VIEWPOINT CAPITAL MANAGEMENT

Item 1 - Cover Page March 17, 2026 Viewpoint Capital Management LLC Madrona Plaza 1421 34th Avenue, Suite 214 Seattle, WA 98112 (c) 206.902.6706 (p) 206.219.1410 (f) 206.219.1455 ryan@viewpontcapitalllc.com www.viewpointcapitalllc.com CRD Number: 158899 This brochure provides information about the qualifications and business practices of Viewpoint Capital Management LLC. If you have any questions about the content of this brochure, please contact us at 206.219.1410 or via email to ryan@viepointcapitalllc.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 Viewpoint Capital Management is available on the SEC’s website at https://adviserinfo.sec.gov/. Viewpoint Capital Management is a registered investment adviser with the SEC. Registration as an investment adviser does not require any level of skill or training. 1 March 17, 2026  Item 2 - Material Changes For your information, there are NO material amendments in this Annual Update Amendment filed when compared to the version dated February 19,2025. This is the current version of Form ADV Part 2 AB, dated March 17, 2026. Starting on Page 5 of this brochure, PTE 2020-02 and the DOL were in court to address this PTE. The law still exists but the exemption was never rescinded. - 2/13/2023, the US District court vacated the DOL’s 2021 FAQ guidance that interpreted the PTE, not the rule itself. - On July 7 – 9, 2025, US District court vacated limited portions of the text and preamble of PTE 2020-02 and rejected Title II (IRA advice) and rejected future relationship and single rollover to on going advice theories, but again, not PTE 2020-02 itself. As a result, PTE 2020-02 “stands for now.” The total of assets under management (AUM) was updated through the end of last year; December 31, 2025. A change (increase or decrease) in assets under management is NOT a material change to this document (ADV Part 2AB). 2 March 17, 2026  Item 3 - Table of Contents Contents Item 1 - Cover Page ..................................................................................................................................... 1 Item 2 - Material Changes .......................................................................................................................... 2 Item 3 - Table of Contents .......................................................................................................................... 3 Item 4 - Advisory Business ......................................................................................................................... 4 Item 5 - Fees and Compensation ................................................................................................................ 6 Item 6 – Performance Based Fees and Side-by-Side Management ........................................................ 9 Item 7 – Types of Clients ........................................................................................................................... 9 Item 8 - Method of Analysis, Investment Strategies, and Risks of Loss ................................................ 9 Item 9 – Disciplinary Information ......................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations .......................................................... 10 Item 11 – Code of Ethics, Participation, or Interest in Client Transactions ..................................... 11 Item 12 - Brokerage Practices .................................................................................................................... 12 Item 13 – Review of Accounts ................................................................................................................ 13 Item 14 – Client Referrals and Other Compensation ......................................................................... 14 Item 15 – Custody .................................................................................................................................... 16 Item 16 – Investment Discretion .............................................................................................................. 16 Item 17 – Voting Client Securities ......................................................................................................... 16 Item 18 – Financial Information ............................................................................................................ 16 Form ADV Part 2 B, Brochure Supplement Item 1 – Cover Page ....................................................... 17 Privacy Disclosure ..................................................................................................................................... 