ELEMENT POINTE ADVISORS, LLC

Form ADV Part 2A –Brochure March 30, 2025 Item 1. Cover Page 333 SE 2nd Avenue, Suite 2520 Miami, FL 33131 (786) 655-9790 www.elementpointe.com This Form ADV Part 2A (“Brochure”) provides information about the qualifications and business practices of Element Pointe Advisors, LLC, also conducting advisory business under the name of Element Pointe Family Office. If you have any questions about the contents of this Brochure, please contact us at the telephone number listed above. Element Pointe Family Office is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Registration as an investment adviser does not imply a certain level of skill or training. Additional information about Element Pointe Family Office is also available on the SEC’s website at www.adviserinfo.sec.gov.  Form ADV Part 2A –Brochure Item 2. Material Changes This Brochure provides information about a variety of topics related to the business practices, compliance policies and procedures, and conflicts of interest of Element Pointe Family Office (“Element Pointe” ,”Firm”, “we”, ”our”, ”us”). We may make routine updates to this Brochure to improve and clarify the description of such information or in response to evolving industry or firm practices. The Firm has not made any material changes to this Brochure since the last annual amendment which was filed on March 14, 2024. From time to time, we may amend this Brochure to reflect changes in our business practices, changes in regulations, and routine annual updates as required by securities regulators. This complete Brochure or a summary of material changes shall be provided to clients annually and if certain material changes are made. We encourage all current and prospective clients to read this Brochure carefully in its entirety and to discuss any questions you may have with us. Page | 2  Form ADV Part 2A –Brochure Item 3. Table of 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 ........................................................................................................................................................................................ 8 Item 6. Performance-Based Fees and Side-by-Side Management ..................................................................................................................... 14 Item 7. Types of Clients ...................................................................................................................................................................................................... 15 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................................................... 16 Item 9. Disciplinary Information ...................................................................................................................................................................................... 23 Item 10. Other Financial Industry Activities and Affiliations .................................................................................................................................. 24 Item 11. Code of Ethics ...................................................................................................................................................................................................... 25 Item 12. Brokerage Practices ........................................................................................................................................................................................... 27 Item 13. Review of Accounts ............................................................................................................................................................................................ 31 Item 14. Client Referrals and Other Compensation .................................................................................................................................................. 33 Item 15. Custody .................................................................................................................................................................................................................. 34 Item 16. Investment Discretion ....................................................................................................................................................................................... 35 Item 17. Voting Client Securities ..................................................................................................................................................................................... 36 Item 18. Financial Information ......................................................................................................................................................................................... 38 Page | 3  Form ADV Part 2A –Brochure Item 4. Advisory Business Firm Information Element Pointe Family Office is a wealth management and family office advisory firm. We offer Investment Management, Financial Planning, Consulting, Family Office Advisory and Retirement Plan Advisory services, and affiliated private fund management. The Firm was formed in 2016 as a Delaware limited liability company and is owned by David Savir and Carlos A. Dominguez directly and indirectly through Element Pointe Group, LLC, a holding company. While this Brochure generally describes our business, certain sections also discuss the activities of our Supervised Persons, which refer to our officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on our behalf and is subject to our supervision or control. Advisory Services We provide advisory services to high-net-worth individuals, trusts, estates, retirement plans, charitable organizations, corporations, other business entities, and pooled investment vehicles. Our advisory services are provided to individual, joint, retirement, trust and estate, and separately managed accounts (each a client “account” or “portfolio”). These services include wealth management, which generally encompasses a combination of comprehensive financial planning, family office and consulting services, as well as discretionary and non-discretionary investment management services (further described below). Prior to rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with us which define the terms, conditions, authorities and responsibilities of our Firm and the client. Family Office Advisory Services We serve as a family office advisor to ultra-high net worth (“UHNW”) families (generally with liquid net worth greater than $100 million). We recognize that UHNW families have a unique set of needs. In addition to holding assets in many different legal entities, UHNW families often hold assets at many different banks, brokerage firms, and other custodians, and often have significant private company interests and real estate holdings. We understand the challenges of managing these many relationships and vast financial interests. We offer family office advisory services including, but not limited to: Family governance and decision making • Portfolio consulting advice (“manager of managers”). • • Ongoing oversight and/or management of portfolios across multiple financial institutions and/or investment managers • Account aggregation and consolidated reporting • Management of bank and brokerage relationships • Banking and credit consulting • Cash flow and liquidity management • Coordination of activities between tax and legal advisors, banks, and third-party trustees • Estate planning coordination with attorneys and tax advisors • Liquidity and exit planning Learning and development • • Philanthropic consulting • Lifestyle services Page | 4  Form ADV Part 2A –Brochure Investment Management Services We manage client investment portfolios on a discretionary or non-discretionary basis. We help the client to determine their investment objective(s). The following are some important factors we consider when formulating and implementing investment recommendations: • Risk tolerance • Investment time horizon Income and liquidity needs • • Tax considerations • Recommended asset allocation/asset class guidelines • Limitations on investment holdings We maintain a series of asset allocation models based on risk tolerance and investment objective. We primarily allocate client assets among various exchange-traded funds (“ETFs”), mutual funds, independent investment managers (“Independent Managers”), and private funds across a broad spectrum of equity, fixed income, and alternative asset classes. In some limited circumstances we may incorporate individual equity and fixed income securities, private placements, and options. Our investment recommendations are not limited to any specific product or service offered by a broker dealer. Some Independent Managers, investments, and strategies we recommend have account level investment minimums. Where appropriate, we also provide advice about different types of legacy positions or other investments held in client portfolios. Clients may engage us to manage and/or advise on investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, we direct or recommend the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. A client may also give us a limited power of attorney to execute trades at other financial institutions that the client prefers to use for specific accounts (“Held Away Assets”). Access to Held Away Assets includes the ability to view and report on the assets and/or the ability to buy and sell securities in the account. When managing Held Away Assets, we are only responsible for the assets we manage and the decisions and recommendations that we make. We tailor our advisory services to meet the needs of our individual clients and seek to ensure, on a continuous basis, that we manage client portfolios in a manner consistent with those needs and objectives. We consult with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their portfolios. Pursuant to our discretionary authority and absent specific written instructions from the client to the custodian, we will select the cost-basis methodology that we believe to be most tax-efficient when executing trades. Clients are advised to promptly notify us if there are changes in their financial situations or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if we determine that, in our sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to our management efforts. To the extent that any portion of a client’s account is invested in mutual funds, we are governed by the investment restrictions described in the mutual fund’s prospectus and statement of additional information and not by any client-imposed restrictions. Page | 5  Form ADV Part 2A –Brochure Use of Independent Managers As mentioned above, we can select Independent Managers to actively manage a portion of our clients’ assets. Clients will receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. We evaluate a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses we believe are reputable. To the extent possible, we seek to assess the Independent Managers’ investment strategies, past performance and risk results in relation to our clients’ individual portfolio allocations and risk exposure. We also take into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. We continue to provide services related to the discretionary selection of the Independent Managers. On an ongoing basis, we monitor the performance of those accounts Independent Managers manage. We seek to ensure the Independent Managers’ strategies and target allocations remain aligned with our clients’ investment objectives and overall best interests. Financial Planning and Consulting Services