VISTAMARK INVESTMENTS

Item 1: Cover Page PART 2A OF FORM ADV: FIRM BROCHURE FIRM BROCHURE March 31, 2026 VISTAMARK INVESTMENTS LLC Investment Advisory Firm CRD# 335309 VISTAMARK INVESTMENTS LLC 333 West Chestnut Street Hinsdale, IL 60521 Phone: (312) 895-3001 x 100 Email: Info@vistamarkllc.com This brochure provides information about the business practices and qualifications of Vistamark Investments LLC. Any inquiries regarding the contents of this brochure should contact Mr. Matthew Rice by phone at (312) 895-3001 x 100 or by email at: Info@vistamarkllc.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 Vistamark Investments LLC is also available on the SEC’s website at www.adviserinfo.sec.gov Registration does not imply a certain level of skill or training. 1  Item 2: Material Changes • Vistamark Investments has increased its assets under management in excess of $100 million and has filed for registration with the Securities and Exchange. 2  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 .......................................................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management ......................................................................... 7 Item 7: Types of Clients ....................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................................................... 8 Item 9: Disciplinary Information ........................................................................................................................ 12 Item 10: Other Financial Industry Activities and/or Affiliations ............................................................................ 12 Item 11: Code of Ethics, Client Transactions and Personal Trading ..................................................................... 13 Item 12: Brokerage Practices ............................................................................................................................ 13 Item 13: Review of Accounts ............................................................................................................................. 17 Item 14: Client Referrals and Other Compensation ............................................................................................ 18 Item 15: Custody .............................................................................................................................................. 18 Item 16: Investment Discretion ......................................................................................................................... 19 Item 17: Voting Client Securities ....................................................................................................................... 19 Item 18: Financial Information .......................................................................................................................... 20 Item 19: Requirements for State-Registered Advisers ............................................... Error! Bookmark not defined. Part 2B of Form ADV: Brochure Supplements .................................................................................................... 20 3  Item 4: Advisory Business Vistamark Investments LLC specializes in discretionary investment management and advisory services for individuals, families, trusts, estates, businesses, pensions, and nonprofit organizations. The firm is a limited liability company registered with the Securities and Exchange Commission (SEC) and headquartered in Illinois, solely owned by Mr. Matthew Rice, CFA, CAIA, Sean McEvilly, CFA, and William Seyfarth, with Mr. Rice serving as Chief Compliance Officer. Vistamark Investments has been in business since February of 2025, with our initial filing with the State of Illinois. As of 3/31/2026, Vistamark Investments had $317,196,489.00 in assets under management (“AUM”) on a discretionary basis. Investment Advisory Services Vistamark Investments begins each engagement by thoroughly understanding the unique circumstances, goals, and financial position of the client—whether an individual, family, trust, estate, business, pension, nonprofit organization, financial institution, or other entity. This collaborative approach ensures that client-specific insights serve as the foundation for developing a customized, comprehensive investment strategy designed to meet the client’s objectives. Discretionary Investment Management Vistamark Investments predominantly provides discretionary investment management services to its clients, though not exclusively so. In certain cases, hybrid arrangements may apply, particularly where Vistamark is engaged to manage some accounts on a discretionary basis while offering recommendations only for other accounts. Account investment structure and supervision—whether discretionary or recommendation-based—is guided by each client’s investment objectives, investment experience, time horizon, liquidity needs, risk tolerance, tax circumstances, and other relevant factors. Vistamark’s investment recommendations and decisions are not limited to any specific security, asset class, or industry and may include guidance and advice regarding the following types of securities and investment vehicles: Exchange Traded Funds (ETFs) Mutual Funds Individual Securities (Equities, Fixed Income, and other publicly traded securities) Alternative Investments (including but not limited to Hedge Funds, Private Equity, Private Credit, Real • • • • Estate, and Infrastructure) Because these investments involve varying degrees of risk, they are only utilized or recommended when consistent with a client’s stated investment goals, tolerance for risk, need for liquidity, and tax considerations. Importantly, we evaluate the risk of any single investment within the broader context of each client’s overall portfolio, not solely on the basis of the risk characteristics of the individual security. As part of its investment management approach, Vistamark Investments builds custom portfolios that are individually structured to align with clients’ goals, risk tolerance, and time horizon. In creating and refining these portfolios, we also consider additional client-specific factors such as other existing holdings and investments, tax circumstances, liquidity requirements, job or business correlation and income dependency, sector or thematic exposures, personal interests, and other unique considerations. 4  Once a portfolio is established under a discretionary arrangement, we monitor its strategy and performance on an ongoing basis and will rebalance as appropriate. In cases where services are non-discretionary or hybrid, clients may receive recommendations they can implement directly. If a client’s financial circumstances or investment objectives change, they are expected to promptly inform Vistamark Investments to ensure that their overall investment strategy—whether managed or advised— continues to reflect their evolving needs. Sub-Adviser Services Vistamark Investments provides sub‑advisory services for certain client accounts and/or pooled investment vehicles. Under these arrangements, Vistamark Investments is responsible for providing discretionary portfolio management services for the assigned portion of the strategy in accordance with guidelines established by the Primary Adviser. The Firm does not have a direct advisory relationship with the underlying clients or investors in these accounts. All client communications, account administration, and fee billing are handled by [Primary Adviser Name]. Qualified Plan 3(21) or 3(38) Services Vistamark Investments may offer qualified plan fiduciary services under ERISA Section 3(21) or 3(38) to employee benefit plans and their fiduciaries. The scope of these services is based on the needs of the plan and the specific responsibilities requested by the plan sponsor, administrator, or named fiduciary. Depending on the negotiated arrangement, Vistamark may serve as either a co-fiduciary under Section 3(21) or as an investment manager with discretionary authority under Section 3(38). In general, these services may include, but are not limited to, analyzing and selecting the plan’s investment options, choosing qualified default investment alternatives (QDIAs), monitoring and benchmarking investments, creating or reviewing the plan’s investment policy statement, conducting recordkeeping vendor analysis (including fee evaluation and benchmarking), providing asset allocation or asset-liability optimization services, and documenting ongoing oversight procedures. Vistamark may also provide other services that aid the plan sponsor or its participants in optimizing outcomes, as