18 3 March 17, 2026  Item 4 - Advisory Business Viewpoint Capital Management LLC (referred to in this brochure as “Firm,” “Advisor,” “We,” “Us,” “Our”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). Viewpoint was founded in 2011. Ryan P. Sawyer is our managing member, sole owner and is also the Chief Compliance Officer. Advisory Services Viewpoint provides comprehensive investment advisory (portfolio management) services. These include the following: Identification of each client’s objectives and risk tolerances through the client’s profile   Asset allocation / recommendations  Security selection, purchase, sale or hold decisions and,  Overall portfolio management with investment discretionary authority,  Directed brokerage to Schwab, each client’s independent (from Viewpoint) third party, qualified custodian, and broker. We develop individual investment portfolios that integrate the long-term investment goals, risk tolerances and financial objectives of our clients as described in written and verbal communications. When you establish an advisory relationship with us, we document who you are and what your current investment goals and objectives are in the Client Profile. This Profile then guides our investment decisions and recommendations. We then manage your account assets with your unique circumstances in mind. We tailor our advice to you and your assets by:  Making investment decisions (for discretionary accounts) in accordance with each Client’s profile. This means that we will determine which securities, the number of securities and timing of transactions to make for your account based on our professional determination (as guided by your profile) Portfolios contain investments from multiple asset classes based on objectives and the risk tolerance of each client. In client portfolios we employ primarily individual stocks and bonds and passively managed ETFs, mutual funds and cash. We can access other types of liquid securities, if required, consistent with your goals and objectives. Clients may place reasonable restrictions upon the type of securities or specific securities that are bought, sold, or held in your account, within your Profile. These restrictions requested by each client are made by the client, in the Client Profile and can be changed by updating your Profile. They are not accepted until reviewed and accepted by Viewpoint. Any restrictions that limit the ability of Viewpoint to manage the assets that have an adverse impact on portfolio diversification or return objectives are discussed and the impact of those restrictions. The result is they may be accepted or rejected. 4 March 17, 2026  Assets Under Management As of December 31, 2024, we had the following assets under management. These numbers include fee paying and non-fee-paying assets managed by Viewpoint, including the assets of employees and families, both discretionary and non-discretionary: Investment Discretionary Authority Non- Discretionary Authority $ 222,968,000 $ 44,831,000 Fiduciary Advice Exemption: PTE 2020-02. As shown above, under material changes, this PTE has been in court due to suits against the DOL (Department of Labor). As a result, the PTE has been changed as indicated above by these suits. The suits caused PTE 2020-02 to be changed by striking down aggressive DOL interpretations and vacated specific pre-able statements of PTE 2020-02. This means PTE 2020-02 is still an exemption which allows financial institutions to receive otherwise prohibited compensation if they are (like Viewpoint) fiduciaries under the existing 1975 five-part test. As a fiduciary, the following conditions are enforceable when fiduciary status exists: - Best interest standard (prudence and loyalty) - Reasonalbe compensation for services provided. - No misleading statements are provided. For fiduciaries like Viewpoint, written policies and procedures are required for: - Conflict mitigation policies - Documentation of rollover and transfers - Supervisory oversight; and - Retrospective review. Viewpoint has a PTE 2020-02 worksheet that must be completed and retained internally within 10 days of making a recommendation to a retirement investor. We disclose here, that “Viewpoint does not generally recommend to any client that they roll over a 401k to an IRA.” I. Investment advice has been defined through The Impartial Conduct Standard which has three parts: Provide investment advice that is in the best interest of the retirement investor, prudence (proper and suitable). Viewpoint meets our fiduciary obligations to all our clients, including retirement investors. II. We charge only reasonable compensation (as disclosed in the next section, below). Security transactions for the retirement investor account (IRA, etc.) managed by Viewpoint are directed brokerage transactions, only (see Item 12, below). III. We make no misleading statements to the retirement investor regarding the recommendation and relevant matters. 5 March 17, 2026  Senior Safe Act Legislation and Compliance As required by law, via the Senior Safe Act, which provides immunity to Viewpoint when we see or suspect a senior client of being exploited. To comply, we have in our policies and procedures information related to this topic and what we will do and must do. For reader’s information:  Viewpoint defines a senior investor at 65 years of age.  We function as a fiduciary for all clients.  Diminished capacity is the most often complaint our research has told us. This is now called major neurocognitive disorder.  