OBJECTIVE CAPITAL MANAGEMENT, LLC

Objective Capital Management, LLC 29325 Chagrin Blvd., Suite 204 Pepper Pike, OH 44122 Phone: (216) 468-1231 Fax: (216) 452-9734 Website: www.ocmwealth.com March 21, 2025 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Objective Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at the phone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Objective Capital Management, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for our firm is 156013. Objective Capital Management, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.  Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes Since the Last Update There are no material changes in this brochure from the last annual updating amendment on 03/27/2024, of Objective Capital Management, LLC. Material changes relate to Objective Capital Management, LLC’s policies, practices or conflicts of interests. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. 2  Item 3 Table Of Contents Item 2 Material Changes ............................................................................................................ 2 Item 3 Table Of Contents ........................................................................................................... 3 Item 4 Advisory Business ........................................................................................................... 4 Item 5 Fees and Compensation ................................................................................................. 6 Item 6 Performance-Based Fees and Side-By-Side Management .............................................. 7 Item 7 Types of Clients .............................................................................................................. 7 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 8 Item 9 Disciplinary Information ..................................................................................................11 Item 10 Other Financial Industry Activities and Affiliations.........................................................11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..12 Item 12 Brokerage Practices .....................................................................................................14 Item 13 Review of Accounts ......................................................................................................15 Item 14 Client Referrals and Other Compensation ....................................................................15 Item 15 Custody ........................................................................................................................16 Item 16 Investment Discretion ...................................................................................................16 Item 17 Voting Client Securities ................................................................................................16 Item 18 Financial Information ....................................................................................................17 3  Item 4 Advisory Business Firm Description Objective Capital Management, LLC (“OCM”) is a registered investment adviser based in Cleveland, Ohio. We are organized as a limited liability company under the laws of the State of Ohio. We have been providing investment advisory services since 2011. Christopher Denholm and Tristan Lewis are our principal owners. Currently, we offer the following investment advisory services, which are personalized to each individual client: Investment Management Services Financial Planning Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Objective Capital Management, LLC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Types of Advisory Services Investment Management Services We offer discretionary and non-discretionary investment management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary investment management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. This authority also allows our firm to delegate discretionary authority to sub-advisers who will assist with the management of your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non- discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. When the Client elects to use Objective Capital Management, LLC on a non-discretionary basis, Objective Capital Management, LLC will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, Objective Capital Management, LLC will obtain prior Client approval on each and every transaction before executing any transaction. As part of our portfolio management services, we may use one or more sub-advisers to assist with managing your account on a discretionary basis. The sub-adviser(s) may use one or more of their model portfolios to manage your account, and we will regularly monitor the performance of your accounts managed by sub-adviser(s). We may pay a portion of our advisory fee to the 4  sub-adviser(s) we use; however, you will not pay our firm a higher advisory fee as a result of any sub-advisory relationships. Financial Planning Services We offer financial planning services. Financial planning will typically involve providing a variety of advisory services, including consulting, to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we review and analyze the information you provide to our firm, we may deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Program(s) Our firm does not participate in any wrap fee programs. Assets Under Management As of December 31, 2024, we provide continuous management services for $288,580,241 in client assets on a discretionary basis, and $16,159,921in client assets on a non-discretionary basis. We also manage $315,713,928in client assets under advisement. 5  Item 5 Fees and Compensation Method of Compensation and Fee Schedule Our fee for investment management services is based on a percentage of your assets we manage and is set forth in the following fee schedule: Annual Fee Assets Under Management $0- $2,000,000 $2,000,001- $15,000,000 $15,000,001 and above 1.50% 1.00% 0.85% Our annual investment management fee is billed and payable quarterly in advance based on the value of your account on the last day of the previous quarter. If the investment management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. You may terminate the investment management agreement upon 30-days' written notice to our firm. For accounts opened or closed mid-billing period, unearned fees will be refunded to the Client. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Financial Planning Services We charge an hourly fee of $250 for financial planning services, which is negotiable depending on the scope and complexity of the plan, your situation, and your financial objectives. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you and request that you approve the additional fee. Services are completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Fees are due upon completion of services rendered Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, you may terminate the financial planning agreement by providing written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. 6  Client Payment of Fees Investment management fees are billed quarterly in advance, meaning that we invoice you before the billing period. Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the "Brokerage Practices" section of this brochure. Prepayment of Client Fees We do not require any prepayment of fees of more than $1,200 per Client and six months or more in advance. Fees for financial plans are due, in full, at the commencement of the contract. Investment management fees are billed quarterly in advance. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to the firm. External Compensation for the Sale of Securities to Clients Our firm does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of Objective Capital Management, LLC. Item 6 Performance-Based Fees and Side-By-Side Management Sharing of Capital Gains We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance based fees while at the same time managing accounts that are not charged performance- based fees. Our fees are calculated as described in the Advisory Business section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 Types of Clients Description We offer investment advisory services to individuals, banks and thrift institutions, investment companies, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Account Minimums In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your Account if it falls below a minimum size which, in our sole opinion, is too small to effectively manage. 