appropriate to the needs of the plan. By tailoring its role to the unique requirements of each plan, Vistamark Investments seeks to help plan sponsors and fiduciaries meet their responsibilities while supporting participants with a thoughtfully structured, cost- conscious, and well-monitored investment lineup. Item 5: Fees and Compensation Investment Advisory Fees Annual advisory fees are due quarterly and payable in arrears. With client authorization, fees can be deducted from client accounts. Clients also have the option to pay the fees due within 30 days of the end of the previous quarter by other means. Fees are typically based on a percentage of the market value of assets under management, including cash and cash equivalents, as of the closing balance on the last business day of the previous quarter. Unless negotiated otherwise, the annual advisory fee is 1.25%. Assets Under Management Assets Under Management Annual Advisory Fee 1.25% 5  If the annual fee is 1.25%, clients will be charged 0.3125% quarterly in arrears. This fee will be directly debited from the account(s) being managed. Example: If the account value at the end of the quarter is $1,000,000, that amount will be charged 0.3125%, resulting in a quarterly fee of $3,125. Unless negotiated otherwise, this percentage-of-assets structure applies. However, in certain circumstances, Vistamark Investments may charge fees on a monthly basis, utilize flat-fee pricing, or apply other customized fee structures as agreed upon with clients. The Vistamark Investments investment advisory contract can typically be terminated by the client within five (5) business days of the signing of the investment advisory contract, in which case the client will not be responsible for advisory fees incurred during that time. Thereafter, investment advisory agreements can typically be terminated by either party within thirty (30) days after written notice. Investment advisory agreements can be terminated by either party within thirty (30) days after written notice. Investment Advisory Fee Billing Unless negotiated otherwise, Vistamark Investments receives written authorization from the client to deduct advisory fees from an account held by a qualified custodian. Vistamark Investments sends the qualified custodian an invoice of the amount of the fee to be deducted from the client’s advisory account(s) at the end of each quarter or billing period. The qualified custodian sends the client a statement, at least quarterly, that reflects the deductions of the investment advisory fees. Vistamark Investments’ investment advisory fees are billed quarterly, in arrears, and are based on the quarter-end balance of the accounts managed or, if structured differently, on the balance at the end of the relevant billing period. Clients will receive an invoice within the first two weeks of the month after the previous quarter end or billing period. These fees will be directly debited from the account being managed at the end of each quarter or billing period. Investment Management Fee Structure Unless negotiated otherwise, Vistamark Investments’ advisory fees are billed quarterly in arrears, payable quarterly; and based on the quarters ending balance of the Client account on the last day of the previous calendar quarter. Clients’ fees will be directly debited from their account(s) the month after the previous quarter. Investment Advisory Fee Billing Unless negotiated otherwise, Vistamark Investments receives written authorization from the client to deduct advisory fees from an account held by a qualified custodian. Vistamark Investments sends the qualified custodian an invoice of the amount of the fee to be deducted from the client’s advisory account(s) at the end of each quarter. The qualified custodian sends the client a statement, at least quarterly, that reflects the deductions of the investment advisory fees. Vistamark Investments investment advisory fees are billed quarterly, in arrears, and are based on the quarter end balance of the accounts managed. Clients will receive an invoice within the first 2 weeks of the month after the previous quarter end. These fees will be directly debited from the account being managed. Sub-Advisory Service Fees For sub‑advisory services, Vistamark Investments is compensated by the Primary Adviser based on a negotiated fee schedule between the parties. The Firm does not bill or receive fees directly from the underlying clients or investors. Clients of the Primary Adviser pay advisory fees as disclosed in that adviser’s Form ADV. 6  Qualified plan Consulting Fees Vistamark Investments’ qualified plan and retirement plan 3(21) or 3(38) fiduciary services are negotiated individually with the plan sponsor, administrator, or named fiduciary. Fee arrangements may vary and can range between 0.005% and 1.00% of plan assets annually—depending on the size of the plan and services rendered—or may be structured as a flat fee. Fees may be incorporated within investment options and paid to Vistamark Investments via the plan custodian, or may be paid directly by the plan sponsor or company. Qualified and retirement plans may also incur additional expenses imposed by the plan administrator and/or custodian, which are separate from Vistamark Investments’ advisory fees. Either party to the qualified plan consulting agreement may terminate the arrangement with written notice in accordance with the terms of the service agreement. Fees will be prorated for the billing period in which termination occurs, and any unearned advisory fees will be refunded to the client within thirty (30) days, if applicable. Vistamark Investments’ fees for 3(21) or 3(38) fiduciary services are negotiated with the plan administrator and are typically collected through the internal fees and expenses of the plan’s mutual fund investment lineup Other Fees and Expenses Vistamark Investments does not charge additional fees other than the fees listed. Vistamark Investments does not receive or share any additional fees or expenses incurred by clients. Vistamark Investments’ clients will incur brokerage and other transaction costs by the custodian. Vistamark Investments does not receive these fees nor does it share in these fees; see Item 12 for additional information. Item 6: Performance-Based Fees and Side-By-Side Management Vistamark Investments does not charge performance-based fees, nor does it participate in side-by-side management. Side-by-side management refers to the practice of managing some accounts that are charged performance-based fees, while simultaneously managing other accounts that are not. Performance-based fees involve compensation based on a share of capital gains or capital appreciation within a client’s account. Vistamark’s fees are calculated as described above and are not tied to the capital gains or appreciation of assets in client accounts. The only compensation received by Vistamark Investments for its investment management services is the management fee negotiated with clients; no additional fees or compensation are accepted. Vistamark Investments does not charge or share in any performance-based fees. 7  Item 7: Types of Clients Vistamark Investments clients can include individuals, high net worth individuals, business entities, trusts, estates, charitable organizations, and qualified plans. Vistamark Investments does not require an annual minimum fee or asset level for investment advisory or investment planning services. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss When appropriate, Vistamark Investments may use the following methods of analysis when providing investment advice to clients: Methods of Analysis Macroeconomic Analysis - Macroeconomics is the study of the behavior of the economy as a whole and uses various economic indicators that tell us about the overall health of the economy. Macroeconomic analysis can help consumers, firms, and governments make better decisions. Consumers want to know how easy it will be to find work, how much it will cost to buy goods and services in the market, or how much it may cost to borrow money. Businesses use macroeconomic analysis to determine whether expanding production will be welcomed by the market. Governments and central banks turn to macroeconomics when determining budgets, creating taxes, deciding on interest rates, and making policy decisions. Within an investment portfolio, understanding how different asset classes respond to changes in the macroeconomic environment can help investment decision makers make more informed decisions with the goal of improving the overall effectiveness of the portfolio. Fundamental Analysis - Fundamental analysis involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and skill of the company's management, and the outlook for the company's industry. The resulting data is used to measure the true value of the company's equity and debt issuance compared to current market prices. The risk of fundamental analysis is that information obtained, or conclusions drawn are incorrect and the analysis will not provide an accurate estimate of the company’s performance and outlook which in turn, can affect the value of the company’s stock and their creditworthiness, or ability to repay its debt. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Quantitative Analysis - Quantitative analysis is a technique that seeks to understand asset price behavior by using mathematical and statistical modeling, measurement, and research. Quantitative analysis aims to represent a given reality in terms of a numerical value. Quantitative analysis is employed for several reasons, including measurement, performance evaluation or valuation of a financial instrument, and predicting real- world events, such as changes in a country's gross domestic product (GDP). Quantitative analysis uses statistical techniques to examine and analyze past, current, and anticipated future events. Any subject involving numbers can be quantified; thus there are many fields in which quantitative analysis is used and can be beneficial. in different Qualitative Analysis - Qualitative analysis is a form of analysis that uses subjective judgment based on information that is difficult to quantify, such as management expertise, industry cycles, strength of research and development, and labor relations. Qualitative analysis contrasts with quantitative analysis and often the two investment techniques are used together to provide multiple perspectives investment opportunities. 8  Technical Analysis -Technical Analysis involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific investment securities. The risk of market timing based on technical analysis is that charts will not accurately predict future price movements. Current prices of securities often reflect all information known about that security and day to day changes in market prices of securities will follow random patterns and, in these cases, may not be predictable with any reliable degree of accuracy. Cyclical Analysis - Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. The lengths of economic cycles are difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Investment Strategies Vistamark Investments believes that thoughtful diversification across a broad range of asset classes is essential to achieving long-term investment success. Each client portfolio is designed to align directly with the client’s unique objectives and risk tolerance, using a disciplined strategic asset allocation framework that incorporates prevailing long-term market trends. Portfolios are constructed using Vistamark’s proprietary methodology, emphasizing exposures to asset classes that respond differently to key economic drivers such as growth and inflation. By combining assets with low correlations, portfolios are structured to reduce overall volatility compared to the risk of individual asset classes in isolation. While Vistamark remains focused on long-term positioning, short-term adjustments are made only when necessary and strictly in accordance with client mandates. The firm does not engage in speculative strategies or frequent trading of securities, reflecting its conviction that disciplined, strategic portfolio construction best serves client interests over time. Risk of Loss Investing in securities involves risks, including the loss of capital. Securities will and do fluctuate in value. Clients should understand and be prepared for these fluctuations in value as well as for the potential of loss. Vistamark Investments assists clients in determining an appropriate asset allocation strategy based primarily on their risk tolerance and time horizon. Even with these methods in place, there is no guarantee that a client will meet or exceed their investment goals. Vistamark Investments will continually review a client's investment goals, financial situation, time horizon, tolerance for risk and other factors at least annually to determine if the current asset allocation is still appropriate for that client. A client’s participation and understanding of the process, including full and accurate disclosure of all relevant information, is an essential piece to the client to understand the risks involved. Vistamark Investments relies heavily on the information provided by the client in determining the appropriateness of any investment portfolio. Therefore, the responsibility lies with the client to relay accurate and up to date information to Vistamark Investments. This information should include any material changes in the client’s financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each client in advance of investing the client’s assets. Margin balances are expected to remain within prudent industry standards, typically at or below limits set by Federal Reserve Regulation T or the client’s custodian. Clients choosing to maintain higher margin levels may do so only after Vistamark Investments communicates the risks, obtains documented client acknowledgment, and periodically reassesses suitability. Continued elevated margin requires periodic risk reaffirmation through negative consent. 9  Vistamark Investments will make recommendations in line with the client’s stated objectives and risk tolerance, but the decision to use margin ultimately rests with the client, as long as it remains compliant with applicable regulations and custodial policies. If margin use materially violates the client’s stated objectives, risk tolerance, or legal/custodial standards, Vistamark Investments reserves the right to limit or decline further margin transactions to fulfill its fiduciary and regulatory duties. All investments involve risks including possible loss of principal. The following are some of the basic risks associated with the asset classes mentioned in Item 4 of this ADV Part 2. Each investment has its own specific risks, and those risks will vary by investment. Market Risk - All securities are subject to market, economic, liquidity other risks. The market price of a security may fluctuate throughout the day and may vary by exchange. The success of a particular investment depends upon the accurate assessment of the future path of price movements of individual securities. While performance of individual securities is assessed, individual security performance should also be viewed within the context of the overall portfolio. There can be no assurance that Vistamark Investments will be able to predict price movements accurately. Authorized Participant Concentration Risk. Authorized Participant Concentration Risk refers to the potential negative consequences arising when an ETF's ability to maintain its market price close to its Net Asset Value (NAV) relies heavily on a limited number of Authorized Participants (APs). Only an Authorized Participant may engage in creation or redemption transactions related to underlying Exchange-Traded Fund and Exchange-Traded Note transactions, and none of those Authorized Participants is obligated to engage in creation and/or redemption transactions. To the extent that Authorized Participants exit the business or are unable to proceed with creation or redemption orders with respect to the Fund and no other Authorized Participant is able to step forward to create or redeem Creation Units, Exchange-Traded Fund and Exchange-Traded Note shares may be more likely to trade at a premium or discount to NAV and possibly face trading halts or delisting. Capital risk — Investment markets are subject to economic, regulatory, market sentiment, and other risks. All investors should consider the risks that may impact their capital, before investing. The value of your investment may become worth more or less than at the time of the original investment Commodity risk — Commodities markets can be more volatile than traditional investments such as equity or fixed income securities. Commodities may be affected by changes in overall market movements, interest rate changes, and/or events affecting a specific commodity and/or industry. Counterparty risk — risk that one party to a transaction might default on its contractual obligation. Counterparty risk can increase for those transactions not executed on a regulated exchange. Default risk — is the risk that a company or an individual security will be unable to make the required payments on their debt obligation. Lenders and investors are exposed to default risk in virtually all forms of credit extensions. Company risk — Common stocks of individual companies are subject to many risk factors including, but not limited to, economic conditions, government regulations, market risk, and industry risk. Equity security prices may decline as a result of adverse changes in these and other factors. Some equities are more volatile than others and may present higher risk of loss. Credit risk — The value of fixed income securities may decline, and/or the issuer or guarantor of that security may fail to pay interest or principal when the payments are due. As a general rule, lower rated securities carry a greater degree of credit risk, and therefore have a greater risk of loss, than higher-rated securities. 