Financial Exploitation: Ryan looks for physical or emotional abuse, neglect and blocked access to the senior client accounts and assets, through a power of attorney that was not previously present, among many others. We ask that you be aware of Senior Safe Act issues and our compliance. In addition, we are now running reports of our clients owned by those On and over, and the assets held in these accounts. If we discover potential exploitation1, we are obligated to report to the police, social services and, if necessary, lock down the client’s account at Schwab. Item 5 - Fees and Compensation Viewpoint charges annual fees based on a percentage of client assets under management. The table below is the standard fee schedule. Fees are billed quarterly on the inception value of the account (pro-rated for the number of days in the quarter the services are provided). For subsequent quarters, fees are charged on the portfolio value at the quarter end as determined by your custodian. Fees are charged after the services are provided. As a result, upon the termination of an agreement between Viewpoint and a client, the refund of fees is not applicable. Please see below. Assets under Management Annual Advisory Fee $0 - $1,000,000 1.00% $1,000,001 - $5,000,000 0.85% $5,000,001 + 0.70% Fees are documented in the advisory agreement we have with you. This fee schedule is negotiable based on several factors, including, and not limited to the following:  Number of accounts in the relationship  Prospect of additional accounts and / or assets to manage.  Other relationships (family members)  Among others 1 The North American Securities Administrators (US and Canada), showed in February of 2020 that in New York state alone, exploitation of seniors ranged from $352 million to $1.5 billion! 6 March 17, 2026  Fee Payment: Fees are paid to Viewpoint directly from your accounts held at your independent third- party qualified custodian. You authorize Viewpoint in the advisory agreement to have fees “directly debited” from your custodial account(s) held at your third party and qualified, independent custodian (Charles Schwab & Co., Inc. “Schwab” See Item 12, below). Your written authorization allows us to:  Calculate the fee based on the assets under management,  Request the fee due and payable from your custodian initially and each quarter thereafter; and,  Receive the fee due and payable from your custodian when the debit requests are received from Viewpoint. Viewpoint will, when issuing a debit request to your custodian (Schwab), send the following information to you in a worksheet that reflects: 1. The formula is used to calculate the fee. 2. The fee calculation itself. 3. The amount of assets under management on which the fee is based. 4. The period the fee covers; and, 5. The amount of the fee is due for the period. Direct debiting is NOT custody of your funds or securities as those are held at Schwab, your independent and third-party qualified custodian. Note: Please verify the accuracy of our fee calculations as your custodian does not perform this task. SLOAs: Viewpoint does not permit or use SLOAs – standing letters of authorizations, as currently these are considered custody by the SEC. For your protection and the protection of your assets, please contact Schwab to have funds or securities moved from your account(s) to those other accounts you so designate, in writing, to Schwab. Additional Fees and Costs: Advisory fees paid to Viewpoint are separate and distinct from the fees and expenses you will pay your broker / custodian, Schwab. The fees you will pay your broker / custodian include but are not limited to: IRA fees  Commissions and transaction costs  12b-1 fees on mutual funds held in your custodial / brokerage accounts at Schwab.  Sub-agent transfer fees  SEC or Exchange fees  Wire or mail / postage costs  Dealer mark-up or mark-downs on principal transactions if any  Margin interest if used.  Commissions on new issues (if applicable)   Safekeeping fees  Redemption fees, exchange, or similar fees for mutual fund trades  Advisory fees and operational costs to mutual funds or ETFs by the underwriters of these securities, among others 7 March 17, 2026  Fees and expenses of mutual funds or ETFs are provided via a prospectus from Schwab, your custodian directly. Please note that Viewpoint does not participate in or receive directly or indirectly any of these additional fees or expenses charged to clients by Schwab. Schwab solely retains them. Mutual fund redemption fees: Some mutual fund shares you may own before becoming a client of Viewpoint impose a redemption fee on descending time periods when the shares are sold. This fee is charged by the mutual fund when sold within a defined period from the purchase of the fund shares. Redemption fees vary from one to five years or more. Although a redemption fee is deducted from redemption proceeds just like a deferred sales load, it is not considered to be a sales load. Sales loads are commissions payable by the mutual fund to broker dealers and their stockbrokers for initially selling the mutual fund shares to investors. Redemption fees are designed to stop short term redemptions of long-term investments. Redemption fees are retained by the mutual fund itself. In most cases, the mutual fund shares use the "first-in, first-out" (FIFO) method to determine the holding period. Under this method, the date of the redemption will be compared with the earliest purchase