RUNNING POINT CAPITAL ADVISORS LLC

Part 2A of Form ADV: Firm Brochure Running Point Capital Advisors LLC 101 North Paci�ic Coast Highway, Suite 305 El Segundo, California, 90245 424-502-3501 www.Runningpointcapital.com March 31, 2025 This Disclosure Brochure (“Brochure”) provides information about the quali�ications and business practices of Running Point Capital Advisors LLC. If you have any questions about the contents of this Brochure, please contact us at 424-502-3501 or jim@runningpointcapital.com. The information in this brochure has not been approved or veri�ied by the United States Securities and Exchange Commission or by any state securities authority. Running Point Capital Advisors LLC is a registered investment adviser. Registration of an Investment Advisor does not imply any level of skill or training. Additional information about Running Point Capital Advisors LLC is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our �irm's CRD number is 306275.  Item 2 Material Changes Running Point Capital Advisors, LLC (“Running Point”) provides its disclosure brochure (“Brochure”) to you when we enter into an advisory agreement with you. We then deliver an updated brochure at least annually. This Brochure, dated March 31, 2025, replaces the version dated March 28, 2024. We will provide you with an updated Brochure, as required, based on the changes or new information, or upon request, at any time without charge. The following material changes have been made since our last Annual Amendment, which was �iled on March 28, 2024: • Item 4 – Advisory Business section was updated to re�lect Running Point’s Assets Under Management as of December 31, 2024. To include information on third-party platforms that provide access to held away assets, Trustee Services and advisory services related to Private Placement Life Insurance (PPLI) and Private Placement Variable Annuity (PPVA). • Item 5 – Fees and Compensation was updated to include additional detail Trustee Services fees and fees the PPLI and PPVA advisory services. • Item 7 – Types of Clients section was updated to re�lect the updated minimum account size. • Item 15 – Custody was updated to re�lect that a related person serves as trustee to a client account. No less than annually, our Brochure will be updated. Within 120 days of our �iscal year end, we will deliver the updated Brochure or summary of material changes which have been made to our Brochure since its last annual update. The summary will include information about how you may obtain an updated Brochure at no charge, and it will include the date of the last annual update. We will provide updated disclosure information about material changes more frequently as needed. 2  Item 3 Table of Contents Item 1 Cover Page Item 2 Material Changes ....................................................................................................................................................... 1 Item 3 Table of Contents ................................................................................................................................................ 2 Item 4 Advisory Business ................................................................................................................................................ 3 Item 5 Fees and Compensation .............................................................................................................................................. 4 Item 6 Performance-Based Fees and Side-By-Side Management .................................................................................................................................. 8 Item 7 Types of Clients ......................................................... 10 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................................................................................................................ 11 Item 9 Disciplinary Information ................................................. 11 Item 10 Other Financial Industry Activities and Af�iliations ............................................................................................................................ 14 Item 11 Code of Ethics, Participation or Interest in Client Transactions and .................................................................. 14 Personal Trading ............................... 17 Item 12 Brokerage Practices .................................................................................................................................................................. 17 Item 13 Review of Accounts ..................................................................................................................................... 17 Item 14 Client Referrals and Other Compensation ....................................................................................................................................... 22 Item 15 Custody ....................................................................................... 22 Item 16 Investment Discretion ................................................................................................................................................................ 23 Item 17 Voting Client Securities ................................................................................................................................ 23 Item 18 Financial Information .............................................................................................................................. 23 ................................................................................................................................. 