10  Currency risk — Investments that are held or exposed to foreign currency, are exposed to fluctuations in a foreign exchange rate or rates in addition to the risks associated with the specific underlying investment. Derivative risk — Derivatives involve various degrees of risk. The value of derivative investments can be affected by market movements, the underlying companies, changes in interest rates, and/or factors affecting the underlying security. Derivatives can also involve liquidity risk and expiration/time risk. Equity market risk — Equity markets are subject to many risk factors, including economic conditions, government regulations, market sentiment, local and international political events, and environmental and technological issues. Exchange-Traded Fund and Exchange -Traded Note risk – Exchange-Traded Funds and Exchange-Traded Notes contain a range of risks. Those risks include, but are not limited to, price fluctuation of the underlying securities, liquidity risk which may cause difficulty transacting in these securities at a fair market price, and passive investing risk which limits the ability of the underlying investment manager to deviate market exposures from the underlying index. Exchange-Traded Funds and Exchange-Traded Notes prices will fluctuate throughout the trading day; commissions may be charged when trading Exchange-Traded Funds and Exchange- Traded Notes. Fixed Income risk — risks associated with fixed income securities may include, but are not limited to, economic conditions, government regulations, credit worthiness, and fluctuations in interest rates. The secondary market value of fixed income securities will fluctuate with changes in interest rates, liquidity, and the creditworthiness of the specific issuer. Foreign Market risk — Foreign investments present risks that include changes in currency exchange rates, liquidity, economic, and political uncertainty. These risks may be greater in emerging markets. Interest Rate risk —Changes in interest rates will affect investment values. This volatility will typically be greater for long term fixed income securities than for short term fixed income securities. Changes in interest rates may also affect the value of other financial assets. Issuer risk — A security issued by a particular issuer may be impacted by factors that are unique to that issuer and thus may cause that security’s return to differ from that of the market. Liquidity risk — Investments with low liquidity can have significant changes in market value, and there is no guarantee that these securities can be sold at fair market value. Management risk — Investment strategies implemented by a management team of a specific investment fund that doesn’t perform as expected may underperform or suffer significant losses. Management also risk includes personnel turnover of specific individuals hired to manage a fund. Tracking risk — The volatility in the performance of an investment relative to its index/benchmark because of various factors which may include, but are not limited to, active management decisions associated with the underlying investments and fees. Here is a list of the investment types listed in “Item 4” of this ADV Part 2A, with the 3 main risks most commonly associated with each: • Exchange Traded Funds (ETFs) - Market risk, Management risk, Tracking risk. ETF’s are investment vehicles that contain/hold other investments allowing them to be traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of an ETF can be lower from that of the underlying securities, that the ETF may be limited by its investment strategy, and that an ETF's price may fluctuate throughout the day. 11  • Mutual Funds - Market risk, Management risk, Tracking risk. Mutual Funds are investment vehicles that contain/hold other investments and may be limited by their investment strategies (i.e. Growth or Value), and a mutual fund's price may fluctuate based on underlying market conditions, and the pricing of the underlying securities. • Individual Securities - Market risk, Liquidity risk, Issuer-specific risk. Individual securities may be traded on an exchange or over-the-counter. They can be subject to transaction costs, and their market value may fluctuate based on company performance, market conditions, and broader economic factors. While Vistamark Investments has provided a list of risks associated with investing in financial markets there may be additional risks that have not been listed above. Clients should consult with their Vistamark Investments representative about any additional risks with which they may be concerned. Item 9: Disciplinary Information Vistamark Investments has not been the subject of any disciplinary action(s) and does not have any legal or disciplinary information to disclose. Any disciplinary information regarding Vistamark Investments Investment Advisor Representatives (IARs) would be disclosed here as well as additional information being disclosed on the Vistamark Investments IAR’s ADV Part 2B. Criminal or Civil Actions The owners of Vistamark Investments – Mr. Matthew Rice, Mr. Sean McEvilly, and Mr. William Seyfarth—have never been involved in any criminal or civil proceedings Administrative Proceedings There are no administrative proceedings to report. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and/or Affiliations Vistamark Investments and its representatives are not registered or have an application pending to register as a broker-dealer. Neither Vistamark Investments, nor its representatives, are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the foregoing. Vistamark Investments does not recommend or select other investment advisers for clients. Vistamark Investments provides sub advisory services to unaffiliated registered investment advisers and other appropriately registered firms. These relationships create a potential conflict of interest because the Firm receives compensation from the Primary Adviser for its services. The Firm mitigates this conflict by providing investment management services consistent with the investment guidelines established for the strategy and by not having any direct client relationship with the underlying investors. 12  Mr. Matthew Rice acts in the capacity of Chief Investment Officer for First Business Bank headquartered in Madison, WI. Mr. Matthew Rice acts in the capacity of Investment Advisor Representative and Chief Investment officer for Goldstone Financial Group. Mr. Matthew Rice acts in the capacity of owner and consultant for Vistamark Consulting LLC. Item 11: Code of Ethics, Client Transactions and Personal Trading Code of Ethics Vistamark Investments and its employees are committed to a Code of Ethics that is available for review and will be provided to clients and prospective clients upon request. Vistamark Investments strives to comply with all applicable laws and regulations governing its practices. Therefore, Vistamark Investments has set forth guidelines for professional standards of conduct for its associated persons, the goal of which is to always protect our client interests and to demonstrate its commitment to its fiduciary duties of honesty, good faith, and fair dealing with clients. All associated persons are expected to adhere strictly to these guidelines. Associated persons are also required to report any violations of the Firm's Code of Ethics. Additionally, Vistamark Investments maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about clients or their account holdings by Vistamark Investments or any associated person. Participation or Interest in Client Transactions Neither Vistamark Investments nor any of our associated persons has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this Brochure. Personal Trading Vistamark Investments’ employees and associated persons can own securities that are also held in client