date of shares held in the client account. While it is not the general practice of Viewpoint to sell client securities in a period that would generate a redemption fee, it should be expected that we will do so if: 1) The sale is in the client’s best financial interests, or 2) Fund shares must be redeemed to pay our advisory fees from the account. A complete explanation of these charges is contained in the related mutual fund prospectus and “Statement of Additional Information” for each investment company (or mutual fund). Schwab, as indicated, will send you a mutual fund prospectus, or you can obtain a prospectus from the investment company (through its website or by telephone or mail). Termination: A portfolio management agreement may be terminated by either party with written notice delivered to the other party. Upon termination, Viewpoint will have no additional authority to manage the account assets; all transactions placed prior to termination will settle. As fees are charged in arrears, fees due and payable to Viewpoint will be charged and deducted. If the account was terminated prior to notification to Viewpoint, we will issue you an invoice for the balance of the fee due and payable through the date of termination. Clients may terminate the agreement within five business days of the date of the agreement without penalty if Form ADV Part 2 AB was not provided 48 hours prior to your execution of our agreement for services. 8 March 17, 2026  Additional Information on Services and Fees Family and Friends: Similar services are provided to family members or friends of Viewpoint at no fee or at fees that are lower than a non-family or friend will receive. Valuation: Security and total portfolio values are calculated by your Schwab, the third-party broker / custodian and not by Viewpoint. Note that Schwab, your custodian, is the official record-keeper of your account assets, profit and loss calculations and other related tax information. Similar Services: Please be aware that similar services may be available at fees that are lower or higher than those charged by Viewpoint. Item 6 – Performance Based Fees and Side-by-Side Management Not applicable. Viewpoint does not charge so-called performance-based fees. Viewpoint does not manage private funds. See Item 5, above, for full information on fees charged. Item 7 – Types of Clients Viewpoint provides portfolio management services to individuals, high net worth individuals, personal trusts or estates and small business owners. We do not impose minimum requirements for opening or maintaining an account and we do not impose a minimum account size. Item 8 - Method of Analysis, Investment Strategies, and Risks of Loss Our investment philosophy focuses on a few important themes:  Value and tactical investing  Inclusion of income producing securities in portfolios, and  Diversification through global investing and non-correlation. Primarily, we concentrate on value investing, in which we try to buy shares below their intrinsic value. This contrasts with philosophies that focus on growth investing, in which shares in companies with high growth rates would be emphasized. On a tactical basis, we try to find out of favor asset classes, which we believe are wrongly ignored by the crowd. We believe that low prices and pessimism go together. Likewise, assets loved by investors might well be overpriced. Efforts at intelligent contrarianism extend to regular portfolio rebalancing, which reduces exposure to asset classes favored by others and increases exposure to those currently out of favor. Part of our focus on value investing has to do with a preference for income-producing investments. Noting that half of market returns during the 20th century were due to dividend reinvestment; we believe dividend payments and dividend reinvestment are crucial. This is particularly true during periods of market weakness. In this sense, our core philosophy has a defensive character, in that we do not rely solely on returns on finding securities that appreciate; rather, we seek to be paid a share of a company’s profits on a regular basis. 9 March 17, 2026  Finally, we also believe in diversification, not only by industry but also globally. While much of the world’s market capitalization exists outside of the United States, U.S. investors continue to overweight their portfolios in US assets. We want to make sure our allocations reflect the increasingly global distribution of market value, both for growth opportunity, diversification of region and currency, and achieving lower correlation of asset price movements. A focus on non-correlation recognizes that reducing volatility can improve risk-adjusted returns. Our overall investment philosophy is to identify for each client’s unique facts and circumstances we strive to reflect those unique characteristics in the form of objectives, risk, allocation, and security selection. Risk: Investments in securities involve risk of loss including the possibility of losing all your initial investment as well as any unrealized gains on investments managed by Viewpoint. Securities held in your portfolio(s) or in underlying investments such as mutual funds or ETFs may underperform in comparison