advisory fee will not exceed 2% annually. The specific advisory fee applicable to you will be clearly stated in the advisory agreement you sign with your IAR. If a commission was paid on the sale of a variable product, TCM prohibits its IARs from charging an advisory fee for this service for a period of two years following the sale. If your IAR did not sell the Page 9 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure variable product to you, this two-year restriction may or may not apply. Alternative Product Advisory Management Fees If you engage your IAR to provide advice regarding your alternative investments, you will pay a separate advisory fee for this service. This fee is in addition to the internal costs associated with the alternative investment and is calculated as a percentage of the investment account value, as reported by the custodian where the investment is held. When provided directly by your IAR, the advisory fee will not exceed 3% annually. The specific advisory fee will be clearly stated in the advisory agreement you sign with your IAR. Because certain alternative investments involve commission payments and various purchase options, a conflict of interest may arise. This may create an incentive for your IAR to make recommendations based on compensation rather than solely on your needs. Alternative investments may also offer different share classes, including load and no-load options. Clients are strongly encouraged to review the prospectus carefully and discuss these considerations with their IAR. If a commission was paid on the sale of an alternative investment, TCM prohibits its IARs from charging an advisory fee for this service for a period of three years following the sale. If your IAR did not sell the alternative investment to you, this three-year restriction may or may not apply. Self-Directed Brokerage Account Fees A Self-Directed Brokerage Account (“SDBA”) is a brokerage window that allows participants to select investment options outside of their employer’s core plan offerings, while still remaining within the retirement plan and maintaining the associated tax advantages. An SDBA provides greater flexibility and control, enabling more diversified, targeted, and strategic retirement investing. This option is intended for investors who acknowledge and understand the risks associated with many of the investments available through an SDBA. Your IAR will work with you to identify your investment goals, objectives, and risk tolerance, and will assist in creating a portfolio allocation designed to meet your objectives while complying with any plan-specific restrictions. Advisory accounts within an SDBA may involve the purchase and/or sale of securities. These accounts can be managed on either a discretionary or non-discretionary basis, depending on the plan and the participant’s needs. Many SDBAs restrict or prohibit certain activities, including but not limited to: • Selling short or using margin • Trading in foreign securities (stocks, bonds) • Trading in bulletin board or pink sheet stocks • Trading real estate/property outside of approved REITs • Trading currencies • Trading limited partnerships • Trading futures/commodities • Trading promissory notes • Trading collectibles • Trading municipal bonds Page 10 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure TCM’s fee schedule for SDBA accounts is the same as the TCM wrap fee schedule, which is negotiated between the plan participant and TCM, up to a maximum of 3.00% annually. TCM charges a minimum fee of $180 annually for accounts held at Charles Schwab. TCM may waive or reduce this fee. Client will pay an annualized fee, which will cover advisory services provided to your account. Separate transaction charges for trading may be charged by your custodian. Ancillary charges such as account fees or transfer costs, etc., are also assessed against the account. Depending on the plan, additional trading fees can apply to the SDBA account(s). Therefore, unlike TCM’s wrap fee program above, the trading in the account could result in additional transaction fees. Please refer to your plans SDBA window, your retirement plan document, and consult your custodian for a complete list of fees, commissions, and other service fees that may apply. Additional Fees and Expenses Depending on your account type or the advisory program selected, additional third-party fees may apply in addition to the advisory fees paid to TCM. These fees may include, but are not limited to: • Custodial or platform service charges • Brokerage or transaction fees • Regulatory fees (e.g., SEC fees) • Account activity, wire transfer, or electronic funds processing fees • ADR fees • Account maintenance or closure fees • Mutual fund operating fees and expenses • Markups/markdowns, bid-ask spreads, and selling concessions • Margin interest • Miscellaneous fees, including transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, legally required fees, and other similar charges Your account fee structure is outlined in your Client Agreement and in the disclosure documents provided by the custodian. These materials specify any additional fees that may apply to your account. If you have questions about your program type or potential costs, please contact TCM directly. IAR Compensation The IARs of TCM often receive a portion of the investment advisory fees paid by clients. Additionally, some IARs may be licensed to offer insurance products and can receive customary commissions on the sale of such products. These commissions are separate from the advisory fee program. When selling insurance products, a conflict of interest may arise due to the commission or fee structure associated with the insurance business. As a result, your IAR may have an incentive to recommend an insurance transaction for the purpose of generating compensation rather than basing the recommendation solely on your