accounts. In the event it is not possible for Vistamark Investments employees and associated persons’ accounts to participate in block trading, clients’ accounts will be prioritized, over Vistamark Investments’ employees and associated persons, in the trading process. Vistamark Investments does not recommend investments solely because of associated persons personal stakes in the investment(s) or related securities. (e.g. warrants, options, and/or futures) If an associated person owns an investment prior to Vistamark Investments taking a position in that same investment, the CCO will closely monitor the associated person’s account/investment(s). If Vistamark Investments decides to buy or sell that investment, associated persons will be restricted from trading that investment until Vistamark Investments trading in that investment has been completed. Once an investment has been identified for trading, the Vistamark Chief Compliance Officer (CCO) will inform associated persons of their intent to trade in a position, and all associated persons will be asked not to buy/sell the specific investment until all trading activity has been completed. This process has been implemented to mitigate any conflict of interest by not allowing Vistamark Investments’ associated persons to trade ahead of clients and potentially receive more favorable prices. Item 12: Brokerage Practices Selecting Brokerage Firms 13  Vistamark Investments can and has the ability to work with multiple custodians but uses Charles Schwab as its preferred custodian. Therefore, Vistamark Investments will recommend that its clients work with Charles Schwab. Vistamark Investments does not receive fees or commission from this or any arrangement. The custodian and brokers we use Vistamark Investments does not maintain custody of your assets that we manage/on which we advise, although we are deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian”. (e.g. broker-dealer or bank) We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we can assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How we select brokers/custodians We seek to select and use a custodian/broker that will hold your assets and execute transactions on terms that are, overall, attractive when compared with other available providers and their services. We consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (without separate fees for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) Best Execution Vistamark Investments believes in using custodians that provide premium services at competitive rates. The reasonableness of commission rates is based on several factors, including the broker's ability to provide professional services, execution, the broker's reputation, experience and financial stability of the broker or dealer, and the quality of service rendered by the broker or dealer in transactions. Best execution is not measured solely by reference to commission rates. Paying a broker a higher commission rate than another broker might charge is permissible if the difference in cost is reasonably justified by the quality of the brokerage services offered. The above-mentioned custodian, Charles Schwab, has a history of best execution performance that is well documented in various publications and testing results. Your brokerage and custody costs 14  For our clients’ accounts that Schwab maintains, Schwab does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and specific ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the residual cash in your account in Schwab’s Cash Features Program. This commitment benefits you because the overall commission rates you pay could be lower than they would be otherwise. In addition to commissions and asset-based fees, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that is executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means achieving favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like Vistamark Investments. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts; while others help us manage and grow our business. Schwab’s support services are available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph benefit you and your account. Services that do not directly benefit a client. Schwab also makes available to us, other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services that benefit Vistamark Investments Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: 15  • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab can also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. This creates an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business and Schwab’s payment for services for which we would otherwise have to pay rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us. Soft Dollar Benefits Our firm participates in the Schwab Advisor Services™ program offered by Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer. Schwab provides our firm with access to brokerage, custody, and other services—some of which may not be available to retail investors. These services may include brokerage services, research, access to trading platforms, pricing and market data, software, technology, and other products or services that assist us in managing client accounts. Schwab provides these services at no direct cost to our firm, although clients may pay Schwab commissions or other transaction fees. These arrangements are considered to be "soft dollar" benefits. While we believe that Schwab’s services and pricing are generally in the best interests of our clients, the receipt of soft dollar benefits creates a potential conflict of interest. We may have an incentive to select or recommend Schwab based on our interest in receiving these benefits rather than solely on the clients' interest in receiving most favorable execution. However, we strive to put client interests first and review our custodial relationships periodically to ensure they remain appropriate. Broker Dealer Affiliations Vistamark Investments’ owner Mr. Matthew Rice is not registered with a broker dealer. Order Aggregation Order aggregation is the practice of combining multiple customer orders, transactions, or related items into a single, consolidated entity to improve efficiency, reduce costs, or achieve better pricing. It is Vistamark Investments’ practice to aggregate transactions across multiple client accounts if there are enough clients and securities to quantify and qualify for order aggregation. Order aggregation is used when Vistamark Investments reasonably believes that the practice will result in a more favorable overall price for clients. 16  Vistamark Investments will ensure that each participating account receives an average price and, if applicable, bears a proportionate share of all transaction costs. Transactions that do not meet the above criteria will not be aggregated. (i.e. trading in one account) Directed Brokerage In limited circumstances, and at our discretion, clients can instruct Vistamark Investments to use one or more particular brokers for the transactions in their accounts. If clients choose to direct our firm to use a particular broker, clients should understand that this might prevent us from effectively negotiating brokerage commissions on a client’s behalf. This practice can prevent Vistamark Investments from obtaining a favorable price and execution. Thus, when directing brokerage business, clients should consider whether the commission expenses, execution, clearance, and settlement capabilities that clients will obtain through a particular broker are adequately favorable in comparison to those that we would otherwise obtain for clients. Trade Errors Trading errors can and do happen. If a trade error occurs when entering a trade on behalf of a client, Vistamark Investments’ policy is to restore a client’s account to the position it should have been in had the trade error not occurred. Depending on the circumstances, corrective actions can include canceling/busting said trade, adjusting the client account to reflect the appropriate asset allocation and/or the reimbursement of any fees to the client account. Referral Programs Vistamark Investments does not participate in any client referral programs or receive client referrals from a dealer or third party. Item 13: Review of Accounts Periodic Reviews Vistamark Investments conducts periodic reviews of clients’ financial plans, making updates as needed in collaboration with each client. The timing and frequency of these reviews are established and agreed upon between Vistamark Investments and the client, with most portfolio and plan reviews scheduled in advance. Additional reviews may also be initiated at any time by either the client or Vistamark Investments as circumstances warrant. All reviews are carried out by Vistamark Investments’ owners—Mr. Matthew Rice, Mr. Sean McEvilly, and Mr. William Seyfarth. Clients receive written monthly statements from the custodian, accessible by regular mail, email, and through the custodian’s digital platforms. The most recent account statements are used during each review, and clients receive their portfolio and financial plan reviews electronically. Review Triggers Other conditions triggering a review are changes in the portfolio allocation, new information affecting the specific client’s situation, and changes in a client's own situation. Regular Reports Vistamark Investments clients receive monthly, quarterly semi-annual and/or portfolio performance statements. In addition, clients also receive transaction confirmations from the account custodian being used. 17  Item 14: Client Referrals and Other Compensation Vistamark Investments receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain amount. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). Vistamark Investments does not receive client referrals or other additional compensation from anyone providing investment advice or other advisory services to clients. Vistamark Investments does not directly or indirectly compensate any person or entity who is not a supervised person for client referrals. As it relates to our preferred custodian, Schwab provides our firm with access to brokerage, custody, and other services—some of which may not be available to retail investors. These services may include brokerage services, research, access to trading platforms, pricing and market data, software, technology, and other products or services that assist us in managing client accounts. While we believe that Schwab’s services and pricing are generally in the best interests of our clients, the receipt of soft dollar benefits creates a potential conflict of interest. We may have an incentive to select or recommend Schwab based on our interest in receiving these benefits rather than solely on the clients' interest in receiving most favorable execution. However, we strive to put client interests first and review our custodial relationships periodically to ensure they remain appropriate. Item 15: Custody Vistamark Investments does not accept or maintain custody of any client accounts. All clients must place their assets with a qualified custodian. Clients can choose a qualified custodian of their own preference. If a client has no preference of a qualified custodian, Vistamark Investments will recommend a qualified custodian to clients based on their needs (i.e. Charles Schwab). Qualified custodians often allow for direct debit of advisory fees. Therefore, if a custodian allows for direct debiting and the client chooses to have advisory fees direct debited from their accounts, Vistamark Investments directly debits client account(s) for the payment of our advisory fees, unless a client directs us not to and chooses a different method of payment. Clients, through the advisory agreement, give written authorization to have their advisory fees deducted directly from their account(s) at the applicable custodian; Vistamark Investments is deemed to have custody of a client's assets during this fee deduction process and, therefore, must have written authorization from the client to do so. Clients will receive all account statements and billing invoices from the custodian that are required in each jurisdiction, and they should carefully review all statements for important information and accuracy. Under government regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct Schwab to deduct our advisory fees directly from your account or if you grant us authority to move your money to another person’s account. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them. I. II. Vistamark Investments possesses written authorization from the client to deduct advisory fees from an account held by a qualified custodian. Vistamark Investments sends the qualified custodian written notice of the amount of the fee to be deducted from the client’s account. 18  Item 16: Investment Discretion Vistamark Investments provides discretionary investment management services to its clients. Custody options will be discussed and approved by both parties prior to the opening of the initial account. The client must approve of the custodian that will be used and the commission rates paid to the custodian by the client. Vistamark Investments does not receive any portion of the transaction fees and/or commissions paid by the client to the custodian on any given trade and/or transaction. Vistamark Investments’ clients may place limitations on Vistamark Investments’ discretionary authority on specific investments and/or industries. Such limitations customarily arise when the client has restrictions on investing in specific securities and/or industries from an employer or other conflict of interest. Discretionary Authority Vistamark Investments manages individual clients’ investments in a discretionary fashion. A signed investment management agreement/contract between the client and Vistamark Investments establishes the discretionary authority for trading in a client’s account. Where investment discretion has been granted by the client, Vistamark Investments will manage the client’s account and has the ability to make investment decisions without consulting with the client as to what securities are to be bought and/or sold, when the securities are to be bought and/or sold, the amount of securities to be bought and/or sold, and/or the price at which the transaction is being executed. In some instances, Vistamark Investments’ discretionary authority will be limited; as a client can impose certain conditions and/or instructions that Vistamark Investments must adhere to. Non-Discretionary Authority Vistamark Investments does not manage investments on a non-discretionary fashion. Non-discretionary management requires that the advisor and client must both agree to any investment transaction prior to a trade being executed. Non-discretionary clients are at a disadvantage from discretionary clients since all investment transactions require pre-approval before a purchase and/or sale can be made. Sub-Adviser Services Vistamark Investments exercises discretionary authority over the portion of assets assigned to it by the Primary Adviser, subject to the investment guidelines and restrictions established for the strategy. The Firm does not have authority to select custodians, determine client fee arrangements, or modify investment objectives. Item 17: Voting Client Securities Proxy Votes Vistamark Investments can and will assist clients with voting proxies if the client chooses. If a client owns investments, they are direct shareholders and can exercise their right as a shareholder to vote on proxies. In most cases, clients will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, the materials would be forwarded directly to clients by mail, unless clients have authorized the firm to contact clients by electronic mail, in which case we would forward any electronic solicitation to vote proxies. Clients that would like assistance from Vistamark Investments in understanding the material within the proxy and/or would like assistance with the voting process can contact Vistamark Investments by phone or by email using the contact information on the front of this Brochure. It is not Vistamark Investments policy to vote securities on the client's behalf, nor do we accept authority to vote proxies on the clients behalf. 