to the general securities markets or other asset classes. Our strategies and security analysis methods also include their own risks. We may be incorrect in our assessments of value investing, tactical decisions, or investments in foreign issues. We access foreign issuer through the US exchanges, by using American Depository Receipts (ADRs). Foreign shares have various risks, including currency and country specific economic risks. The performance of your account is subject to the risk that Viewpoint’s investment strategy may not produce the intended results. Your account could lose money over short periods due to short- term market movements and over longer periods. The value of security may decline due to company specific issues, general market conditions, economic trends, or events that are not specifically related to the issue of security or to factors that affect an industry or industries. During a general downturn in the securities markets, multiple asset classes may be negatively affected. In addition, the use of margin or leverage increases your potential for investment gain, and investment loss. Margin also includes an additional expense as the securities in your account are used as collateral to your broker / custodian for the margin loan. Should markets decline while we are using the margin, you may have to sell securities or contribute more capital to your account to meet the margin balances required. Performance, positive or negative, is impacted by the cost of the margin loan you pay directly to your broker / custodian for the margin loan. Item 9 – Disciplinary Information Neither Viewpoint, the registered investment adviser or Mr. Ryan Sawyer, President, Investment Adviser Representative and CCO have been involved in any civil, criminal or investment related event. Item 10 – Other Financial Industry Activities and Affiliations We are not involved in any other financial industry or activity. We do not receive directly, or indirectly any compensation from any party related to the investment advice provided to clients. The only business of Viewpoint and Ryan Sawyer is as an investment adviser and portfolio manager. 10 March 17, 2026  Item 11 – Code of Ethics, Participation, or Interest in Client Transactions Code of Ethics Viewpoint has adopted and implemented a Code of Ethics that is designed to meet regulatory requirements and to support our fiduciary obligations to each of our clients. The Code of Ethics is required by the Investment Advisers Act of 1940 (Advisers Act) and applicable state law. This Code of Ethics (Code) applies to all employees of Viewpoint. The goal of the Code is to establish business practices that meet our fiduciary obligations and to ensure compliance with federal law requirements that apply to our firm. Please note that Viewpoint has one employee, Ryan P. Sawyer. The Code requires, initially (upon hire) and annual disclosure of:  All “reportable” security holdings (as defined in the Code) for the employee and family members living in the same household.  Brokerage accounts (as that term is defined in the Code), and.  All securities are held in certificate or book entry form.  All members of the employee’s household  All beneficial ownership accounts (as that term is defined in the Code)  Quarterly reporting on all reportable security transactions during the most recent quarter within 10 days of the month following the quarter end.  Quarterly reporting of gifts (when exceeding a small or minor level) given or received. The Code also prohibits the following activity:  Trading for any employee account, Client account or communicating any information when Viewpoint is in possession of Material, Non-Public information on any security. This prohibition (called Prohibition on Insider Trading) is in place until we can verify the information is available in the public domain (via newspapers, internet, etc.). This is also called “insider trading.”  The purchase of an IPO (initial public offering) of security by any employee or beneficial ownership account of an employee; and,  The purchase of a private placement by any employee or beneficial ownership account of an employee Due to the size and nature of our portfolio management services, Viewpoint does not require the pre-clearance of personal security transactions by employees. If you would like a copy of Viewpoint’s Code, please contact Ryan P. Sawyer via email or telephone at the phone number or email address on the cover page of this Brochure. 