needs. TCM seeks to mitigate this conflict by monitoring its IARs’ outside business activities and reviewing their overall recommendations to clients. Page 11 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure Expense Reimbursement TCM and its IARs may receive expense reimbursements for travel and/or marketing from distributors of investment and insurance products. Travel reimbursements generally result from attendance at due diligence or investment training events hosted by product sponsors. Marketing reimbursements typically arise from informal cost-sharing arrangements in which product sponsors underwrite certain marketing expenses, such as advertising, publishing, or seminar costs. Although these reimbursements are not contingent upon specific sales quotas, they are generally provided by sponsors for whom sales have been made or are anticipated. Outside Compensation TCM may enter into written referral agreements with third parties through which the third party may, from time to time, refer clients who establish accounts and enter into advisory relationships with TCM. In such cases, TCM agrees to pay the third party a referral fee equal to a percentage of the fees received by TCM from the referred client. Referral fees may also be shared among multiple third parties who jointly participate in referring a client. TCM discloses any such referral arrangement to the client prior to entering into an advisory agreement. All referral agreements are governed by Rule 206(4)-1 under the Investment Advisers Act of 1940. TCM refers clients only to professionals it believes are competent and qualified in their field. However, it is ultimately the client’s responsibility to evaluate the provider, and the decision whether to engage a recommended firm rests solely with the client. Clients are under no obligation to purchase any products or services from these professionals, and TCM has no control over the services provided by another firm. Clients who choose to engage these professionals will enter into a separate agreement with that firm. Any fees charged by the other firm are separate from, and in addition to, those charged by TCM. If the client wishes, TCM will coordinate with these professionals or with the client’s other advisors (such as an accountant or attorney) to help ensure that the provider understands the client’s investments and to support the coordination of services. TCM will never share information with an unaffiliated professional without the client’s prior authorization. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS TCM provides investment advice to individuals, high-net-worth individuals, families, small businesses, foundations, trusts, charitable organizations, and estates. We also advise on retirement accounts, including – but not limited to – IRAs, SEPs, SIMPLEs, Solo 401(k)s, retirement trusts, defined benefit plans, small business 401(k) plans, and corporate 401(k) plans. TCM does not impose minimum requirements for opening or maintaining accounts, or for engaging our services. However, certain TPAMs may require a minimum account size, and these requirements can vary from one TPAM to another. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION Page 12 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure Investment Selection and Portfolio Management TCM determines investments and allocations based on each client’s predefined investment objectives, risk tolerance, time horizon, financial situation, liquidity needs, and other relevant suitability factors. Client-imposed restrictions and guidelines may affect portfolio composition, and TCM’s investment strategies and advice may vary depending on a client’s specific circumstances. TCM selects investments for client portfolios using a combination of fundamental, cyclical, and technical analysis, along with charting techniques. We gather information from a wide range of resources, including financial publications, independent research, corporate rating services, company press releases, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Asset allocation decisions are guided by the chosen investment strategy, prevailing economic conditions, and TCM’s assessment of the market’s position within the economic cycle. Risks and opportunities are evaluated to determine the portfolio’s level of investment. Market fluctuations may cause a portfolio to deviate from its target allocation. To maintain alignment with established guidelines, accounts are monitored continuously and rebalanced as needed – either back to the original allocation or to a revised allocation based on current market conditions and the selected investment strategy. Changes in allocation may also be triggered by broader market conditions or specific microeconomic factors affecting individual holdings. Analytical Methods Fundamental analysis evaluates a company’s intrinsic value by reviewing economic conditions, industry trends, financial statements, management quality, earnings, expenses, assets, and liabilities. The assessed value is compared to the current market price to guide buy, sell, or hold decisions. Cyclical Analysis examines the stages of an industry cycle to inform investment decisions. Technical analysis studies market-generated data such as historical prices and trading volumes, using charts and statistical tools to identify patterns that may indicate future price movements. Charting focuses on identifying recurring patterns that may indicate future price movements – such as line charts, bar charts, candlesticks, and point-and-figure charts – to spot trends and potential reversals that may signal buying or selling opportunities. Investment Strategies TCM’s strategies may involve long-term and short-term holdings, active trading (including securities sold within 30 days), and the use of options, margin, leverage, and short sales. Clients may place reasonable restrictions on