19  Vistamark Investments does not vote proxies for sub‑advised accounts. Proxy voting responsibility remains with the Primary Adviser or the underlying client, as applicable. Class Action Lawsuits Vistamark Investments is not responsible for determining if securities held by clients are the subject of a class action lawsuit or whether clients are eligible to participate in a class action settlement or litigation nor does Vistamark Investments initiate or participate in litigation to recover damages on a client’s behalf as a result of class actions, misconduct, or negligence of any party that is the subject of a class action suit. Any and all inquiries regarding class action suits should be initially directed to the custodian in which the assets are/were held. Item 18: Financial Information Financial Condition Vistamark Investments does not have any financial conditions that will prohibit it from meeting its contractual obligations to clients. Vistamark Investments does not retain, or during the term of registration will not retain, custody of any client’s cash or securities, and does not accept pre-payment of fees in excess of $500.00 per client and/or six or more months in advance. Vistamark Investment and its affiliated persons have not been subject to a bankruptcy petition at any time during the past ten years. Part 2B of Form ADV: Brochure Supplements This brochure supplement provides information about the above listed supervised employees that supplements the Vistamark Investments LLC brochure. You should have received a copy of that brochure. Please contact Mr. Matthew Rice at (312) 895-3001 x 100 if you have not received this brochure or if you have any questions about the contents of this supplement. For more information about Mr. Matthew Rice, please visit FINRA’s Broker Check at www.finra.org/brokercheck and/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov Supplement 1: Mr. Matthew Rice (CRD# 2946351) Supplement 2: Mr. Sean McEvilly (CRD# 6760943) Supplement 3: Mr. William Seyfarth (CRD# 6921144) 20  Supplement 4: Mr. Ryan Walter (CRD# 5066998) Brochure Supplements Supplement 1: Mr. Matthew Rice (CRD# 2946351) Item 1: Cover Page Mr. Matthew Rice VISTAMARK INVESTMENTS LLC 333 Chestnut Street, Suite 100 Hinsdale, Illinois 60521 March 2026 Name: Mr. Matthew Rice Born: 1974 Item 2: Education, Experience, Certifications, & Industry Exams Passed: Northwestern University| Bachelor of Science in Finance and Economics | 1993-1997 Chartered Financial Analyst (CFA®) | 07/2023 CHARTERED FINANCIAL ANALYST (CFA®) CFA is an international professional certification offered by the CFA Institute to financial analysts who complete a series of three examinations. To become a CFA Charter holder, candidates must: • Pass each of three six-hour exams • Possess a bachelor's degree from an accredited institution (or have equivalent education or work experience) • Have 48 months of qualified, professional work experience • Adhere to a strict Code of Ethics and Standards governing their professional conduct Chartered Alternative Investment Analyst (CAIA) | 04/2008 Chartered Alternative Investment Analyst (CAIA) The Chartered Alternative Investment Analyst (CAIA) designation is a globally recognized credential for professionals who work with alternative investments. To become a CAIA Charter holder, candidates must: • Pass the Level I and Level II CAIA exams, and maintain an active membership with the CAIA Association • Possess a bachelor's degree or equivalent and have at least one year of professional experience Financial Services Background for the Preceding Ten Years: Vistamark Investments LLC | Managing Partner, Chief Compliance Officer, and Investment Advisor Representative | 01/2025 – Present Vistamark Consulting LLC | Owner and Consultant | 09/2025 – Present Goldstone Financial Group, LLC | Chief Investment Officer and Investment Advisor Representative | 10/2025- Present First Business Bank | Chief Investment Officer | 09/2023 – Present Fiducient Advisors | Managing Partner and Chief Investment Officer | 01/2006 – 09/2023 Item 3: Disciplinary Information Mr. Matthew Rice has never been the subject of an administrative or self-regulatory organization proceeding; or any other hearing or formal adjudication regarding a professional attainment, designation or license. 21  information visit FINRA’s Broker Check at For more about Mr. Matthew Rice, please www.finra.org/brokercheckand/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Rice currently serves as Chief Investment Officer for First Business Bank in Madison, WI, which operates as a Bank Trust Department rather than a Registered Investment Advisor (RIA). In this role, he provides investment consulting, technology solutions, employee mentorship, and a range of consulting and management services in support of the bank’s trust operations, overseeing approximately $3.5 billion in assets under management as of September 2025. Mr. Rice reports directly to the President of First Business Bank Private Wealth. He has held this position since September 2023 and established Vistamark Investments LLC with the full knowledge and approval of First Business Bank leadership. Mr. Rice may also engage in consulting assignments through Vistamark Consulting LLC, a nonaffiliated entity designated for projects outside the RIA purview. These assignments may include industry advisory services for private equity clients, management consulting engagements through third-party firms, expert witness activities related to complex financial litigation or divorce proceedings, and other specialized consulting services typically unrelated to the registered investment advisory business. Vistamark Investments LLC may, as appropriate, provide resources or support to Vistamark Consulting LLC or directly to Mr. Rice in connection with consulting or other professional engagements. For specific engagements, Vistamark Consulting LLC may also serve as a client of Vistamark Investments LLC. All actual or perceived conflicts of interest are fully disclosed to all relevant parties. Mr. Rice acts in the capacity of Chief Investment Officer and Investment Advisor Representative for Goldstone Financial Group, LLC. In this capacity, Mr. Rice is responsible for directing investment strategy and providing oversight for the firm’s client portfolios. Mr. Rice is not responsible for Goldstone Financial Group’s RIA compliance framework, reports directly to the President of Goldstone Financial Group, and holds no ownership interest in Goldstone Financial Group. Item 5: Additional Compensation Mr. Rice receives compensation from First Business Bank for his role as Chief Investment Officer. Mr. Rice receives compensation from Goldstone Financial Group, LLC for his role as Chief Investment Officer and Investment Advisor Representative. Mr. Rice is the owner of Vistamark Consulting LLC and is compensated for his work and his ownership stake in Vistamark Consulting. Item 6: Supervision As the Chief Compliance Officer (CCO) and Managing Partner of Vistamark Investments LLC, Mr. Matthew Rice is responsible for the supervision of all investment adviser representatives of Vistamark Investments LLC. His contact information is on the cover page of this disclosure document. Mr. Matthew Rice adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s policies and procedures manual, the firm’s compliance manual, including the code of ethics, and applicable securities regulatory requirements. For more information about Mr. Matthew Rice, please visit FINRA’s Broker Check at www.finra.org/brokercheck and/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov 22  Supplement 2: Mr. Sean McEvilly (CRD# 6760943) Item 1: Cover Page Mr. Sean McEvilly VISTAMARK INVESTMENTS LLC 333 Chestnut Street, Suite 100 Hinsdale, Illinois 60521 March 2026 Name: Mr. Sean McEvilly Born: 1991 Item 2: Education, Experience, Certifications, & Industry Exams Passed: Northwestern University | Bachelors of Science in Economics | 2014 Northwestern University | Masters in Management Studies | 2016 Chartered Financial Analyst (CFA®) | 01/2022 CHARTERED FINANCIAL ANALYST (CFA®) CFA is an international professional certification offered by the CFA Institute to financial analysts who complete a series of three examinations. To become a CFA Charter holder, candidates must: • Pass each of three six-hour exams • Possess a bachelor's degree from an accredited institution (or have equivalent education or work experience) • Have 48 months of qualified, professional work experience • Adhere to a strict Code of Ethics and Standards governing their professional conduct Financial Services Background for the Preceding Ten Years: Vistamark Investments LLC | Managing Partner, and Investment Adviser | 09/2025 – Present Vistamark Consulting LLC | Consultant | 09/2025 – Present Grand Canyon University | Professor of Finance | 01/2024 - Present Crescent Capital, LLC | Principal, Chief Compliance Officer, and Investment Adviser | 12/2022 – 12/2025 Morgan Stanley | Financial Advisor | 04/2020 – 11/2022 Wells Fargo | Associate | 02/2017 – 07/2019 PNC Bank | Equity Research Analyst | 07/2016 – 02/2017 Item 3: Disciplinary Information Mr. Sean McEvilly has never been the subject of an administrative or self-regulatory organization proceeding; or any other hearing or formal adjudication regarding a professional attainment, designation or license. For more information about Mr. Sean McEvilly, please visit FINRA’s Broker Check at www.finra.org/brokercheckand/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Sean McEvilly may also engage in consulting assignments through Vistamark