11 March 17, 2026  Item 12 – Brokerage Practices Viewpoint does not have discretionary brokerage authority. This means that we cannot and do not select a broker for your account transactions. We require each Client to evaluate the broker we recommend. We then require each Client to “direct Viewpoint” to use this broker for all your account transactions. In determining which broker to use and to recommend, we evaluated several brokerage solutions. We recommend and use exclusively, Charles Schwab and Co., Inc. Note that Schwab has purchased TD Ameritrade Inc. of Toronto, Canada. The purchase was completed on October 6, 2020. However, the integration of the two companies into Schwab was completed September of 2023. Schwab is an independent, third-party qualified custodian. Viewpoint and Schwab are not affiliated or related in any way. Schwab provides services to independent investment advisers like Viewpoint through Schwab Advisor Services (a service program). Schwab is registered as a:  Securities broker / dealer with the Financial Industry Regulatory Authority (FINRA) and the U.S. Securities and Exchange Commission  Member of the Securities Investors Protection Corporation (SIPC)  A registered investment adviser with the U.S. Securities and Exchange Commission; and,  Member of the National Futures Association (NFA) and is registered as a Commodity Trading Adviser As a result, in recommending Schwab, Viewpoint also asks that clients independently evaluate Schwab as your broker dealer and custodian. As indicated above, each client evaluates and selects Schwab as their custodian and broker and directs all security transactions for their account to Schwab. Viewpoint does not seek out other brokers or dealers for portfolio transactions, does not negotiate commissions on transactions and, as a result, the best execution for your account transactions may not be achieved. However, in evaluating Schwab, we believe that Schwab provide excellent security transaction services at reasonable commissions to all our clients and transactions we place for each of our clients. We used the following criteria to evaluate broker / custodians, including Schwab:  Combination of execution services for transactions and no additional fee for custody  Capability to execute, clear and settle client transactions.  Capability to facilitate transfers and payments from or to your accounts (wire transfers, check requests, etc.)  Breadth of securities available for purchase or sale  Competitiveness of services available and ability to negotiate them, including margin interest, etc.  Reputation, financial strength, and stability of the broker / custodian  Among others In addition, Schwab provides benefits to Viewpoint and to each of our clients that are beneficial. These services include: 12 March 17, 2026   No custodial costs to clients of Viewpoint  Access to institutional class shares of mutual funds at minimums that would otherwise not be accessible by Viewpoint or our clients. Information and data  Transactions at no fee for certain participating mutual funds  Access to an institutional trading desk (and operational support)   Among others Block Trading: Viewpoint may, but is not obligated to, aggregate the transactions of multiple clients, at the same time, in the same security. Typically, Viewpoint trades client-by-client; as a result, block trading is not used very often, if at all. Block trading allows Viewpoint to create larger blocks of purchase or sale transactions, which may allow us to negotiate prices with Schwab, thus fulfilling our obligation of best execution (which is not defined under Federal securities laws). Best execution is a concept that includes price, speed and efficiency of the transaction, commission costs and, the best possible transaction at the time (based on all relevant factors). Block trading will apply to stocks, bonds, and ETFs. As mutual funds (open ended) are traded at the previous day’s Net Asset Value (or NAV), there is no real benefit to blocking mutual fund trades together (except for the efficiency of processing one transaction on behalf of all participating client accounts). When block trading security transactions in equities, fixed income, or ETFs, if applicable, Viewpoint creates one transaction record which identifies the gross amount to purchase or sell. If the block transaction is completed fully, each participating account is credited with their pro-rated share of the block. If there are multiple transactions executed by Schwab to fully fill the order, all executions are averaged to price; all participating clients receive the average price. If the transaction cannot be fully completed, all clients will be allocated their pro-rated portion of the transaction; except smaller accounts (allocations of 100 shares or fewer) will be allocated in full, the balance of the securities will be allocated pro-rata. This saves clients from receiving anything other than full-round lots. Employee trades may be blocked with those of clients. In the case of partial fills, Employee account trades are “excluded” from the allocation until all client transactions are completed. We do not put the interests of Viewpoint or an Employee before those of our advisory clients. Item 13 – Review of Accounts Reviews: All Client accounts are managed and reviewed by Ryan P. Sawyer on at least a quarterly basis with more formal reviews semi-annually. However, we continually monitor securities held in all client accounts. The reviews compare security holdings, asset allocation, and investment restriction compliance with each client’s stated investment goals, objectives, and risk tolerances. We recommend at least an annual review of portfolio performance with each client. 