the strategies used or the types of investments held in their portfolio. Whenever possible, TCM seeks to: • Strategically diversify with non-correlating assets. • Maintain a balance between growth and value styles. • Diversify across markets and sectors. • Rebalance in response to market changes. Page 13 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure • Manage portfolios for tax efficiency. Third Party Asset Manager Selection and Evaluation TCM evaluates TPAMs based on their experience, expertise, investment philosophy, and historical performance to assess whether they have demonstrated the ability to invest successfully across varying time periods and economic conditions. As part of our ongoing risk assessment, TCM monitors TPAMs underlying holdings, strategies, portfolio concentrations, and use of leverage. Investing with a TPAM who has achieved past success carries the risk that such results may not be repeated in the future. Because TCM does not control the specific investments within a TPAM’s portfolio, there is also the risk that the TPAM may deviate from the statement investment mandate or strategy, potentially making the portfolio less suitable for our clients. Furthermore, as TCM does not oversee TPAM’s daily business or compliance operations, we may not be aware of deficiencies in internal controls that could lead to business, regulatory, or reputational issues. Risk of Loss You are advised – and should understand – that TCM’s past performance does not guarantee future results. Market and economic risks may adversely affect your account’s performance and could result in a loss of capital. Investing in securities involves the risk of loss, which you should be prepared to bear. There are principal and material risks that may negatively impact your account’s value and total return. Additional risks, not described here, could also prevent your portfolio from achieving its investment objectives. It is important to review all disclosure information carefully and understand that you may lose money by investing in any of our strategies. Your account may be subject to the following risks: Alternative Investments: Alternative investments are generally illiquid and do not trade on a national securities exchange. They typically include direct participation program securities (such as partnerships, limited liability companies, business development companies, or real estate investment trusts), commodity pools, private equity, private debt, and hedge funds. These investments carry various risks, including illiquidity and potential devaluation due to adverse economic or real estate market conditions. They are not suitable for all investors. Alternative investments are generally considered speculative and may involve a high degree of risk – particularly when concentrated in one or a few such investments. These risks can be greater and substantially different from those associated with traditional equity or fixed-income investments. Additional details on these risks are provided in the product’s prospectus. You should read the prospectus carefully before investing. Capitalization Risk: Small and mid-capitalization companies may face challenges due to limited resources or less diversified products and services. Their stocks have historically been more volatile than those of larger, more established companies. Cash and Cash Equivalents: A portion of your assets may be held in cash or cash equivalents to help meet your objectives, provide ongoing distributions, or take a defensive position. Holding cash may reduce Page 14 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure market exposure and limit potential returns. Concentration Risk: A large position in a single security, sector, or industry can amplify losses and increase portfolio volatility. Concentrated portfolios are more vulnerable to sudden losses that can significantly impact performance. Credit Risk: Credit risk is the possibility that the issuer of a security will be unable to make interest or principal payments when due. Downgrades in an issuer’s credit rating, or perceived changes in its financial strength, can negatively affect security values and portfolio performance. Cryptocurrencies – Digital Assets: Cryptocurrencies are a relatively new and highly volatile asset class. Prices can swing rapidly, and the market is subject to uncertainty, fraud, theft, manipulation, security breaches, and operational failures. Most cryptocurrency trading venues are largely unregulated, increasing exposure to fraud and market manipulation. These investments are suitable only for clients wishing to have an allocation to an investment with a speculative objective who can bear the economic risk of the investment, who have no need for liquidity, understand the risks and are willing to accept those risks of loss of their entire investment in exchange for potential returns. Given the complexity of the products and technology that cryptocurrencies pose, investment decisions made with respect to the allocation of any portfolio to cryptocurrencies are subject to various potential risks including technical, legal, market, and operational risks, price volatility, illiquidity, valuation methodology, related-party transactions, and conflicts of interest, and that those investments decisions will not always be profitable. Derivatives: Derivatives, such as futures contracts, derive their value from other securities or indices. They can be used for hedging or speculative purposes. While hedging can help manage risk, it may increase expenses and does not guarantee success. Equity Securities: Equity prices tend to be more volatile than fixed-income securities. Prices fluctuate based on company-specific events, industry conditions, and broader market factors. Small and mid-cap stocks often have higher volatility, lower trading volume, and less liquidity than large- cap stocks. Exchange-Traded