We provide financial planning and consulting services on a standalone basis. These services include advice on investment and non-investment related matters, such as retirement planning, education planning, estate planning, and insurance planning. We do not provide financial planning or consulting services to all clients. We determine in our sole discretion whether to offer or provide these services for a given client based on the client’s needs, preferences, and objectives. Financial planning differs from consulting services in that we will prepare a financial plan for a client and the term of advisory services will end, whereas consulting services generally do not include the preparation of a financial plan and are longer term in nature. The client retains the sole responsibility for determining whether to implement any recommendations we make and for placing any resulting transactions. We do not have discretionary authority with respect to the client’s assets unless the client enters into a wealth management agreement with us. A conflict of interest exists if the advice we provide in connection with financial planning or consulting services includes recommendations for other services that we provide. A client is under no obligation to act upon our recommendation. If a client elects to act on any of our recommendations, the client is under no obligation to affect the transaction through us. Retirement Plan Advisory Services We provide ongoing investment monitoring and recommendations of investments on a non-discretionary basis to clients that are trustees or other fiduciaries to retirement plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). This service constitutes “investment advice” under Section 3(21) of ERISA and in these instances, we are a “fiduciary” as such term is defined under Section 3(21) in connection with this service. You should understand that to the extent we are engaged to perform services other than ongoing investment monitoring and recommendations, those services are not “investment advice” under ERISA and we will not be a “fiduciary” under ERISA with respect to those other services. We do not provide recommendations to plan participants with respect to their selection of investments and the client retains the sole responsibility for determining whether to implement any recommendations we make. From time to time, we offer the client or plan participants advisory services that are separate and apart from our Retirement Page | 6  Form ADV Part 2A –Brochure Plan Advisory Services. In offering any such services, we are not acting as a fiduciary under ERISA with respect to such services. If we offer any such separate services, the client will make an independent assessment without reliance on our advice or judgment. Affiliated Private Fund We serve as investment manager to Element Pointe Deep Access Fund, LP (“EP Deep Access Fund”), a special purpose vehicle (“SPV”) and private fund. Our affiliate, Element Pointe Deep Access GP, LLC (“EP Deep Access GP”), serves as EP Deep Access Fund’s general partner. EP Deep Access Fund is a Delaware limited partnership. EP Deep Access Fund was formed to acquire an interest in a non-publicly traded security. EP Deep Access Fund’s assets and liabilities are held separately and are not commingled with the Firm’s funds. EP Deep Access Fund was created in connection with our identification of a private investment for inclusion in some clients’ portfolios, but where the availability to individual investors limited clients’ participation. In its capacity as general partner, EP Deep Access GP coordinated the structuring of the EP Deep Access Fund and manages its operations, including retaining legal and accounting professionals. EP Deep Access GP has delegated the day-to-day operations to us. EP Deep Access Fund has defined investment objectives that are set forth in its offering documents and we tailor our investment advisory services to meet those objectives. We, or our affiliate, offer the opportunity to invest in an affiliated private fund to other investors, including, without limitation, potential clients and business partners, which are strategically important to our business and our ability to serve the long- term interests of our clients. This is a conflict of interest because third-party investors are allocated a portion of an investment that could have otherwise been offered to a client. To mitigate this conflict, we will support any such allocations with a written justification regarding how the allocation stands to benefit our long-term ability to serve our clients’ interests. These determinations will require the approval of the Chief Compliance Officer. Assets Under Management As of December 31, 2024, the Firm had approximately $1,585,889,338 in total Assets Under Advisement (“AUA”), which includes $854,542,445 of Regulatory Assets Under Management (“AUM”). Of this AUM, we managed $802,072,113 on a discretionary basis, and $52,470,332 on a non-discretionary basis. Additionally, AUA includes, but is not limited to, personal property, outside investments, and other real assets of approximately $737,602,754 (as of December 31, 2024), for which we provide family office advisory or consulting services. These are non-GAAP accounting assets and include values derived from information provided by the families with whom we work and are not independently verified by us. In addition to our AUA, we provide consolidated reporting-only services for an additional $133,833,137 in assets (as of December 31, 2024). Page | 7  Form ADV Part 2A –Brochure Item 5. Fees and Compensation We offer services on a fixed and/or asset-based fee basis which is determined by the client’s assets under management and/or advisement. Occasionally, clients ask us to report on assets we do not manage. In such cases, and in our sole discretion, we can negotiate a fixed reporting fee or, alternatively, charge an asset-based reporting fee determined by the value of the assets on which we provide reporting services. This reporting fee generally does not exceed 0.20% of the value of the non-managed assets for which we are asked to provide reporting services. Investment Management and Family Office Advisory Fees We offer services for an annual fee based on the amount of assets under our management. This management fee is set forth in the client’s wealth management agreement and varies in accordance with the following blended (weighted-average) fee schedule: PORTFOLIO VALUE ANNUAL FEE First $3,000,000 1.00% Next $7,000,000 0.85% Next $15,000,000 0.65% Next $25,000,000 0.45% Next $50,000,000 0.40% Above $100,000,000 0.25% Our fee for family office advisory services is determined on a case-by-case basis that typically depends on our assessment of the scope of work, complexity of the engagement, overall relationship size, and potential for future revenue. In some instances, we may choose to provide family office services for no additional fee beyond the fee paid to us for investment management services. This practice creates a conflict of interest because some family office clients will pay more than other clients will for our services. To mitigate this conflict, we make clients aware of this conflict herein to assure they are aware of this conflict prior to engagement of our services. Alternatively, we charge a negotiated fixed fee that is based upon the anticipated services and assets managed for a particular client. Notwithstanding the standard fee schedule shown above, the fees we charge for our services are negotiable at our sole discretion, and arrangements to charge a lesser fee can cause a client’s fee to differ from the fee charged to others, as explained further in the section below titled “Fee Discretion.” We prorate the annual fee and charge it quarterly, in arrears, based upon the market value of the average daily account balance for each day of that quarter, including accrued interest and dividends. Since the asset-based fee is determined by the average daily account balance, assets that are deposited into or withdrawn from an account after the inception of a quarter (and for assets managed in the initial quarter), are billed on a pro rata basis. Advisory fees on investments in hedge funds and private equity funds held in or reflected on the statements of brokerage custodians we recommend will be billed quarterly, in arrears, based on the average daily value, in accordance with the valuation methodology outlined below in the section titled “Valuation of Private Funds for Fee Billing.” Page | 8  Form ADV Part 2A –Brochure For Held Away Assets, which includes private fund positions held in, or reflected on the statements of, custodial brokerage accounts outside of brokerage custodians we recommend, we will charge an annual fee (which is pro- rated and billed quarterly, based on a 360-day calendar, and charged in advance) based upon the value of the assets in the account at the close of business on the last day of the previous quarter. Upon termination of an account holding Held Away Assets, we refund prepaid fees due to the client on a prorated share based on the remaining days of the 90-day period. Independent Managers typically charge additional fees pursuant to such relationship and clients should refer directly to the disclosure document provided by the Independent Manager for its standard fee schedule. Account Value Calculation for Fee Billing Through our account aggregation and portfolio accounting software provider, we receive a data feed from each custodian, which includes daily positions, transactions, and asset values. The value we use to calculate advisory fees can differ from the net value shown on the brokerage statement the custodian of a client’s assets provides. There are two primary reasons for these values to differ: 1) Trade Date versus Settlement Date – The brokerage statements most custodians provide value all securities and cash balances based upon trades not being completed until settlement date (when the money is due), while the value we use for billing is derived from our account aggregation and portfolio accounting software, which values all securities and cash balances based upon trade date (initiation of cost basis for performance and tax reporting purposes). For example, if a recent buy in an account has executed, but not yet settled at quarter-end, the trade will still show as a cash position on the brokerage statement the custodian provides. In contrast we will use the purchased security and value for performance and billing calculations. 