13 March 17, 2026  If you notify Viewpoint to a change in your circumstances (marriage, divorce, medical issues, birth of a child, death in the family, or other noteworthy events), these are triggers for a review of your account and your investment goals and objectives. Additional triggers can include client- imposed restrictions such as limits on capital gains or losses (tax harvesting), among others. Reports: Viewpoint prepares written performance reports for clients as part of portfolio reviews with each client. There is no set schedule for the issuance of reports to clients. These reports, when prepared, provide a summary of investment performance for the recent quarter, year to date and inception to date. The reports also reflect holdings, transactions, and cash balances. Item 14 – Client Referrals and Other Compensation New SEC Marketing Rule, Rule 206(4)-1 made effective November 2022 combines two separate Rules into one2. This new Rule combines many past interpretations, no action letters and even enforcement cases over the last few decades. This new rule has modernized and complicated investment adviser advertising for many investment advisers. However, much of the new rule is not applicable to Viewpoint and its business. An advertisement is now defined as “any direct or indirect communication the investment adviser makes to more than one person.” In addition, emails, text messages, instant messages, electronic presentations, videos, films, podcasts, digital audio or video files, blogs, billboards, and all manners of social media are now considered, if published by the investment adviser as advertising under the new Rule. Viewpoint limits advertising to our website. We do not otherwise advertise3. We may, from time to time, include market comments in reports when meeting with clients which occur annually or as requested by each client. Note that Viewpoint does not:  Present actual or model investment performance. Viewpoint provides individual portfolio management services for each client based on the client’s investment objectives, goals, risk tolerance and other personal factors in private client reports to each client.  Use endorsements or testimonials about the firm or our services made by clients, ex- clients or other third parties, where we pay direct or indirect compensation for such services. We have not done so and will not do so. We obtain all our clients ourselves. 2 Old rule 206(4)-1, the Advertising Rule, and the 206(4)-3 the Cash Solicitation Rule. Both are now combined in the new Rule. 3 Advertisements now include technology delivery methods, including emails, text messages, instant messages, electronic presentations, videos, films, podcasts, digital audio or video files, blogs, billboards, and all manner of social media. 14 March 17, 2026  Viewpoint will follow existing general prohibitions on our website, our primary (and only) marketing activity. These carry over from the old rule and are part of this New Rule. Viewpoint will: 1. Not use material misstatements or material omissions or be materially misleading to a reasonable investor. 2. Not use facts that cannot be substantiated upon SEC request / demand. 3. Not discuss investment benefits or make references to investment advice that is not fair and balanced. 4. Not use performance advertising presentations in marketing that are not fair and balanced or comply with performance requirements of the New Rule. a. As indicated above, Viewpoint does not publish or provide performance advertising, gross and net performance numbers to gain new clients. b. Not show 1-, 5-, 10- year performance figures in an advertisement. c. Not use model performance which is now “hypothetical performance.” This means performance was not actually achieved by any portfolio (client) of our firm. d. Not using targets, projections, or hypothetical and back tested performance. 5. Not use information that is “otherwise materially misleading.” 6. No use testimonials or endorsements as indicated above. 7. We do not use third party rating services, as we have never done so and do not plan to do so. Other Compensation: Schwab, the broker / custodian recommended to Clients provides (see Item 12) certain benefits to both Viewpoint and our Clients. These benefits include the following:  Access to Client data.  Trade execution / aggregation  Pricing and other market data. Viewpoint does not value portfolio securities or total portfolio values for performance calculations. Based on our request, Schwab directly debits our advisory fees from your custodial (Schwab) accounts. These valuations are provided by Schwab, are calculated by our portfolio accounting system provided by Schwab used by Viewpoint to make debit requests, based on Schwab prices of all securities held in your account(s).  Direct debiting of our advisory fees as described in Item 5.  Help with back office / operational functions.  Educational and technology events and information  Technology, compliance, legal and business consulting  Access to employee benefit providers, human capital consultants and insurance providers,  Others Schwab may pay us for these benefits, or discount / waive fees or arrange for third party vendors to provide the services at no cost or fees lower than we would pay separately. If our assets are $10 million or more (of client assets held at Schwab), we do not pay for these services or benefits. 