24 3  Item 4 Advisory Business Running Point Capital Advisors LLC (“Running Point”) is a registered investment adviser with its principal place of business located in California. Running Point became registered with the Securities and Exchange Commission in 2019. James Schlager and Michael Ashley Schulman are the principal owners. Running Point offers the following advisory services to our clients: DISCRETIONARY PORTFOLIO MANAGEMENT Running Point manages the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, Running Point develops a client's personal investment program and creates and manages a portfolio based on that program. We conduct at least one, but sometimes more than one meeting (in person, if possible, otherwise via telephone) with clients in order to understand their current �inancial situation, existing resources, �inancial goals, and risk tolerance. Based on what we learn, we propose an investment program to the client. Upon the client’s agreement to the proposed investment program, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts at least annually, or more frequently if the client noti�ies us about any signi�icant changes to their �inancial or personal circumstances. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. The Client may limit our discretionary authority by providing us with a written communication that details restrictions and other guidelines. Our investment recommendations will generally include advice regarding the following investments: • • • • • • • • • • • • • • 4 Money market funds and other cash instruments Exchange listed securities, and securities traded over-the-counter Mutual fund shares and exchange traded product shares – passive and actively managed Equities Closed-end funds (CEFs) Separately managed accounts Corporate debt securities and asset backed securities Preferred securities Private equity funds Hedge funds Credit funds Municipal securities Governmental securities Real estate and real estate investment trust (REIT) shares/interests  • • • • Master limited partnership (MLP) shares Structured products and derivatives Options and warrants Alternative non-traded private investments As part of our investment advisory services, we may recommend one or more third-party sub- advisers to manage all or a portion of the Client's investment portfolio on a fully discretionary basis. Factors we take into consideration when making our recommendation include, but are not limited to, the money manager's performance, investment strategies, methods or analysis, advisory fees and other fees, assets under management, and the Client's �inancial objectives and risk tolerance. We would generally retain authority to hire/�ire the sub-adviser, and we will periodically monitor the performance of the sub-adviser to ensure its management and investment style remain aligned with the Client's objectives and risk tolerance. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, risk tolerance, liquidity and suitability. FINANCIAL PLANNING We provide �inancial planning services. Financial planning is a comprehensive evaluation of a client’s current and future �inancial state that uses currently known variables to ascertain future cash �lows, asset values and withdrawal plans. Through the �inancial planning process, all questions, information and analysis are considered as they impact, and are impacted by, the entire �inancial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed �inancial plan designed to assist the client in achieving his or her �inancial goals and objectives. In general, the �inancial plan can address any or all of the following areas: • Financial Position: Understand a Client's current �inancial situation. Sources of evaluation • Investment Planning: include income, expenses, assets, liabilities, etc. Determine a suitable way to structure investments to meet �inancial • Income Tax Planning: goals, and determine the appropriate account type (e.g., joint tenants, IRA, Roth IRA, etc.) Evaluate the current tax situation to help minimize a Client's taxes • Retirement Planning: and �ind more pro�itable ways to use the extra income generated. Assess retirement needs to help a Client determine how much to accumulate, as well as distribution strategies designed to create a source of income during retirement years. Insurance Planning and Risk Management: • Credit Planning: • Evaluate a Client's credit needs. Evaluate the Client's insurance needs and • Estate Planning: review insurance policies and the like. Review the Client's cash needs at death, income needs of surviving • Education Planning: dependents and estate planning goals. Review the educational needs for the Client and his/her family and plan for educational expenses. 5  We gather information through interviews and review of documents provided by the Client, including questionnaires. Information gathered includes the Client's current �inancial status, future goals, investment objectives, risk tolerance and family circumstances. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of �inancial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. The client is under no obligation to act upon Running Point’s �inancial planning recommendations or to retain Running Point to implement the client’s �inancial plan. A �inancial plan may require the services of a specialist such as an insurance specialist, attorney or tax accountant. We may recommend third-party service providers or utilize Running Point’s internal professional service advisors, but the Client is under no obligation to use any service provider recommended by us. PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY) Running Point uses third-party platforms, Pontera Solutions Inc. and/or Future Capital (the “Held- Away Asset Platforms”) to facilitate discretionary management of held away assets such as de�ined contribution plan participant accounts. Using the Held-Away Asset Platforms’ Order Management System software, Running Point is able to facilitate discretionary investment management, including trading, for retirement plan participant accounts (often referred to as a participant’s 401k account or HSA). If a client chooses to provide access to these types of accounts through a Held- Away Asset Platform, Running Point will be able to regularly review and monitor the investments, and rebalance and trade as needed, to implement investment strategies similar to the client’s other accounts that are managed at Running Point. In order for Running Point to manage a client’s retirement plan participant account(s), the client will provide the Held-Away Asset Platforms with their retirement plan participant account login credentials. Once the client account(s) is connected to the platform, Running Point will