2) Accrued Interest and Dividends – We include accrued interest and dividends in calculating the daily value of assets in accounts on which we serve as advisor. This may differ from the value reflected in statements the custodian provides, as most custodians do not include the value of accrued interest and dividends; rather, most custodians use a cash accounting method wherein dividend and interest income is not accounted for until paid. We calculate advisory fees in a standardized manner, which reflects the initiation and disposition of securities, accrued interest and dividends, and flows into and out of an account as well as the timing of these flows. Valuation of Private Funds for Fee Billing Portfolios we manage and advise on sometimes include investments in private funds that are not reflected on custodian brokerage statements (i.e., the fund sponsor sends statements to the client). For billing purposes, we use the most recent valuation the manager of the fund has provided, plus any net contributions to the fund since the most recent valuation the fund manager has provided. The value provided for a certain investment will be the fund manager’s estimate of its current value, not the liquidation value of the investment. In instances where custodian statements include private funds and the data feed we receive from the custodian also includes such positions, we rely on the data the clients’ custodian or record keeper provides via the data feed to our portfolio accounting software provider for the valuation used to calculate our fees related to such positions. We determine the billing methodology (i.e., whether in arrears or in advance) based on whether the account is held at brokerage custodians we recommend (billed in arrears based on average daily value) or Held Away (billed in advance, as discussed above). Investments Page | 9  Form ADV Part 2A –Brochure in private funds not reflected on custodian brokerage statements (i.e., the fund sponsor sends statements to the client) are billed in arrears based on average daily value during the period. In the case of private funds, average daily value will be the most recent valuation, plus any capital contributions since the last valuation date, minus any distributions since the last valuation date. Unlike publicly traded securities, private funds’ valuations do not fluctuate daily. Valuation of Direct Investments in Private Companies for Fee Billing Pursuant to a written agreement, we may advise clients on direct investments in private companies. We do not attempt to value these investments or determine a fair value. Rather, for billing and performance reporting purposes, we will value the assets at cost, until the private company obtains a valuation statement from an accredited accounting firm or investment bank, or until the company successfully raises follow-on capital at an updated valuation. Assets Excluded from Fee Billing At the inception of a client relationship, we often open two accounts for a client, one of which is classified as a “Funding/Self- Directed” account, and the other is classified as a “Managed” account. The “Funding/Self-Directed” account is intended to hold a client’s self-directed trades (i.e., trades that the client instructs us to make, that are directed by the client and not expressly recommended by us). Additionally, we may, at our sole discretion, agree to hold specific cash balances in the “Funding/Self- Directed” account where the client has expressly requested that we maintain a specific amount in cash or cash equivalents, for a specified period of time, for the purpose of funding the client’s upcoming cash need or large capital expenditures. We may, at our sole discretion, use the “Funding/Self-Directed” account to segregate legacy concentrated stock positions we inherit from the client’s prior brokerage firm, where the client has specifically requested that we retain and not liquidate these positions in their account. We exclude the balances within this account from fee billing. Notwithstanding the above paragraph, we view and treat cash as an asset class, and newly deposited cash will be placed in a “Managed” account unless otherwise agreed to by Element Pointe. We regularly evaluate and analyze cash equivalent products and securities in an effort to preserve capital, enhance yield, and preserve buying power within clients’ portfolios. Furthermore, at any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Element Pointe may maintain large cash positions in billable “Managed” accounts for risk-management purposes. As such, the billable “Managed” account holds investment assets, which includes cash, money market funds, or cash equivalents that are part of the overall investment portfolio and strategy, and the account balances of a “Managed” account are included in fee billing. Depending upon current yields, at any point in time, our advisory fees could exceed the interest paid by the client’s money market fund or cash equivalent instrument. Financial Planning and Consulting Fees We determine our fee for financial planning on a case-by-case basis that typically depends on the complexity and scope of work, although we can waive the fee at our discretion. For consulting engagements, our fees are determined on a case-by-case basis based on the scope of work to be performed. We may also consider other factors such as the client’s specific needs and circumstances and whether other professionals are needed to render the services being contemplated. For financial planning engagements, we will invoice the client for the fees owed for services upon delivery of a completed financial plan to the client. For consulting services, the fee is negotiated based on the scope of the engagement and the client is required to pay us at the time of consultation or in accordance with a payment schedule for ongoing consulting engagements. Page | 10  Form ADV Part 2A –Brochure Affiliated Private Fund Fees and Expenses Investors in an affiliated private fund will pay operating and organizational fees and performance-based fees to the Element Pointe affiliated general partner as compensation for services. Specific details are set forth in the private fund’s offering documents. This practice presents a conflict of interest and gives us an incentive to recommend an affiliated private fund based on the compensation the Element Pointe affiliate receives overall, rather than based on a client’s needs. To address this conflict, in addition to disclosing it to clients, we do not charge investment management fees on client assets invested in an affiliated private fund. Clients have no obligation to invest in a private fund we manage. Performance-Based Fees We do not charge performance-based fees for Investment Management, Financial Planning, Consulting, Family Office Advisory Services, or Retirement Plan Advisory Services. For client investments in private funds we manage, our affiliate serving as general partner will earn performance-based compensation, which is compensation that is based on a share of realized profits of the affiliated private fund’s assets. The performance-based compensation is set forth in the affiliated private fund’s offering documents. We have a financial incentive to allocate client assets to an affiliated private fund rather than investment products managed by nonaffiliated firms, in that it creates the opportunity to receive performance-based fees that are higher than annual wealth management fees. We do not charge investment management fees on clients’ assets invested in an affiliated private fund in order to mitigate this conflict. Fee Discretion Arrangements to charge a lesser fee to a particular client can differ from the fee charged to another. The fees we charge for our various advisory services are negotiable at our sole discretion. This includes fees for asset management services we provide with respect to certain client holdings (e.g., Held Away Assets, accommodation accounts, alternative investments, etc.). We can choose to lower or waive advisory fees or aggregate accounts for purposes of calculating billable portfolio values for several reasons, including, but not limited to: anticipated future earning capacity, anticipated future additional assets, dollar amount of assets managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, and pro bono activities. This is a conflict of interest in that some clients will pay more than other clients for our services. To mitigate this conflict, we make clients aware of this difference herein to assure they are aware of this conflict prior to engagement of our services. Performance-based compensation charged in connection with a client’s investment in an affiliated private fund is not negotiable. Additional Fees and Expenses In addition to the advisory fees they pay to us, clients will also incur charges imposed by other third parties, such as broker- dealers, custodians, trust companies, banks, Independent Managers, private investment issuers (private equity funds, hedge funds, or direct investments), other financial institutions, and third-party plan administrators (“TPA”). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees charged by the Independent Managers and TPAs, margin costs, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic Page | 11  Form ADV Part 2A –Brochure fund fees, and other fees and taxes on brokerage accounts and securities transactions. Although we attempt to negotiate similar fees for our clients among the broker-dealer custodians that we recommend, fees are not consistent among custodians, are subject to change, and are subject to the amount of assets our clients maintain with a specific custodian, As a result, clients can pay more or less than other clients for similar services. The minimum amount of client assets that brokerage custodians we recommend require us to maintain are described in Item 12, below. When investing in ETFs, mutual funds, private equity funds, or hedge funds (“fund”) a client will bear the proportionate share of fees and expenses as an investor. The client does not pay these fees directly; rather they are deducted from the fund’s assets and will affect the performance of the investment. Charges imposed directly by a fund in a client’s account are disclosed in the fund’s prospectus or offering documents. We do not receive any portion of these fees. These fees are in addition to the advisory fees we charge. Our brokerage practices are described at length in Item 12, below. Unlike mutual funds and ETFs, stocks do not have underlying fees. Investing in stocks can result in a lower overall cost than investing in mutual funds or ETFs. Although the custodian makes stocks available in a client’s account for investment, the portion of an account that are not invested in stocks can incur a higher cost of investment that can impact the overall performance of the account. An affiliated private fund investor is responsible for paying their share of fund operational and organizational expenses, including legal, accounting, auditing, and other professional expenses, which are set forth in the fund’s offering documents. Direct Fee Debit Clients provide us and/or Independent Managers with the authority to directly debit their accounts for payment of investment advisory fees. The brokerage custodians that act as the qualified custodians for client accounts, from which we retain the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to us. Use of Margin We generally do not use margin in the management of clients’ investment portfolios. If a client specifically requests that we use margin for leveraged investing in securities, we may consent to the use of margin for leveraged investing, in our sole discretion, after careful review of the client’s financial situation, investment experience, and risk tolerance. In these cases, we will assess the fee payable on the total market value of the client’s account, gross of margin. Some clients choose to pledge assets held in an account we manage as collateral for a margin or bank loan used for outside investments, spending, or other needs unrelated to assets we manage. In these cases, we will assess the fee payable on the total market value of the client’s account, gross of margin. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to our right to terminate an account. Additions may be in cash or securities, however we reserve the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to us, subject to the usual and customary securities settlement procedures. However, we generally design our portfolios as long-term investments and the withdrawal of assets can impair the achievement of a client’s investment objectives. We consult with clients about the Page | 12  Form ADV Part 2A –Brochure options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they can be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Page | 13  Form ADV Part 2A –Brochure Item 6. Performance-Based Fees and Side-by-Side Management We do not assess performance-based fees for Investment Management, Financial Planning, Consulting, Family Office Advisory Services or Retirement Plan Advisory Services. For a client investment in an affiliated private fund, our affiliate that serves as general partner will earn performance-based compensation, which is compensation that is based on a share of capital appreciation of the private fund’s assets. See Item 5 above regarding conflicts associated with this arrangement. Page | 14  Form ADV Part 2A –Brochure Item 7. Types of Clients We offer services to individuals, trusts, estates, charitable organizations, corporations, business entities, trustees or other fiduciaries to retirement plans subject to ERISA, and private funds organized by our affiliate. When we provide investment advice to you regarding your retirement plan or individual retirement account, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with retirement clients’ interests, so we operate under a special rule that requires us to act in retirement clients’ best interests and not put our interest ahead of them. Under this regulation’s provisions, we must: Follow policies and procedures designed to ensure that we give advice that is in a retirement client’s best interest; • Meet a professional standard of care when making investment recommendations (give prudent advice); • Not put our financial interests ahead of a retirement client’s when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • • Charge no more than is reasonable for our services; and • Give a retirement client basic information about conflicts of interest. We have an economic incentive to encourage a client to rollover a retirement plan or IRA into an IRA we manage. This arrangement creates a conflict of interest in that it creates an incentive for us to recommend that a client rollover their account for advisory services rather than retaining it with an unaffiliated third party. For this reason, as a matter of policy, we do not solicit retirement account relationships. The retirement accounts that we manage are limited to those where a client for whom we are managing other non-retirement accounts specifically requests to move their retirement account to us for the purpose of consolidating providers, and where we agree to accommodate the client’s request. Minimum Account Value As a condition for starting and maintaining an investment management relationship, we impose a minimum portfolio value of $15,000,000. In our sole discretion, we can accept clients with smaller portfolios based upon criteria, including, but not limited to: anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, and pro bono activities. We only accept clients with less than the minimum portfolio size if we determine the smaller portfolio size will not cause a substantial increase of investment risk beyond the client’s identified risk tolerance. For certain client relationships and at our discretion, we aggregate the portfolios of family members to meet the minimum portfolio size for the relationship. Client investors in an affiliated private fund must meet the investment requirements set forth in the affiliated private fund’s offering documents. Page | 15  Form ADV Part 2A –Brochure Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies We believe that a portfolio should be diversified across asset classes as well as geographies. Numerous academic studies have found that diversification across global asset classes, often referred to as “asset allocation,” is the main driver of the variability of portfolio returns over the long-term. It is therefore important to formulate an asset allocation that will help to preserve and grow wealth over time, while also remaining consistent with an investor’s goals, financial plans, and risk tolerance. We leverage our access to industry leading research on economics, global equities, fixed income, and various other key asset classes to construct portfolios that address clients’ overall goals. The portfolio management process involves the selection of investments and Independent Managers for each of the asset classes within clients’ portfolios. We favor a “core and satellite” approach, using low-fee index funds or beta exposure in large and efficient markets, while also complementing this core beta exposure with a portfolio of thematic ETFs, sector ETFs, and individual stocks, (note: clients’ portfolios with lower account values, generally will not include individual stocks). Furthermore, we utilize active Independent Managers and investments for exposure to specific asset classes, geographies, sectors, or concentrated positions, where we believe that active management can add value. While diversification is important, over-diversification and high fees can dampen a portfolio’s long term return potential. Thus, we strive to be disciplined and efficient in the portfolio construction process. Furthermore, at times, asset classes can have wide deviations from what we believe is fair value. When we perceive that asset classes have become overvalued or undervalued, we aim to make tactical adjustments in clients’ portfolios. We believe that these tactical adjustments can help reduce risk and preserve capital over a market cycle. Although we believe in the importance of making shorter-term tactical adjustments around a strategic target, we do not believe in “all or nothing” market-timing (e.g., alternating between all-cash and all-equities). We believe in the importance of staying invested over the long-term and maintaining long-term exposure to equity and fixed income markets, and other select asset classes, with tactical adjustments as a complement to a long- term strategic allocation. As previously mentioned, we use a “core and satellite” approach to managing U.S. equity allocations. We use low-cost index funds as the “core,” broad-market exposure within equity portfolios. We then complement this core equity allocation with sector, thematic ETF over-weights, and individual stocks based on our views of the relative values of sectors and companies within the U.S. economy. These sector and thematic ETF and individual stock over-weights are primarily implemented through low-cost, sector-specific ETFs, actively managed mutual funds, alternative investments, and private investments. Additionally, we may purchase individual company stocks, including American Depository Receipts (“ADRs”) of non-U.S. companies, where we believe that a stock can meaningfully outperform the broader market over a five year time frame. We utilize equity options and index options in the management of some clients’ portfolios. Prior to our execution of any option transaction in a client’s portfolio, the client will be required to sign a separate agreement with the custodian, authorizing the use of options in the client’s account. The Element Pointe Approach We believe that the first step in providing meaningful advice is to have an in-depth understanding of the client. Once we have Page | 16  Form ADV Part 2A –Brochure a true understanding the client’s needs and goals, we aim to take the following steps to create a customized wealth management plan: Tailor target allocations to the client’s specific ownership structure and estate plan • Review current balance sheet, investment portfolio, and estate plan • Conduct quantitative and qualitative analysis of current portfolio • Develop target allocations that align with the client’s goals • • Select Independent Managers and investment vehicles based on research and due diligence • Continuously monitor the portfolio, making tactical adjustments and rebalancing when appropriate • Communicate regularly to keep the client informed about financial markets, their portfolio, and our views • Meet regularly to review portfolio performance and address any changes to the client’s needs and goals We strive to serve clients by maintaining a customized and disciplined approach, combined with the ability to be nimble when unique opportunities arise. Risk of Loss Investing in securities always involves risk of loss. Depending on the different types of investments utilized, there are varying degrees of risk. Accordingly, you should be prepared to bear investment loss including the loss of your original principal. Further, past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Because of the inherent risk of loss associated with investing, we are unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing as described below. Market Risk Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of our recommendations and/or investment decisions depends, to a great extent, upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. There can be no assurance that we will be able to predict those price movements accurately or capitalize on any such assumptions. Foreign Investment Risk Investing in securities issued by or that invest in non-U.S. companies entails risks that are not typically associated with investing in financial products sold in the U.S. Foreign investments are subject to additional risks including, but not limited to: exchange rates, currency control regulations, political and social instability, expropriation, imposition of foreign taxes (including withholding taxes), market liquidity, information availability, higher transaction costs, foreign government supervision, brokers and issuers, settlement, uncertainty in enforcing contractual obligations, accounting and auditing standards and price volatility. In addition, accounting and financial reporting standards that prevail outside of the U.S. generally are not as rigorous as U.S. standards and, consequently, less information is typically available concerning companies located outside of the U.S. Page | 17  Form ADV Part 2A –Brochure Concentration Risk An investment in a single issuer, geographic area, or sector involves the risk that an investment’s value can be more volatile or perform differently from the overall market. Adverse developments in an issuer’s business, geographic area, sector, or industry could affect a concentrated portfolio’s value more than one that is more diversified and could result in a loss of principal. Mutual Fund and ETF Risk An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains that cannot be offset by a corresponding loss in the event they sell securities for a profit. Shares of mutual funds are distributed and redeemed on an ongoing basis by the fund itself or by a broker acting on the fund’s behalf. The trading price at which a share is transacted is equal to a fund’s stated daily net asset value per share (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). Mutual fund share prices and execution costs may differ based on share class. The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s underlying holdings. The trading prices of a mutual fund’s shares can differ significantly from the NAV during periods of market volatility, which, among other factors, can lead to the mutual fund’s shares trading at a premium or discount to its actual NAV. Shares of ETFs are listed on securities exchanges and transact at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies can cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder has no means to dispose of such shares. Equity Securities Risk Equity securities (common, convertible preferred stocks and other securities whose values are tied to the price of stocks, such as rights, warrants and convertible debt securities) could decline in value if the