15 March 17, 2026  As a result, there is a conflict-of-interest present when we recommend Schwab and require clients to select Schwab (and direct us to place all transactions for your accounts at Schwab). The conflict is our interest in the continuation of our receipt of the benefits listed above. We mitigate this conflict by showing the information (and conflict) here. Item 15 – Custody Even though direct debiting advisory fees is a form of custody, no investment adviser has its fees directly debited are needed to indicate in Form ADV that they have custody. This can be confusing, as directly debiting is what is called “technical custody.” Therefore, we are bound to follow the direct debit process / procedure as described under Item 5. In addition, we suggest that you review both the statements we sent to you at the time of the debit request being sent to your custodian, to verify the accuracy of our fee calculation; Schwab as your custodian does not perform this task. We also encourage you to carefully review the periodic account statements you receive from Schwab. Item 16 – Investment Discretion In the written agreement we have with you, we are granted limited power of attorney to determine, without your specific consent, the securities to purchase, sell or hold for your account and the timing of the transactions. You may impose investment, tax, or other restrictions on our discretionary services; such restrictions are required in writing, in your client profile. These restrictions may be amended by updating your client profile but are not implemented until reviewed and accepted by Viewpoint. Non-Discretionary Clients are our legacy (older) clients / accounts. These clients must approve, on a transaction-by-transaction basis, all security transaction recommendations prior to our placement of those transactions at Schwab. Approval may be via telephone, via email or fax. If you are not available to Viewpoint to approve transactions during normal market hours or days, you may miss opportunities or be subject to losses (as we cannot trade for you without your explicit consent). Therefore, please be available during open market hours to approve recommended transactions. Item 17 – Voting Client Securities Viewpoint does not vote proxies for securities held in client accounts. Clients retain the right and responsibility to vote proxies for all securities held in your accounts. Clients receive proxies or other materials (including corporate actions) directly from Schwab, your custodian. Item 18 – Financial Information This item is not applicable to Viewpoint. We do not publish financial information on Viewpoint. 16 March 17, 2026  Form ADV Part 2 B, Brochure Supplement Item 1 – Cover Page Ryan P. Sawyer CRD: 158899 Educational and Business Experience Year of Birth: 1971 Education: BA, 1994, English & Philosophy, Seattle University, summa cum laude MSt, 1996, English Literature, Oxford University, with distinction, Rhodes Scholar Business Background: 2011 to Present President, IA Representative, Portfolio Manager, CCO Viewpoint Capital Management, LLC 2004 to 2011 Wealth Management Advisor, AVP Merrill Lynch 1996 to 2001 Director, Strategic Growth; Group Product Manager Amazon Disciplinary History: None (No arbitration claims; no liable charge (civil, self-regulatory organization or administrative proceeding) Other Business Activity: None Compensation: None Supervision: Ryan P. Sawyer is the principal and portfolio manager / investment adviser representative of Viewpoint. As a result, he is the primary and sole supervisor of the advice and services provided to Clients of Viewpoint. Should you have any questions, please contact Ryan at the phone number on the cover page of this Brochure Supplement or via email at ryan@viewpointcapitalllc.com. 17 March 17, 2026  Privacy Disclosure Viewpoint Capital Management LLC takes the safeguarding of our clients’ personal and non- public information we gather for each of our clients. The information we collect includes:  Social security numbers  Addresses  Tax bracket, income.  Personal and family obligations  Other information and data We gather this information from the following sources:  You, when filling out brokerage / custodial applications  You, when sharing information with Viewpoint so we can tailor our portfolio management services for you.  Transactions you have executed or placed with other professionals.  Your accountants or attorney as applicable  Others What we do not do: We do not share or release your personal, non-public information with any person unless: It is necessary to facilitate the processing of security transactions for your accounts.   A State or Federal Governmental Agency requests it.  You request us to do so (for example, to your other service professionals, i.e., accountant / CPA or attorney) Protection: We have implemented proper security and controls over our office space, our computer and computer systems, files, and related data capture points or recordkeeping. We keep physical, electronic, and related safeguards to protect your personal, non-public information. If you have questions about our Privacy Disclosure or our Privacy controls, please contact Ryan P. Sawyer at ryan@viewpointcapitalllc.com. 18 March 17, 2026