review the current account allocations. When deemed necessary, Running Point will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Client accounts will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Running Point will not have direct access to your log-in credentials stored by the Held-Away Platforms and will only have authority to place investment trades within such accounts. While the Held-Away Asset Platforms have stated that data security measures have been implemented to protect client information, it is important to recognize the inherent risks of sharing account credentials. It is also important to understand that no data security program is impervious to risk. In the event of a data breach involving one of the Held-Away Asset Platforms, there is a possibility that a client’s participant account credentials could be compromised. Moreover, the sharing of login details with a third-party, such as one of the Held-Away Asset Platforms, may not be allowed by the 6 retirement plan’s online platform terms-of-use policies. This could potentially lead to service  providers associated with those accounts disclaiming liability to the client for any unauthorized transactions. This is a critical consideration as it might limit your recourse in the event of unauthorized access to the client account. We recommend that you review the security and privacy policies of the speci�ic online platform(s) associated with your retirement plan participant account(s) with respect to this issue. In light of these considerations, Pontera maintains their Commitment to Client Protection on their website. You can also review a summary of their security measures, terms of use and privacy policy. Similarly, Future Capital maintains an Information Security Program that is designed to safeguard client information, ensure data integrity, and comply with regulatory requirements. More information on Future Capital’s program can be found on their website, including their security policy, terms of use and privacy policy. Running Point recommends that clients also review their account pro�iles to set privacy preferences and to ensure understanding of the scope of the Held-Away Asset Platforms actual contractual obligations. Furthermore, it is essential to consult with your legal counsel to assess the risks associated with this arrangement and the enforceability of the Held-Away Asset Platforms’ policies in protecting your data. Clients are under no obligation to retain Running Point to manage retirement plan participant account(s). These accounts will be billed through Schwab. Running Point is not af�iliated with the Held-Away Asset Platforms . and does not receive any compensation for clients using the platform. PRIVATE PLACEMENT LIFE AND/OR VARIABLE ANNUITY Running Point offers Private Placement Life Insurance (“PPLI”) and Private Placement Variable Annuities (“PPVA”) to quali�ied clients. PPLI and PPVAs involve investing in both publicly traded securities and private illiquid investments. Running Point may be engaged as the Separate Managed Account Investment Manager for PPLI and or PPVA and/or as the licensed registered representative through our insurance af�iliate, Running Point Capital Insurance Agency (“RPCIA”). Running Point sub-advises the assets in the PPLI and/or PPVA capital accounts and charges a management fee on those assets. Please refer to Item 5 - Fees and Compensation for more information regarding Running Point’s fees related to PPLI & PPVA advisory services. TRUSTEE SERVICES We will provide Trustee services to certain client accounts. These services are provided in conjunction with our advisory services for the account and include performing administrative duties, maintaining accurate records and acting in accordance with the trust documents. WRAP FEE PROGRAMS Running Point does not sponsor, or participate in, wrap fee programs. 7  AMOUNT OF MANAGED ASSETS As of December 31, 2024, Running Point has $643,362,647 in assets under management on a discretionary basis and $13,580,519 in assets under management on a non-discretionary basis. Item 5 Fees and Compensation PORTFOLIO MANAGEMENT FEES Running Point generally charges an annual fee based on the client’s assets under management by Running Point, in accordance with the following schedule: Assets Under Management Standard Annual Fee Up to $5 million 1.00% $5 million - $10 million 0.85% $10 million – $20 million 0.75% $20 million - $50 million 0.65% $50 million - $100 million 0.55% Over $100 million 0.45% In addition to the investment management fee described above, Running Point charges additional fees for custom �ixed income management. These fees are negotiable and vary based on such factors as the underlying investment strategy and complexity of the services provided. If custom �ixed income management is used in your portfolio, an additional schedule or exhibit of fees will be provided to you. The following fees are generally assessed as a percentage of the market value of all assets in the account: 1. 2. 3. Customized Target Income Portfolio 0.25% Short Term Fixed Income 0.10% Covered Call Writing Income Strategy 0.50% Running Point’s portfolio management fees are billed quarterly in advance based upon the value (market value or fair value in the absence of market value) of the client's account at the end of the previous quarter, including margin (gross). Our fee shall be prorated for any partial calendar quarter during the terms of the Agreement, based on the number of days in such calendar quarter included in the terms of the Agreement. For those who become clients in the middle of a quarter, Running Point prorates our fee based off the current market value of the account. Clients may choose to be billed directly for fees or authorize Running Point to directly debit fees from their account in accordance with the client authorization in the Wealth Management Agreement. 