Funds (“ETFs”): ETFs face risks such as lack of an active trading market, potential losses from secondary market trading, or disruptions in the creation/redemption process. These factors may cause ETF shares to trade at a premium or discount to their net asset value. Fixed Income Securities: The value of bonds fluctuates with market conditions, interest rates, and credit quality. Rising interest rates generally lower bond prices, especially for those with longer maturities. Credit risk refers to the possibility that the issuer will fail to make timely interest or principal payments. High-yield (“junk”) bonds carry higher risks of principal and income loss than investment-grade bonds. Foreign Securities and Currency Risk: International and emerging-market investments carry risks such as currency fluctuations, foreign taxes and regulations, illiquid markets, political instability, and the potential for total loss of the investment’s value. Interest Rate Risk: In a rising rate environment, the value of fixed-income securities typically declines, and equity values may also be negatively impacted. Page 15 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure Market Risk: No investment approach can eliminate market risk. Economic, political, and company- specific events can cause security values to rise or fall. Your investment may lose value, and you may receive less than your original investment upon liquidation. Mutual Funds: Mutual funds may hold a variety of asset types, each with its own risks. Money market funds, while aiming to preserve principal, can lose value. Aggressive growth funds may be more volatile and are best suited for investors willing to accept price swings. Income from tax-free funds may still be subject to certain taxes. Mutual fund performance will vary based on the performance of the underlying assets, changes in interest rates, and market conditions. Risks may be magnified depending on how a fund invests or uses certain strategies. Additional information is available in the fund’s prospectus, which can be obtained from your IAR or the fund company. Options: Options trading can involve greater price volatility than the underlying securities. Buying and writing options are complex strategies that carry above-average investment risks. Securities Lending: Securities lending involves the risk that the borrower may fail to return the securities, or that the collateral provided may decline in value. These situations may also lead to adverse tax consequences for the fund. Special Purpose Acquisition Company (SPACs): SPACs, which raise capital through IPOs to acquire private companies, carry unique risks. They typically have no operating history, making it difficult to assess management performance. The timeline to complete a merger can be uncertain, leading to periods of illiquidity. Success depends heavily on management’s ability to identify and execute a profitable acquisition. Risks include potential dilution, regulatory changes, and market volatility. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Client Information Provided to Portfolio Managers and Client Contact Non-public information is information about you not accessible to the public. Your social security number, net worth, and annual income are examples of non-public information. Public information is information about you readily accessible to the public. Public information may include your name, phone number, and address. For all accounts, including those in the programs described in this brochure, your IAR will have access to the non-public information provided by you in the account opening process. This information is protected in accordance with TCM’s Privacy Policy. TCM’s Privacy Policy is available on TCM’s website and is provided upon opening your account and annually thereafter. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS TCM does not place restrictions on the client’s ability to contact and consult their IAR. If a client has chosen a third-party asset manager, your IAR can schedule a meeting with the portfolio manager, if requested. TPAMs are not required to be available for unscheduled or unannounced visits or calls by clients. However, TPAMs are expected to periodically meet with clients and should generally be available to take client telephone calls on advisory-related matters. Page 16 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure ITEM 9: ADDITIONAL INFORMATION We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are, overall, advantageous when compared to other available providers and their services. When evaluating custodians/brokers, we consider a broad range of factors, including but not limited to: • Ability to maintain the confidentiality of trading intentions • Timeliness of execution and trade confirmations • Liquidity of securities traded • Willingness to commit capital • Ability to place trades in challenging market conditions • Availability of research and investment ideas • Execution facilitation services • Recordkeeping and custody services • Frequency and correction of trading errors • Access to multiple market venues • Expertise with specific securities • Financial condition and business reputation Charles Schwab and Fidelity Investments Based on these considerations, our firm primarily recommends Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Investments (“Fidelity”)—both registered broker-dealers and members of the SIPC—as custodians for client accounts. These firms are independent and unaffiliated SEC-registered broker- dealers. Schwab and Fidelity will hold your assets in a brokerage account and execute securities transactions as instructed by you and/or us. While we recommend these custodians/brokers, the decision is yours, and you will open your account directly with the custodian/broker by entering into an account agreement with them. We do not open the account on your