7  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: • Charting Analysis - involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. • Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company's industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. • Technical Analysis - involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. • Cyclical Analysis - a type of technical analysis that involves evaluating recurring price patterns and trends. • Modern Portfolio Theory (MPT) is a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. • Long Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. • Short Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. • Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. • Option Writing - a securities transaction that involves selling an option. An option is the right, but not the obligation, to buy or sell a particular security at a specified price before the expiration date of the option. When an investor sells an option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. The seller pays the buyer a premium (the market price of the option at a particular time) in exchange for writing the option. Investment Strategy Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Client assets are advised using: Charting and Technical Analysis - The risk of market timing based on technical analysis is that charts may not accurately predict future price movements. Current prices of securities may reflect all information known about the security and day to day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. 8  Fundamental Analysis - The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Cyclical Analysis - Economic/business cycles may not be predictable and may have many fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the FIFO (First-In First-Out) accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, please provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Please note that decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Security Specific Material Risks Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Market Risk: The prices of securities held by mutual funds in which Clients invest may • decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Interest-rate Risk: Fluctuations in interest rates may cause investment prices to • fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Inflation Risk: When any type of inflation is present, a dollar today will buy more than • a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the • dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. 9  Reinvestment Risk: This is the risk that future proceeds from investments may have to • be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. • Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Management Risk: The advisor’s investment approach may fail to produce the • intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. Equity Risk: Equity securities tend to be more volatile than other investment choices. • The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Investment Companies Risk: When a Client invests in open end mutual funds or ETFs, • the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. Long-term purchases: Long-term investments are those vehicles purchased with the • intension of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. Short-term purchases: Short-term investments are typically held for one year or less. • Generally there is not a high expectation for a return or an increase in value. Typically, short- term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. Trading risk: Investing involves risk, including possible loss of principal. There is no • assurance that the investment objective of any fund or investment will be achieved. 10  Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, • that are not back by real assets or tangible securities and are more volatile than traditional currencies and financial assets. Digital currency is a digital representation of value that functions as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender status. Digital currency is not backed or supported by any government or central bank. Digital currency’s price is completely derived by market forces of supply and demand, traded between consenting parties with no broker and tracked on digital ledgers commonly known as blockchains. Investing in digital currency comes with significant risk of loss that a client should be prepared to bear and, due to the nature of cryptocurrencies, clients are exposed to the risks normally associated with investing but also unique risks not typical of investing in traditional securities. These, include, but are not limited to, volatile market price swings or flash crashes, market manipulation, economic, regulatory, technical, and cybersecurity risks. Please also see below for additional description/properties: Increased Price Volatility – The price of cryptocurrency is constantly fluctuating. Susceptible to Error/Hacking – Technical glitches, human error and hacking Unregulated – Digital currency markets and exchanges are not regulated with • the same controls or customer protections available in fixed income, equity, option, futures, or foreign exchange investing. • Trade or balance can surge or drop suddenly. Price can drop to zero. • can occur, which typically do not affect traditional securities to the same extent. • Forks – This implies a splitting of the chain on which the cryptocurrency runs, which makes it go in a different direction, with different rules than the existing blockchain. Soft Fork – only a protocol change; the cryptocurrency still continues to o work on the original blockchain rules. o Hard Fork – a permanent divergence in the blockchain. Item 9 Disciplinary Information Criminal or Civil Actions Objective Capital Management, LLC and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Objective Capital Management, LLC and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings Objective Capital Management, LLC and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Objective Capital Management, LLC or the integrity of its management. Item 10 Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Mitch Stein is a registered representative of Mutual Services Inc. Futures or Commodity Registration Neither Objective Capital Management, LLC nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Mitch Stein is a registered representative of Mutual Services Inc. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable 11  products conflict with the fiduciary duties of a registered investment adviser. Objective Capital Management, LLC always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any Objective Capital Management, LLC representative in such individual’s outside capacities. Tristan Lewis has a financial affiliated business as an insurance agent. Less than 1% of his time is spent on this activity. He will offer Clients services from those activities. As an insurance agent, he may receive separate yet typical compensation. Victoria Callero is a licensed assistant, client operations and perform transactional requests at Mutual Securities, Inc. Jason A Tosh is a registered representative. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Objective Capital Management, LLC always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services any representative of Objective Capital Management, LLC in such individuals outside capacity. Jason A Tosh is a representative at Mutual Securities. Jason A Tosh is the owner of Tosh Travel, LLC. Ryan S Watt is a registered representative. From time to time, he will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Objective Capital Management, LLC always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services any representative of Objective Capital Management, LLC in such individual's outside capacity. Ryan S Watt is a representative at Mutual Securities. Ryan S Watt is a board of directors member at Juvenile Diabetes Research Foundation - Southern and Central Ohio Chapter. These practices represent a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest Objective Capital Management, LLC does not select or recommend other investment advisors. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics The affiliated persons (affiliated persons include employees and/or independent contractors) of Objective Capital Management, LLC have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Objective Capital Management, LLC affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior 12  for affiliated persons of Objective Capital Management, LLC. The Code reflects Objective Capital Management, LLC and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. Objective Capital Management, LLC’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of Objective Capital Management, LLC may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Objective Capital Management, LLC’s Code is based on the guiding principle that the interests of the Client are our top priority. Objective Capital Management, LLC’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to nonpublic information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. Objective Capital Management, LLC will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest Objective Capital Management, LLC and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Objective Capital Management, LLC and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide Objective Capital Management, LLC with copies of their brokerage statements. The Chief Compliance Officer of Objective Capital Management, LLC is Christopher Denholm. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Objective Capital Management, LLC does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front 13  running, affiliated persons are required to disclose all reportable securities transactions as well as provide Objective Capital Management, LLC with copies of their brokerage statements. The Chief Compliance Officer of Objective Capital Management, LLC is Christopher Denholm. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12 Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions We maintain relationships with several broker-dealers. While you are free to choose any broker- dealer or other service provider, we recommend that you establish an account with a brokerage firm with which we have an existing relationship. Such relationships may include benefits provided to our firm, including but not limited to, research, market information, and administrative services that help our firm manage your account(s). We believe that recommended broker- dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by recommended broker- dealers, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. Because we do not pay for these services, we may have a conflict of interest in directing your brokerage business as these services could be considered to provide a benefit to our firm. In recognition of the value of research services and additional brokerage products and services recommended broker-dealers provide, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Directed Brokerage In circumstances where a Client directs Objective Capital Management, LLC to use a certain broker-dealer, Objective Capital Management, LLC still has a fiduciary duty to its Clients. The following may apply with Directed Brokerage: Objective Capital Management, LLC's inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among Clients and conflicts of interest arising from brokerage firm referrals. Best Execution Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. Soft Dollar Arrangements Objective Capital Management, LLC does not receive soft dollar benefits. Aggregating Securities Transactions for Client Accounts Objective Capital Management, LLC is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of Objective Capital Management, LLC. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. 14  Item 13 Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Managing Members and/or Investment Adviser Representatives of our firm will monitor your accounts on an ongoing basis and will conduct account reviews at least quarterly to ensure the advisory services provided to you and are consistent with your stated investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals, • year-end tax planning, • market moving events, • security specific events, and/or, • changes in your risk/return objectives. We will not provide you with additional or regular written reports in conjunction with account reviews. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). We will review your financial plan as agreed upon in the advisory agreement or upon your request. At your request, we may meet with you and/or your third-party money manager(s) to discuss asset allocation, but we will not make recommendations regarding specific investments or provide any regular written reports to you. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by Objective Capital Management, LLC’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Item 14 Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Objective Capital Management, LLC does not receive any economic benefits from external sources. Advisory Firm Payments for Client Referrals Objective Capital Management, LLC may enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with Objective Capital Management, LLC, that refer Clients to Objective Capital Management, LLC in exchange for compensation. All such agreements will be in writing and comply with the requirements of Federal or State regulation. If a Client is introduced to Objective Capital Management, LLC by a solicitor, Objective Capital Management, LLC may pay that solicitor a fee. While the specific terms of each agreement may differ, generally, the compensation will be based upon Objective Capital Management, LLC’s engagement of new Clients and is calculated using a varying percentage of the fees paid to Objective Capital Management, LLC by such Clients. Any such fee shall be paid solely from Objective Capital Management, LLC’s investment management fee, and shall not result in any additional charge to the Client. 15  Each prospective Client who is referred to Objective Capital Management, LLC under such an arrangement will receive a copy of this brochure and a separate written disclosure document disclosing the nature of the relationship between the solicitor and Objective Capital Management, LLC and the amount of compensation that will be paid by Objective Capital Management, LLC to the solicitor. The solicitor is required to obtain the Client’s signature acknowledging receipt of Objective Capital Management, LLC’s disclosure brochure and the solicitor’s written disclosure statement. Item 15 Custody Account Statements As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent qualified custodian. You will receive account statements from the independent qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. You should compare our statements with the statements from your account custodian(s) to reconcile the information reflected on each statement. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, please contact us directly at the telephone number on the cover page of this brochure. Item 16 Investment Discretion Discretionary Authority for Trading Objective Capital Management, LLC may require discretionary authority to manage securities accounts on behalf of Clients. Objective Capital Management, LLC has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize Objective Capital Management, LLC discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Objective Capital Management, LLC allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to Objective Capital Management, LLC in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. Objective Capital Management, LLC does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17 Voting Client Securities Proxy Voting We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. 16  In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. Item 18 Financial Information Balance Sheet A balance sheet is not required to be provided because Objective Capital Management, LLC does not serve as a custodian for Client funds or securities and Objective Capital Management, LLC does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Objective Capital Management, LLC has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years Objective Capital Management, LLC has not had any bankruptcy petitions in the last ten years. 17