issuer’s condition declines or in response to overall market and economic conditions. A fund's principal market segment(s) – such as large cap, mid cap or small cap stocks, or growth or value stocks – can underperform other market segments or the equity markets as a whole. Investments in smaller companies and mid-size companies can involve greater risk and price volatility than investments in larger, more mature companies. Fixed Income and Municipal Securities Risk Fixed income securities are subject to interest rate risk and credit quality risk. The market value of fixed income securities generally declines when interest rates rise, and an issue of fixed income securities could default on its payment obligations. Municipal securities carry different risks than those of other fixed income securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event bonds are revenue bonds) to pay interest on its bent and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal level but can be taxable in Page | 18  Form ADV Part 2A –Brochure individual states other than the state in which both the investor and municipal issuer are domiciled. Options Risk Trading options is highly speculative in nature and involves a high degree of risk. Options investing, either directly or indirectly through a fund’s underlying investments, involves risks such as liquidity, interest rates, market conditions, credit and the risk that a position could not be closed timely. The purchase or sale of an option involves the payment or receipt of a premium by the investor and the corresponding right or obligation to either purchase or sell the underlying security, commodity, or other instrument for a specific price at a certain time or during a certain period. Purchasing options involves the risk that the underlying instrument will not experience a change price in the manner expected so, as a result, the investor could lose their premium. Selling options involves the possibility of greater risk because the investor is exposed to the full extent of the actual price movement in the underlying security (unlimited loss) rather than solely being exposed to losing the premium. Real Estate Investment Trusts Risk Investing in Real Estate Investment Trusts (“REITs”) involves risks associated with investing in real estate, including, but not limited to, sensitivity to changes in real estate values, the risk of investment loss due to the use of leverage and other speculative investment practices, interest rate risk, lack of liquidity, and performance volatility. REITs may not be liquid as there is no secondary trading market available. Although a REIT issuer may make repurchase offers from time to time, there is no guarantee that an investor can redeem their shares during the repurchase offer and the issuer may repurchase shares at a price below net asset value and has the ability to suspend repurchases under certain circumstances. Alternative Investments Risk Alternative investments, including funds that invest in alternative investments, can carry a higher degree of risk than traditional equity and fixed income investments. They involve a greater risk of loss, including complete loss of the investment, often charge high fees, and can be illiquid and volatile. Alternative investments often lack diversification, involve complex tax structures, and are delayed in reporting important tax information to investors. Private Investments Risk Private investments carry a greater risk that you could lose all or a part of your investment. Other risks associated with investing in private investments include, but are not limited to: 1) They are highly speculative investments; 2) they are difficult, if not impossible, to sell or liquidate; 3) they are unregistered securities which are not subject to the same regulatory oversight as registered investments; 4) they can have higher expenses and fees than traditional investments; 5) issuer’s representations are difficult to verify independently; and 6) they can have little or no diversification. Independent Manager Risk As previously stated, we can select Independent Managers to manage a portion of our clients’ assets. The use of Independent Managers in investment programs involves additional risks. The success of the Independent Manager depends on the capabilities of its investment management personnel and infrastructure, all of which may be adversely impacted by the departure of key employees and other events. The future performance results of the Independent Manager may differ significantly from the Independent Manager’s past performance. While we intend to employ reasonable diligence in evaluating and monitoring Independent Managers, no amount of diligence can eliminate the possibility that an Independent Manager may provide misleading, incomplete, or false information or representations, or engage in improper or fraudulent conduct, Page | 19  Form ADV Part 2A –Brochure including, but not limited to, unauthorized changes in investment strategy, insider trading, misappropriation of assets and unsupportable valuations of portfolio securities. Margin Risk While the use of margin borrowing can substantially improve returns, it also increases overall portfolio risk. Margin transactions are generally affected using capital borrowed from a financial institution, which is secured by a client’s holdings. Under certain circumstances, the financial institution providing margin can demand an increase in the underlying collateral. If the client is unable to provide the additional collateral, the financial institution can liquidate the client’s account assets to satisfy the client’s outstanding obligations, which could have extremely adverse consequences. In addition, fluctuations in the amount of a client’s borrowings and the corresponding interest rates can have a significant effect on the profitability and stability of a client’s portfolio. Pledged Assets Risk Pledging assets in an account to secure a loan involves additional risks. The lender has the authority to liquidate all or part of the securities at any time without giving prior notice to the client in order to maintain required collateral levels, or can call a loan at any time. As a practical matter, this could cause the sale of assets and therefore realized losses in a declining market. The lender’s collateral requirements can restrict our ability to make investment decisions or recommendations or can force liquidation, which could interfere with a client’s investment goals and/or result in adverse tax consequences. Additionally, the cost of loan interest and advisory fees could exceed investment returns. Private Equity, Private Credit and Hedge Fund Risk Investing in private equity, private credit, or hedge funds involves a high degree of risk. In addition to the risks inherent in the underlying investments, risks include, but are not limited to, limited diversification, no secondary market, and lack of liquidity. Expenses are typically higher than other investments and often include performance fees. The investment duration generally covers several years, limiting an investor’s ability to make redemptions. Additionally, they may require ongoing investment commitments. It is possible to lose some or all of your investment. Direct Investments Risk Investing in direct investments involves a high degree of risk including, but not limited to, limited diversification, limited secondary markets, and lack of liquidity. The investment duration can cover several years and limit an investor’s ability to withdraw funds. It is possible to lose some or all of your investment. Digital Asset Risk Generally, we do not directly advise on cryptocurrencies (e.g. Bitcoin, Ether, etc.), decentralized application tokens and protocol tokens, blockchain‐based assets or other cryptofinance and digital assets. (collectively “digital assets”). We may recommend ETFs, mutual funds or other investments that invest in or engage in transactions related to digital assets. Digital assets represent a speculative investment and involve a higher degree of risk because of their limited adoption and acceptance and investor speculation, which increases their volatility risk. Several factors affect the price of digital assets, including, but not limited to: supply and demand, investors’ expectations with respect to the rate of inflation, interest rates, currency exchange rates, and future regulatory measures (if any) that restrict the trading of digital assets or the use of digital Page | 20  Form ADV Part 2A –Brochure assets as a form of payment. Cybersecurity Risk Our information and technology systems and those of our key service providers are vulnerable to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Although we have implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, they could become inoperable for extended periods of time or cease to function properly. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in our operations and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information. Risk of Natural Disasters, Epidemics, Terrorist Attacks, Acts of War, and Geopolitical Events Countries and regions in which we invest on behalf of our clients, where we and/or the Independent Managers we engage on behalf of our clients have offices, or where we otherwise do business are susceptible to natural disasters (e.g., fires, floods, earthquakes, storms, and hurricanes) and epidemics/pandemics or other outbreaks of series contagious diseases. The occurrence of a natural disaster or epidemic/pandemic could, directly or indirectly, adversely affect and severely disrupt the business operations, economies, and financial markets of many countries (even beyond the site of the natural disaster or epidemic/pandemic) and could adversely affect our clients’ investments or our ability to do business. In addition, terrorist attacks, or the fear or the precautions taken in anticipation of such attacks, could directly or indirectly, materially, and adversely affect certain industries in which we invest on behalf of our clients, where we or the third party managers we engage on behalf of our clients have offices, or where we otherwise do business. Acts of war (e.g., war, invasion, acts of foreign enemies, hostilities and insurrection, regardless of whether war is declared), geopolitical and other events, including geopolitical tensions, economic sanctions, trade disputes, and related responses to these events, have led, and in the future may lead, to immediate and long-term disruptions and uncertainty in the U.S. and global economies and financial markets, which may increase financial market volatility and have significant adverse direct or indirect effects on our clients and their investments. As evidenced by the COVID-19 pandemic, the spread of disease, illness, pandemic, and other health risks, especially those with new or unknown consequences, can impact the United States and other markets causing significant loss of life, supply- chain disruption, sales disruption, market loss, recession, economic collapse, interest rate change and general disruptions in global markets. Events such as these, which cannot be predicted, could materially and adversely affect our client’s investments, both in the near- and long-term, general economic conditions, and market liquidity. The duration of such events can occur over multiple years and without any definitive conclusion. Tax Considerations The cost basis accounting method selected for a particular client will affect that client’s tax liability. Generally, the custodian’s default accounting method for calculating the cost basis for investments is First-In First-Out (FIFO). Pursuant