behalf, though we may assist you in the process. Schwab and Fidelity may make certain research and brokerage services available at no additional cost to our firm. These services may be directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by Schwab and Fidelity may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab and Fidelity to our firm in the performance of our investment decision-making responsibilities. As a result of receiving these services, we may have an incentive to continue using, or to expand our use of, Fidelity and Schwab. Our firm considered this potential conflict of interest when deciding to establish relationships with these custodians. We have determined that these relationships are in the best interest of our clients and are consistent with our fiduciary duty, including our obligation to seek best execution. Schwab and Fidelity charge brokerage commissions and transaction fees for certain securities transactions Page 17 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure (e.g., transaction fees for some no-load mutual funds and commissions for individual equity and debt securities). They also provide access to many no-load mutual funds without transaction charges, as well as other no-load funds at nominal transaction charges. Their commission rates are generally discounted from standard retail rates. However, the commissions and transaction fees charged by these custodians may be higher or lower than those charged by other custodians or broker-dealers. Additionally, our clients may pay a commission to Schwab and Fidelity that is higher than what another qualified broker-dealer might charge for the same transaction if we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. When seeking best execution, the determining factor is not the lowest possible cost, but rather whether the transaction provides the best overall qualitative execution. This includes consideration of the full range of a broker-dealer’s services, such as the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, while we strive to obtain competitive rates for the benefit of all clients, we may not always secure the lowest possible commission rates for specific transactions. Schwab and Fidelity do not charge transaction fees for U.S.-listed equities and exchange-traded funds. We do not receive soft dollar benefits in excess of what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The research products and services obtained by our firm will generally be used to service all of our clients, but not necessarily all at any one particular time. We do not acquire client brokerage commissions (or markups or markdowns). We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits. We do not receive brokerage for client referrals. We provide investment management services to a variety of clients. At times, portfolio transactions may be executed under concurrent authorizations to buy or sell the same security for multiple accounts with similar investment objectives. While such concurrent transactions could potentially be advantageous or disadvantageous to one or more accounts, we execute them only when we believe doing so is in the best interest of the accounts involved. When concurrent transactions occur, our goal is to allocate executions in a manner we deem equitable to all participating accounts. In each situation, we strive to allocate trades as fairly as possible, considering client objectives, current asset allocation, and the availability of funds. We use methods such as price averaging, proration, and other consistently applied, non-arbitrary allocation practices. Trade Errors TCM has implemented procedures to help prevent trade errors; however, errors in client accounts cannot always be avoided. In keeping with our fiduciary duty, it is TCM’s policy to correct trade errors in a manner that serves the best interest of our clients. If a client causes the trading error, the client will be responsible for any resulting loss. Depending on the circumstances, the client may also be unable to retain any gains that result from the correction. Page 18 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure If the client did not cause the trading error, the client will be made whole. When TCM is responsible, we will absorb any resulting loss. If the custodian or broker is responsible, they will be required to cover all costs related to the error. Custody Custody, as it applies to investment advisors, is defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to the physical possession of client assets. If an investment advisor has the ability to access or control client funds or securities, they are considered to have custody and must implement appropriate procedures to safeguard those assets. Advisory Fees TCM is responsible for calculating and deducting advisory fees from client accounts held with the qualified custodian. Written client authorization is always obtained before any fees are deducted, and all fees are reflected on the account statements provided directly by the custodian. The custodians we work with issue independent statements at least quarterly, detailing account balances, transaction history, and any fees debited from your account. Third Party Money Movement The SEC issued a no-action letter with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940. The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodians: • The client submits a written instruction to the qualified custodian that includes the client’s signature, the third party’s name, and either the third party’s address or the account number at the custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing—either on the custodian’s form or separately—to direct transfers to the third party, either on a specified schedule or as needed. • The qualified custodian verifies the instruction (e.g., through a signature review or other appropriate method) and promptly