Consulting LLC, a nonaffiliated entity designated for projects outside the RIA purview. These assignments may include industry advisory services for private equity clients, management consulting engagements through third-party firms, expert witness activities 23  related to complex financial litigation or divorce proceedings, and other specialized consulting services typically unrelated to the registered investment advisory business. Vistamark Investments LLC may, as appropriate, provide resources or support to Vistamark Consulting LLC or directly to Mr. Rice in connection with consulting or other professional engagements. For specific engagements, Vistamark Consulting LLC may also serve as a client of Vistamark Investments LLC. All actual or perceived conflicts of interest are fully disclosed to all relevant parties. Mr. Sean McEvilly is engaged in teaching investment and finance courses at Grand Canyon University. Mr. Sean McEvilly serves as Treasurer of the Kellogg Alumni Association of Phoenix, where he oversees fundraising initiatives, manages the chapter’s financial operations, and fosters community engagement among local alumni. He is also actively involved with the Northwestern Undergraduate Alumni Association, supporting programs that bring graduates together across the greater Phoenix area. Item 5: Additional Compensation Mr. Sean McEvilly receives compensation through consulting assignments through Vistamark Consulting LLC. Mr. Sean McEvilly receives compensation from Grand Canyon University for teaching/lecturing as a professor. Item 6: Supervision As the Chief Compliance Officer (CCO) and Principal of Vistamark Investments LLC, Mr. Matthew Rice is responsible for the supervision of all investment adviser representatives of Vistamark Investments LLC. His contact information is on the cover page of this disclosure document. Mr. Sean McEvilly adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s policies and procedures manual, the firm’s compliance manual, including the code of ethics, and applicable securities regulatory requirements. For more information about Mr. Sean McEvilly, please visit FINRA’s Broker Check at www.finra.org/brokercheck and/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov Supplement 3: Mr. William Seyfarth (CRD# 6921144) Item 1: Cover Page Mr. William Seyfarth VISTAMARK INVESTMENTS LLC 333 Chestnut Street, Suite 100 Hinsdale, Illinois 60521 March 2026 Name: Mr. William Seyfarth Born: 1989 Item 2: Education, Experience, Certifications, & Industry Exams Passed: Northwestern University | Bachelor of Science in Finance and Economics | 2011 University of Kansas | Masters in Business Administration | 2017 24  Financial Services Background for the Preceding Ten Years: Vistamark Investments LLC | Managing Partner, and Investment Advisor Representative | 09/2025 – Present Vistamark Consulting LLC | Consultant | 09/2025 – Present Alliance Bernstein L.P. | Financial Advisor | 07/2023 – 09/2025 Keebeck Wealth Management | Financial Advisor | 12/2021 – 12/2022 Goldman Sachs Ayco Personal Financial Management | Financial Adviser | 08/2019 – 12/2021 Dimensional Fund Advisors LP | Financial Adviser | 01/2018 – 04/2019 Industry Exams Passed Series 7 | General Securities Representative | 06/2018 Series 66 | Uniformed Combined State Law Examination | 08/2018 Item 3: Disciplinary Information Mr. William Seyfarth has never been the subject of an administrative or self-regulatory organization proceeding; or any other hearing or formal adjudication regarding a professional attainment, designation or license. For more information about Mr. William Seyfarth, please visit FINRA’s Broker Check at www.finra.org/brokercheckand/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. William Seyfarth may also engage in consulting assignments through Vistamark Consulting LLC, a nonaffiliated entity designated for projects outside the RIA purview. These assignments may include industry advisory services for private equity clients, management consulting engagements through third-party firms, expert witness activities related to complex financial litigation or divorce proceedings, and other specialized consulting services typically unrelated to the registered investment advisory business. Vistamark Investments LLC may, as appropriate, provide resources or support to Vistamark Consulting LLC or directly to Mr. Rice in connection with consulting or other professional engagements. For specific engagements, Vistamark Consulting LLC may also serve as a client of Vistamark Investments LLC. All actual or perceived conflicts of interest are fully disclosed to all relevant parties. Item 5: Additional Compensation Mr. William Seyfarth receives compensation through consulting assignments through Vistamark Consulting LLC. Item 6: Supervision As the Chief Compliance Officer (CCO) and Managing Partner of Vistamark Investments LLC, Mr. Matthew Rice is responsible for the supervision of all investment adviser representatives of Vistamark Investments LLC. His contact information is on the cover page of this disclosure document. Mr. William Seyfarth adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s policies and procedures manual, the firm’s compliance manual, including the code of ethics, and applicable securities regulatory requirements. For more information about Mr. William Seyfarth, please visit FINRA’s Broker Check at www.finra.org/brokercheck and/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov Supplement 4: Mr. Ryan Walter (CRD# 5066998) Item 1: Cover Page Mr. Ryan Walter VISTAMARK INVESTMENTS LLC 25  333 Chestnut Street, Suite 100 Hinsdale, Illinois 60521 March 2026 Name: Mr. Ryan Walter Born: 1982 Item 2: Education, Experience, Certifications, & Industry Exams Passed: The Ohio State University | Bachelor of Science in Finance and Risk Management | 2005 Financial Services Background for the Preceding Ten Years: Vistamark Investments LLC | Partner, Investment Advisor Representative, & Director of Institutional Advisory | 01/2026 – Present Vistamark Consulting LLC | Consultant | 11/2025 – Present NEPC, LLC | Senior Consultant | 03/2022 – 10/2025 Fiducient Advisors | Senior Consultant | 05/2015 – 02/2022 J.P. Morgan | Investment Assistant | 06/2011 – 04/2015 J.P. Morgan Chase | Equity Trading Assistant | 04/2008 – 05/2011 Merrill Lynch | Financial Advisor | 11/2005 – 04/2008 Industry Exams Passed Series 7 | General Securities Representative Series 66 | Uniformed Combined State Law Examination Item 3: Disciplinary Information Mr. Ryan Walter has never been the subject of an administrative or self-regulatory organization proceeding; or any other hearing or formal adjudication regarding a professional attainment, designation or license. For more information about Mr. Ryan Walter, please visit FINRA’s Broker Check at www.finra.org/brokercheckand/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Ryan Walter may also engage in consulting assignments through Vistamark Consulting LLC, a nonaffiliated entity designated for projects outside the RIA purview. These assignments may include industry advisory services for private equity clients, management consulting engagements through third-party firms, expert witness activities related to complex financial litigation or divorce proceedings, and other specialized consulting services typically unrelated to the registered investment advisory business. Vistamark Investments LLC may, as appropriate, provide resources or support to Vistamark Consulting LLC or directly to Mr. Rice in connection with consulting or other professional engagements. For specific engagements, Vistamark Consulting LLC may also serve as a client of Vistamark Investments LLC. All actual or perceived conflicts of interest are fully disclosed to all relevant parties. Item 5: Additional Compensation Mr. Ryan Walter receives compensation through consulting assignments through Vistamark Consulting LLC. Item 6: Supervision As the Chief Compliance Officer (CCO) and Managing Partner of Vistamark Investments LLC, Mr. Matthew Rice is responsible for the supervision of all investment adviser representatives of Vistamark Investments LLC. His contact information is on the cover page of this disclosure document. Mr. Ryan Walter adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and 26  procedures outlined in the firm’s policies and procedures manual, the firm’s compliance manual, including the code of ethics, and applicable securities regulatory requirements. For more information about Mr. Ryan Walter, please visit FINRA’s Broker Check at www.finra.org/brokercheck and/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov 27