to our investment discretion authority and absent specific written instructions from the client to the custodian, we will select the cost basis we believe to be most tax efficient when executing trades, which can differ from the custodian’s default method. We do not guarantee or represent that our selection will reduce, defer, or eliminate a client’s tax liability or that any particular Page | 21  Form ADV Part 2A –Brochure tax consequences will be obtained. Clients should consult with their tax professionals regarding their particular circumstances. Clients are responsible for advising us and their custodians if they choose to select a specific cost basis accounting method. A client can incur taxes as a result of our actions in connection with managing their account or through underlying investments. For example, our decision to buy or sell securities to allocate a client’s account or to a chosen strategy or portfolio could result in tax liabilities. We attempt to consider general tax implications when we make investment decisions, however, because investment decisions are based on a variety of other factors, decisions can result in less tax-efficiency or undesirable tax consequences for a client. We do not offer tax advice and encourage clients to consult with their accounting or tax professionals regarding their specific situations. Other Risks Disclosed in Specific Disclosure Documents The risks described above represent a general summary of the material risks inherent in our methods of analysis and investment strategies. Investors in pooled investment vehicles should refer to the applicable prospectus, confidential private placement memorandum, or other offering documents, which contain additional risk factors and disclosures and should be reviewed carefully before investing. Page | 22  Form ADV Part 2A –Brochure Item 9. Disciplinary Information We have not been involved in any legal or disciplinary events that would be material to a client’s evaluation of our advisory business or the integrity of our management. Page | 23  Form ADV Part 2A –Brochure Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. In addition to providing clients investment management services, we also manage Element Pointe Deep Access Fund, LP, a private fund that our affiliate, Element Pointe Deep Access GP, LLC, serves as general partner. We may organize and manage other private funds in the future. Affiliated private funds may employ the same or similar investment strategies. As a result, we have a conflict of interest in allocating management time, services, and functions among these commitments and we are not obligated to devote any specific amount of time to them. An affiliated private fund’s general partner will receive performance fees as compensation for its services to the affiliated private fund. As discussed in Item 5 above, this relationship creates a conflict of interest in that it creates an incentive for us to recommend an affiliated private fund investment rather than an investment managed by a third party in that the Element Pointe organization will receive higher overall compensation. The steps we take to address this conflict is set forth in Item 5 above and in the affiliated private fund’s governing documents. Page | 24  Form ADV Part 2A –Brochure Item 11. Code of Ethics We have adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of our Supervised Persons. Our Code of Ethics contains written policies reasonably designed to prevent unlawful practices such as our use of material non-public information and trading of the same of securities ahead of clients to take advantage of pending orders. The Code of Ethics also requires our personnel to report their personal securities holdings and transactions and obtain pre- approval of certain investments (e.g., initial public offerings, limited offerings). We permit Supervised Persons to buy or sell securities that we also recommend to clients. It is also possible that a Supervised Person could take an action with respect to a security investment that is different from that we take with respect to clients. In either case, we permit these transactions if done in a fair and equitable manner that is consistent with our policies and procedures. We have established this Code of Ethics recognizing that some securities trade in sufficiently broad markets to permit Supervised Persons to complete transactions without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, we make exceptions to the policies stated below. When we are engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • • the transaction for the Supervised Person is completed as part of a batch trade with clients; or a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; (iv) shares issued by broad index based exchange traded funds; and (v) shares issued by unit investment trusts that are invested exclusively in one or more open-end funds. Supervised Persons can make personal investments in private securities we recommend, including securities that a client rejects, or in securities that we review but determine are not appropriate for recommending clients invest in due to investment objectives and financial and risk profiles, or an investment not meeting our due diligence standards. This represents a conflict of interest in that Supervised Persons will benefit from the evaluation, investigation, and due diligence we undertake on behalf of our clients, which could result in favorable investment performance. Supervised Persons may not receive favorable investment terms relative to other client investors in private securities we recommend. Clients and prospective clients may contact us at the telephone number listed on the cover of this Brochure to request a copy of our Code of Ethics. As a result of our role as an investment adviser to clients, as well as affiliate private funds we recommend to clients, some clients have multiple business relationships with us and our affiliates. Although we believe that these activities offer opportunities and services that are beneficial to our clients, such activities raise potential conflicts of interest. Namely, that we and our affiliates can receive greater compensation or greater profit if a client avails itself of the various services and Page | 25  Form ADV Part 2A –Brochure investments offered rather than services or investments offered by an unaffiliated third party. Principal Transactions In Connection With the Organization of an Affiliated Private Fund Subject to the terms of the governing documents of the relevant client account, an affiliated private fund may enter into “principal transactions” with a client account within the meaning of Section 206(3) of the Advisers Act in which our affiliate acts as principal for our own account with respect to the sale of a security or other asset to, or purchase of a security or other asset from, such client account. Principal transactions will be completed in compliance with applicable law and the terms of the governing documents of the relevant client account. In connection with such transactions, we will have a conflict between acting in the best interests of a client account and assisting itself or our affiliates by selling or purchasing a particular security. Page | 26  Form ADV Part 2A –Brochure Item 12. Brokerage Practices Recommendation of Broker-Dealers for Client Transactions We recommend that clients utilize the custody, brokerage and clearing services of Fidelity Investments clearing through National Financial Services, LLC and Fidelity Brokerage Services LLC (“Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”) for investment management accounts. Factors that we consider in recommending Fidelity, Schwab, or any other broker-dealer to clients include, but are not limited to, their respective financial strength, reputation, execution, pricing, research, offerings and service. Fidelity and Schwab enable us to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees Fidelity or Schwab charges may be higher or lower than the other or those other financial institutions charge. The commissions our clients pay to Fidelity and Schwab comply with our duty to obtain “best execution.” Clients can pay commissions that are higher than another brokerage custodians might charge to affect the same transaction where we determine that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a financial institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. We seek competitive rates but do not necessarily obtain the lowest possible commission rates for client transactions. Transactions may be cleared through other broker-dealers with whom we and our custodians have entered into agreements for prime brokerage clearing services. In addition, clients may give us the ability to trade securities in accounts held with broker-dealers with whom we do not have an advisory relationship. Should an account make use of these type of relationships, the client may be required to sign an additional agreement, and additional fees are likely to be charged by the custodian or broker-dealer. Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in return for investment research products and/or services, which assist us in our investment decision-making process. We will also obtain research through attendance at conferences and seminars, meetings, and other educational and/or social events. Such research will be used to service all our clients, but brokerage commissions or compensation paid by one client can be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because we do not have to produce or pay for the products or services. We periodically and systematically review our policies and procedures regarding our recommendation of brokerage custodians in light of our duty to obtain best execution. Software and Support Provided by Financial Institutions We receive without cost from Fidelity and Schwab computer software and related systems support, which allow us to better monitor client accounts maintained at the respective custodian. We receive the software and related support without cost because we render investment management services to clients that maintain assets at Fidelity or Schwab. The software and support are not provided in connection with securities transactions of clients (i.e., not “soft dollars”). Page | 27  Form ADV Part 2A –Brochure The software and related systems support benefits us, but not our clients directly. Clients should be aware, however, that our receipt of economic benefits from a broker-dealer creates a conflict of interest since these benefits may influence our choice of broker-dealer over another that does not furnish similar software, systems support or services. Specifically, we receive the following benefits from Fidelity and Schwab: • Receipt of duplicate client confirmations and bundled duplicate statements; • Access to a trading desk that exclusively services their institutional traders; • Access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; • Access to an electronic communication network for client order entry and account information; and • Access to speakers to present at our hosted client events. The availability of these services benefit us because we do not have to produce or purchase them. We mitigate this conflict of interest by disclosing it to clients and reviewing for best execution on a periodic basis. Fidelity waives its fee for providing connectivity between our trade order management system and Fidelity’s custodial and trading platform. Customarily, Fidelity charges investment advisers an annual fee for this connectivity. By waiving this charge, we have an incentive to recommend that clients maintain accounts with Fidelity based on our interest in receiving this benefit for our business rather than based on clients’ interests in receiving the best value in custody services and the most favorable execution of their transactions. This is a conflict of interest. We believe, however, that our selection of Fidelity as custodian and broker-dealer is in the best interests of the clients we recommend to utilize Fidelity as custodian. It is primarily supported by the scope, quality and price of Fidelity’s services based on the factors discussed above and not Fidelity’s services that benefit only us. A custodian can place conditions on the continuing availability of these services. Currently, we do not have to pay for Schwab’s services. Generally, an adviser must maintain a minimum amount of client assets in accounts at Schwab in order to retain its services without cost to the adviser. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend that clients maintain accounts with Schwab based on our interest in receiving Schwab’s services that benefit our business rather than based on clients’ interests in receiving the best value in custody services and the most favorable execution of their transactions. This creates an additional conflict of interest. We believe, however, that, taken in the aggregate, our selection of Schwab as custodian and broker-dealer is in the best interests of the clients we recommend to utilize Schwab as custodian. Our recommendation is primarily supported by the scope, quality and price of Schwab’s services based on the factors discussed above and not Schwab’s services that benefit only us. We receive, without cost, economic and financial markets research from financial institutions, including broker-dealers and asset managers, which assists us in formulating our investment thesis, market views, and individual stock selections. Additionally, financial institutions provide speakers for our client events. We receive this institutional research and access to speakers without cost because these financial institutions offer funds or investment products and services they want us to recommend our clients invest. Clients should be aware that our receipt of institutional research and speakers from financial institutions creates a conflict of interest as these benefits can influence our choice of funds or investment products. Specifically, we currently receive access to research and analysis from the following providers: Page | 28  Form ADV Part 2A –Brochure The Blackstone Group The Carlyle Group • Baron Funds • Baillie Gifford • BlackRock • • Breckinridge • CAIS • • Cliffwater • Columbia • Deutsche Bank • DoubleLine • Fidelity • Goldman Sachs Global Investment Research • Guggenheim • iCapital • Invesco JP Morgan Markets • • Kohlberg Kravis Roberts & Co. L.P. (KKR) • Nuveen • PIMCO • RCP • Vanguard This research is not provided in connection with clients’ securities transactions (i.e., not “soft dollars”). We make an updated version of this list available upon request, as it changes from time to time. We also obtain research through attendance at conferences and seminars, one-on-one meetings where meals are provided or paid for by the financial institutions, and other educational and/or social events, which financial institutions host or sponsor. This creates a conflict of interest because these benefits can influence our choice of funds or investment products and services. We have adopted policies and procedures designed to mitigate and manage these conflicts of interest. Brokerage for Client Referrals We do not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage The client may direct us in writing to use a particular broker-dealer to execute some or all transactions for the client. This includes Held Away Assets. In that case, the client will negotiate terms and arrangements for the account with that broker- dealer and we will not seek better execution services or prices from other broker-dealers or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts we manage (as described below). As a result, the client can pay higher commissions or other transaction costs, greater spreads or receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to our duty of best execution, we may Page | 29  Form ADV Part 2A –Brochure decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Trade Aggregation and Allocation Transactions for each client will be affected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders in order to obtain best execution, to negotiate more favorable commission rates, and/or to allocate trades equitably among our clients to avoid differences in prices and commissions or other transaction costs that could result from such orders being placed independently. Under this procedure, transactions will be averaged as to price and allocated among our clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that we determine to aggregate client orders for the purchase or sale of securities, including securities in which our Supervised Persons invest, we do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. We do not receive any additional compensation or remuneration as a result of the aggregation. Trade allocations will be made prior to the close of business on the trade date. In the event that we determine that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which can include, but are not limited to: (i) when only a small percentage of the order is executed, shares can be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios with similar mandates; (ii) allocations can be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares can be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations can be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, we can exclude the account(s) from the allocation so the transactions can be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order could be executed in all accounts, shares can be allocated to one or more accounts on a random basis. We can only aggregate transactions by custodian, which can result in the price clients with accounts at one custodian receive for a trade differing from the price for trades in the same security placed with another custodian. Trading Errors From time to time, we may make an error in placing a trade on a client’s behalf. We generally consider a “trade error” to be the execution of a transaction on behalf of a client on terms other than those intended. If we place a trade in error, we will generally seek to correct the error and place the client in the position they would have been had the error not occurred. If a trading error results in a profit, we will retain the profit to offset any losses that occur from future trade errors or we will allocate it to a charitable organization. Page | 30  Form ADV Part 2A –Brochure Item 13. Review of Accounts Account Reviews We monitor client portfolios on a continuous basis while regular account reviews are conducted by the Principals of the Firm or their designees on at least a quarterly basis. All investment advisory clients are encouraged to discuss their needs, goals and objectives with us and to keep us informed of any changes thereto. We contact ongoing investment advisory clients at least annually to review our services and/or recommendations and to discuss any changes in the client’s financial situation and/or investment objectives. Account Statements and Reports Clients are provided with transaction confirmation notices and regular account statements directly from the financial institutions where their assets are custodied or from the issuer (in the case of private investments). From time-to-time or as otherwise requested, clients may also receive written or electronic reports from us and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from us or an outside service provider. The value reflected in reports we provide can differ from the net value shown on the brokerage statement provided by the custodian of the client’s assets. There are two primary reasons these values can differ: 1) Trade Date versus Settlement Date – The brokerage statements provided by most custodians value all securities and cash balances based upon trades not being completed until settlement date (when the money is due), while our account aggregation and portfolio accounting software values all securities and cash balances based upon trade date (initiation of cost basis for performance and tax reporting purposes). For example, if a recent buy in an account has executed but not yet settled at quarter-end, the trade will be reflected as a cash position on the brokerage statement provided by the custodian. In contrast, the purchased security and its value will be used for our performance reporting and fee billing calculations. 2) Accrued Interest and Dividends – We include accrued interest and dividends in calculating the daily value of assets in accounts for which we serve as advisor. This may differ from the value reflected in statements provided by the custodian, as most custodians do not include the value of accrued interest and dividends. Most custodians use a cash accounting method instead wherein dividend and interest income is not accounted for until paid. Our performance calculations reflect the initiation and disposition of securities, accrued interest and dividends, and flows into and out of an account as well as the timing of these flows. Through our account aggregation and portfolio accounting software provider, we receive a data feed from each brokerage custodian, which includes the daily positions, transactions, and asset values. We rely on the data provided by the client’s custodian or record keeper, via a data feed to our portfolio accounting software provider, in computing performance. Performance reports we provide are not intended to be a substitute for financial statements issued by the custodian of the client’s assets and should not be relied upon as such. Page | 31  Form ADV Part 2A –Brochure Valuation of Private Funds for Client Reporting Portfolios we manage and advise sometimes include investments private funds that are not reported by the client’s custodian. For reporting and performance calculation purposes, we use the most recent valuation provided by the manager of the fund, plus any net contributions to the fund since the most recent valuation the fund manager provides. The value provided for a certain investment will be the fund manager’s estimate and may not be the liquidation value of the investment. Valuation of Direct Investments in Private Companies for Client Reporting We advise on direct investments in private companies. We do not attempt to value these investments or determine a fair value. Rather, for fee billing and performance reporting purposes, we value the assets at cost, until such time as the private company obtains a valuation statement from an accredited accounting firm or investment bank, or until such time as the company successfully raises follow-on capital at an updated valuation. Page | 32  Form ADV Part 2A –Brochure Item 14. Client Referrals and Other Compensation Compensation Received by Element Pointe Professional Referrals We refer our clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants) to provide certain financial services necessary to meet the goals of our clients. Likewise, we generally receive some non-compensated referrals of new clients from various non-advisory professionals. Custodians We have established relationships with Fidelity and Schwab which act as a custodians for our client accounts. In fulfilling our duties to our clients, we endeavor at all times to act in the best interest of our clients. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may create a financial incentive and influence our recommendation of a custodian. For more information on these custodians and brokerage practices, please see Item 12 – Brokerage Practices. Business Entertainment Our Supervised Persons may be occasionally provided with de minimus meals and entertainment from other financial service providers or third parties in the industry. This may present a conflict of interest in that we have an incentive to maintain a relationship with such providers or third parties. However, all such business entertainment will be conducted in strict accordance with our Code of Ethics, and we will act in our clients’ best interests when engaging in any business with such providers or third parties. Client Referrals from Promoters We do not provide cash compensation to any third-party promoters for client referrals. However, we do provide complimentary meals and entertainment in the context of client appreciation events to individuals, including current clients, who may refer prospective clients to us. The SEC, under its rule governing investment adviser marketing, considers this practice indirect compensation. Indirect compensation creates a conflict of interest so the referral could be biased. Finally, the experience of the client who made the referral may not be representative of any other client's experience with our firm. We compensate certain employees for client referrals. Any such referral fees are paid solely from our investment advisory fees and do not result in any additional charges to clients. Some of our financial professionals receive salary and bonus compensation based, in part, on the amount of client assets they generate and revenue we earn from advisory services. Therefore they have a financial incentive to encourage clients to engage us to provide investment advisory services. We our affiliates and employees, have an incentive to recommend affiliated private funds that we manage in order to receive additional or higher potential compensation. We receive this compensation indirectly through fees earned by our affiliates. Our affiliates and employees invest in affiliated private funds we manage. To avoid a conflict of interest, they are placed on equal footing with the affiliated private fund’s investors. Page | 33  Form ADV Part 2A –Brochure Item 15. Custody Although we do not take physical possession of client funds or securities, we, our affiliate or a Supervised Person are deemed to have custody and/or control of certain client assets in the following situations. Deduction of Fees We are deemed to have custody of clients’ funds to the extent that we have the ability to deduct our advisory fees directly from clients’ accounts. The wealth management agreement and/or the separate agreement with any financial institution generally authorizes us and/or the Independent Managers to debit client accounts for payment of our fees and to directly remit those funds to us in accordance with applicable custody rules. The financial institutions that act as qualified custodians for client accounts, from which we retain the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to us. In addition, as discussed in Item 13, we also provide periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the financial institutions and compare them to those we provide. Standing Letters of Authorization We are deemed to have custody when clients authorize us, via standing letters of authorization, to direct funds to third parties from their custodial accounts. In connection with standing letters of authorization, a client must provide signed written instruction to the custodian to direct transfers to a third party, which the client may instruct the custodian to terminate or change at any time. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. The custodian will verify the instruction with an initial notice, provide the client with a transfer of funds notice promptly after each transfer, and an annual notice reconfirming the instruction. We and our employees may not accept funds in connection with standing letters of instruction, nor may funds be delivered to locations where we conduct business. Affiliated Private Funds We are deemed to have custody of client funds invested in private funds for which our affiliate serves as general partner. Clients invested in an affiliated private fund will receive audited financial statements annually within 120 days of the fund’s fiscal year end. If an affiliated private fund investor does not receive audited financial statements in a timely manner (120 days), they should contact us immediately. Page | 34  Form ADV Part 2A –Brochure Item 16. Investment Discretion With respect to our discretionary client accounts, we are generally granted investment discretion over the selection and amount of securities to be bought or sold in client accounts without obtaining prior consent or approval from the client, subject to the client’s specified investment objectives, guidelines, or limitations (which may arise from applicable laws and regulations or from the terms of such client’s advisory agreement or similar documents). We are only granted discretionary authority upon full disclosure to the client. The granting of such authority is evidenced by the client’s execution of our advisory agreement containing all applicable limitations to such authority. All discretionary trades we make will be accordance with each client’s investment objectives and goals. Based on the terms of the applicable client agreement, we may act in a consulting or advisory capacity only and without discretion. For any third party or affiliated funds, investment guidelines and restrictions are described in the respective fund’s offering documents or our advisory agreement with the fund. In general, investors in such funds are not permitted to impose restrictions or limitations. However, we may enter into side letter or other written agreements with one or more funds investors which have the effect of establishing rights under, or altering, modifying, or changing the terms of interest held by investors. We are generally granted limited or no investment discretion with respect to our non-discretionary investment advisory clients (or the specific asset types or sub-portfolios of discretionary accounts to which consent requirements pertain). Page | 35  Form ADV Part 2A –Brochure Item 17. Voting Client Securities For Investment Management, Financial Planning, Consulting, Family Office Advisory Services or Retirement Plan Advisory Services Accounts We do not vote proxies or monitor or act on security class actions on behalf of clients, unless otherwise requested by a client and accepted by us (see below). Clients maintain exclusive responsibility for: (i) directing the manner in which proxies solicited by issuers of securities they beneficially own will be voted, and (ii) making all elections relative to mergers, acquisitions, tender offers, bankruptcy proceedings, corporate actions, or other types of events pertaining to the client’s investments. Where Independent Managers manage all or a portion of a client’s portfolio, each Independent Manager’s written disclosure documents will address its proxy voting responsibility for the portion of the portfolio that the respective Independent Manager is responsible for managing. We do not render advice to or take any actions on behalf of clients with respect to any legal proceedings, including bankruptcies and shareholder litigation, to which any securities or other investments held in client accounts, or the issuers thereof, become subject, and do not initiate or pursue legal proceedings, including without limitation shareholder litigation, on behalf of clients with respect to transactions, securities, or other investments held in client accounts. The right to take any actions with respect to legal proceedings, including shareholder litigation, with respect to transactions, securities, or other investments held in a client account is expressly retained by the client. For Affiliated Private Funds and Instructed Accounts Where a client has directed us to vote proxies (“Proxy Clients”), e.g. a private fund we manage or adviser directed trust, we have or our affiliate has the authority to vote corporate proxies on their behalf. We have adopted and implemented written proxy voting policies and procedures that are reasonably designed: (i) to vote proxies, consistent with our fiduciary obligations, in the best interests of the Proxy Client; and (ii) to prevent conflicts of interest from influencing proxy voting decisions made on their behalf. Nevertheless, when we cast votes in accordance with our policies and procedures, actual proxy voting decisions made on behalf of a Proxy Client can have the effect of favoring or harming the interests of our other clients. Absent special circumstances, which are described in our Proxy Voting Policies and Procedures, all proxies will be voted consistent with guidelines established and described in our Proxy Voting Policies and Procedures, as they may be amended from time-to-time. A brief summary of our Proxy Voting Policies and Procedures is as follows: • We have formed a Proxy Voting Committee that will be responsible for monitoring corporate actions, making voting decisions in the best interest of Proxy Clients, and ensuring that we submit proxies in a timely manner. • The Proxy Voting Committee will generally vote proxies according to our then current Proxy Voting Guidelines. The Proxy Voting Guidelines include many specific examples of voting decisions for the types of proposals that are most frequently presented, including: composition of the board of directors; approval of independent auditors; management and director compensation; anti-takeover mechanisms and related issues; changes to capital structure; and corporate and policy issues. • Although the Proxy Voting Committee follows the Proxy Voting Guidelines as a general policy, certain issues are Page | 36  Form ADV Part 2A –Brochure considered on a case-by-case basis based on the relevant facts and circumstances. Since corporate governance issues are diverse and continually evolving, we devote an appropriate amount of time and resources to monitor these changes. • Affiliated private fund investors cannot direct our vote on a particular solicitation and cannot revoke our authority to vote proxies. In situations where there is a conflict of interest in the voting of proxies due to business or personal relationships that we maintain with persons having an interest in the outcome of certain votes, we take appropriate steps to ensure that our proxy voting decisions are made in the best interest of the Proxy Clients and are not the product of such conflict. Proxy Clients, including affiliate private fund investors, may contact us to request information about how we voted proxies for their investments, or to get a copy of our Proxy Voting Policies and Procedures, by calling the telephone number listed in Item 1 – Cover Page of this Brochure. Page | 37  Form ADV Part 2A –Brochure Item 18. Financial Information We are required to disclose certain information to clients regarding financial matters of the Firm. • We do not require or solicit the prepayment of more than $1,200 in fees per client for investment advisory services expected or scheduled to be delivered more than six months after such prepayment. • We do not have a financial condition that is reasonably likely to impair our ability to meet our contractual commitments to clients. • We have not been the subject of a bankruptcy petition at any time during the past ten years. Page | 38