provides the client with a transfer-of-funds notice after each transfer. • The client retains the ability to terminate or amend the instruction at any time by notifying the qualified custodian. • The investment adviser has no authority to designate or change the identity, address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records confirming that the third party is not a related party of the adviser and is not located at the adviser’s address. • The qualified custodian sends the client a written initial confirmation of the instruction and an annual notice reconfirming it. We encourage clients to contact us with any questions regarding custody, safety, or security of their assets. Page 19 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure Performance Based Fees and Side-By-Side Management TCM does not charge performance-based fees for its advisory services. All advisory fees are charged exclusively as described in above. Proxy Voting Authority We do not, and will not, accept proxy authority to vote client securities. Clients will receive proxies and other solicitations directly from their custodian or transfer agent. If any proxies are sent to our firm in error, we will forward them to the client and request that the sender mail them directly to the client in the future. Clients are welcome to call, write, or email us with any questions regarding specific proxy votes or other solicitations. Class Action Claims TCM has engaged a third-party service provider, Chicago Clearing Corporation (“CCC”), to monitor and file securities class action litigation claims with claims administrators on behalf of TCM clients. To facilitate this service, it may be necessary to share client information—such as name, account number, and address—with CCC. TCM does not receive any fees or remuneration in connection with this service, nor does it receive any compensation from CCC or any other third-party provider. CCC charges a fee equal to seventeen and a half percent (17.5%) of all claims it collects on behalf of TCM clients. This fee is deducted and retained by CCC from the proceeds paid by the claims administrator. All claims are subject to this fee except SEC Fair Fund cases, in which CCC does not collect a fee. Clients may opt out of this service at any time. If a client chooses to opt out, TCM will not advise on or take any action regarding class action litigation related to investments held in, or previously held in, the client’s account. Clients should be aware that recoveries from class action settlements may be lower if not using CCC’s services. Additionally, fees for comparable services may vary, and lower-cost alternatives may be available from other providers. Disciplinary Information TCM has no legal, financial, or other disciplinary events to report. Additional information is available at www.FINRA.org or www.SEC.gov. • Triumph Capital Management CRD Number: 282814 • Triumph Capital Management SEC Number: 801-107312 Insurance TCM’s IARs may be appointed as agents with various life, disability, or other insurance companies and may receive commissions, trails, or other compensation from product sponsors for insurance transactions conducted on behalf of clients. Insurance business is processed through Triumph Capital, LLC or other approved third-party agencies. Clients are under no obligation to purchase insurance products through TCM or its IARs. In most cases, IARs spend less than 10% of their time on insurance-related business. You may review your IAR’s ADV Form 2B for details on their specific insurance activities. Page 20 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure Derek Eichenwald owns Triumph Capital, LLC, an insurance agency that offers various insurance products and earns customary fees from insurance sales. This creates a potential conflict of interest, as these sales may provide an incentive to recommend products based on compensation earned by the advisor or other supervised persons. To address this conflict, our firm is committed to acting in the client’s best interest in accordance with our fiduciary duty. Triumph Capital Foundation Triumph Capital Foundation (the “Foundation”) is a nonprofit private foundation established in 2022 and managed by individuals who are also employed by TCM. The Foundation’s primary purpose is to facilitate charitable giving. Because the Foundation maintains an advisory relationship with TCM and compensates TCM for its services, a material conflict of interest exists when recommending the Foundation for charitable contributions. TCM has a financial incentive to recommend the Foundation over other nonprofit organizations. Individuals affiliated with the Foundation have disclosed this relationship in their ADV Form 2B. Outside Business Activity IARs of TCM may engage in Outside Business Activities (“OBAs”), which are fully described and disclosed in each IAR’s ADV Form 2B. OBAs can create a material conflict of interest if an IAR has an incentive to devote more time to their outside activities than to their advisory relationship with you. TCM monitors and approves all OBAs to help mitigate this potential conflict. More information about your IAR’s outside business activities can be found by visiting FINRA BrokerCheck at www.finra.org. If you would like a copy of your IAR’s most recent ADV Form 2B, please contact TCM’s Chief Compliance Officer, Brandon Drespling. Other Conflicts of Interest As a fiduciary, TCM and its IARs have an affirmative duty of care, loyalty, honesty, and good faith to act in the best interests of clients. This duty is fulfilled by striving to avoid conflicts of interest and by fully disclosing all material facts when a conflict does arise. A conflict of interest occurs when an IAR’s personal interests are inconsistent with the interests of TCM’s clients or with IAR’s service to the firm. IARs are also expected to avoid situations that could even appear to present a conflict or impropriety. Conflicts of interest may arise if TCM or its IARs have reason to favor one client over another—such as prioritizing larger accounts over smaller accounts, accounts in which employees hold material personal investments, or accounts belonging to close friends or relatives. TCM strictly prohibits favoritism that would constitute a breach of fiduciary duty. IARs are prohibited from using knowledge of pending or potential securities transactions for clients to profit personally—whether directly or indirectly—including by buying or selling such securities for their own accounts. Mr. Brandon Drespling and Mr. Derek Eichenwald are both principals of TCM. While both are supervised by the Compliance Department, the Compliance Department ultimately reports to them. This structure may be considered a conflict of interest. If you have questions regarding the supervision of Mr. Page 21 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure Drespling or Mr. Eichenwald, please contact the Compliance Department before engaging in advisory services with TCM. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading TCM and its associated persons may invest for their own accounts or hold financial interests in the same securities or other investments that TCM recommends or acquires for your account. They may also engage in transactions that are the same as—or different from—those recommended to or executed for your account. This presents a potential conflict of interest. TCM recognizes its fiduciary duty to place your interests first and has implemented policies to avoid or mitigate such conflicts. TCM has adopted a Code of Ethics that establishes the standards of conduct expected of our advisory personnel. The Code addresses, among other topics, personal trading, gifts, prohibitions on the use of inside information, recommendations involving account rollovers, and other situations where conflicts of interest may arise. The Code of Ethics is designed to: • Protect TCM’s clients by deterring misconduct. • Education personnel on our expectations and applicable laws. • Remind personnel of their position of trust and the need to act with complete propriety. • Safeguard TCM’s reputation. • Guard against violations of securities laws. • Establish procedures for monitoring compliance with TCM’s ethical principles. To ensure our fiduciary responsibilities are upheld, TCM has established the following restrictions: • Directors, officers, or employees may not buy or sell securities for their personal portfolios if the decision is based, in whole or in part, on information obtained through their employment—unless that information is also available to the public through reasonable inquiry. No one at TCM may place their own interests ahead of a client’s. • TCM maintains a list of all securities holdings of individuals with access to advisory recommendations. These holdings are reviewed regularly by an appropriate officer of TCM. • Clients have the unrestricted right to decline any advice provided, except in situations where TCM has discretionary authority over the account. • Clients have the unrestricted right to select any broker-dealer, except when TCM has discretionary authority. • TCM prohibits the use of leveraged and inverse intraday ETFs and ETNs in client accounts. • TCM prohibits cross trades in client accounts. • All personnel must comply with all applicable federal and state regulations governing registered investment advisory practices. You may request a complete copy of our Code of Ethics by contacting TCM. Account Reviews – Investment Supervisory Services The underlying securities within the investment supervisory services are regularly monitored. Reviews are conducted by your IAR and further overseen by the supervising principal. An annual Page 22 of 23  ADV Part 2A Appendix 1 – Wrap Fee Brochure review is typically conducted either in person or by telephone. The purpose of these reviews is to ensure that the investment plan continues to align with the client’s goals, objectives, and overall risk tolerance. More frequent reviews may be initiated if there are material changes in factors such as your personal circumstances, or shifts in the market, political, or economic environment. Clients are strongly encouraged to notify TCM of any changes in their personal circumstances. Statements and Reports Clients are urged to compare the reports provided by TCM with the account statements received directly from their account custodian. Upon request, TCM can provide performance and position summary reports, which may also be delivered at client meetings. In addition, the custodian/broker for each client account will provide official account statements at least quarterly. Custodians TCM receives economic benefits from custodians in the form of support products and services that are made available to us and to other independent investment advisors whose clients maintain accounts on these custodial platforms. We benefit from these products and services because, if not provided, the cost would otherwise be borne directly by TCM. This creates a conflict of interest. Additionally, the amount of compensation TCM receives may vary depending on the custodian or broker recommended for client accounts. As a result, TCM has a conflict of interest in making such recommendations. Clients should carefully consider these conflicts when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are further described above. Financial Information We are not required to provide financial information in this Brochure because we do not require the prepayment of more than $1,200 in fees six months or more in advance, we do not have any financial condition or commitment that would impair our ability to meet contractual and fiduciary obligations to clients, and we have never been the subject of a bankruptcy proceeding. Page 23 of 23