8  PRIVATE PLACEMENT LIFE INSURANCE/PRIVATE PLACEMENT VARIABLE ANNUITIES FEES Fees on assets that are managed inside a private placement life insurance or variable annuity contract are billed quarterly in arrears by the insurance company using the insurance company’s valuation of the account on the last business day of the previous quarter, including accrued interest. For the �irst billing cycle on new accounts, fees are prorated as of the date of receipt of �irst assets into the account. Charging higher fees for some strategies versus others is a con�lict of interest controlled by investment guidelines, risk tolerance, and investment objectives. The fees charged may be higher than fees charged for other portfolio management services. These assets generally will not be in included in calculating a client’s fees that are held outside of this structure. These fees are generally negotiable based on factors that include, but are not limited to, the total managed assets as well as the totality and complexity of the overall advisory services provided to the client. The �inal fee schedule is included in the Investment Policy Statement (“IPS”) signed by the owner of the PPLI or PPVA contract. Investors are under no obligation to purchase a PPLI or PPVA using Running Point as the asset manager. Running Point believes that its annual fee for PPLI & PPVA management is reasonable in relation to: (1) services provided under the investment advisory agreement; and (2) the fees charged by other investment advisers offering similar services/programs. In addition to compensation of Running Point, clients will also incur transactional charges imposed by the custodian, administrator, and underlying investment fund. An employee of Running Point is also a registered representative of The Leaders Group, Inc., a registered broker-dealer. With respect to the PPLI and PPVA products, the employee in their capacity as a registered representative of The Leaders Group, charges an annual fee between 0 and 0.30% on assets invested in the PPLI or PPVA program, taken as a fee from the cash accumulation within the PPLI or PPVA, and billed quarterly in arrears. The registered representative may also charge a placement fee between 0% and 3% on the premium invested into the PPLI and PPVA (“Placement Fee”). In the event the registered representative does not charge a Placement Fee, Running Point will not charge a set-up fee. This presents a con�lict of interest, in that, both Running Point and the Running Point employee, as a registered representative of The Leaders Group, have an incentive to recommend the PPLI or PPVA to clients. Clients are under no obligation to use Running Point for access to these products. Negotiability of Advisory Fees : The speci�ic manner in which fees are charged by Running Point is established in a written Investment Advisory Agreement with Running Point. All fees may be subject to negotiation, based on several factors, including, but not limited to, the size of the relationship, the nature and complexity of the products and investments involved, time commitments and travel requirements. We may group certain related client accounts for the purposes of determining the annualized fee. 9  FINANCIAL PLANNING FEES Running Point’s Financial Planning fee is determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to Typical costs for �inancial planning arrangements may entering into a contract with any client. range from $3,500 to $30,000 or more, depending on needs and varying complexity. Clients are typically billed in advance for services provided. TRUSTEE SERVICES FEES Running Point’s Trustee services fee ranges from .30% to 1% of assets in the trust. This fee is in addition to the advisory fee charged to for the management of the assets. GENERAL INFORMATION Termination of the Advisory Relationship : A client agreement may be canceled at any time, by either party, for any reason. As disclosed above, certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of portfolio management fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. A client will generally not receive any reimbursement for �inancial planning fees, which are project based. Third-Party Fees : All fees paid to Running Point for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds, ETFs, private funds or other pooled investment vehicles or sub-advisers hired by Running Point for its clients. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. Additional Fees and Expenses : In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which Running Point effects Please refer to the "Brokerage Practices" section (Item 12) transactions for the client's account(s). of this Form ADV for additional information. Advisory Fees in General : Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisors for similar or lower fees. Item 6 Performance-Based Fees and Side-By-Side Management Running Point Capital Advisors LLC does not charge performance-based fees or participate in side- by-side management. Performance-based fees are generally based on a share of the capital gains or capital appreciation of the client account assets. 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. 10  Item 7 Types of Clients Running Point provides advisory services to the following types of clients: • • • • • • • • • Individuals (other than high net worth individuals) High net worth individuals Small businesses and their owners Large businesses and their owners Family Of�ices Trusts and estates Private Foundations Charities Pension and retirement plans MINIMUM INVESTMENT AMOUNTS REQUIRED Running Point generally requires a minimum account size of $5 million for portfolio management services. This account size is subject to change and is negotiable by our �irm, at any time and in our sole discretion. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Our approach for generating asset allocation recommendations is based on extensive market and investment research and may also involve the use of third-party experts, research, or consultants. We utilize economic, �inancial, and market data from third-party sources we believe to be reliable, but we generally do not seek to independently con�irm the accuracy of such information. Similarly, we rely on a variety of third-party �inancial applications to perform numerous �inancial calculations related to asset allocation, �inancial planning projections, investment selection, and investment manager evaluations. Although we may review the quality of these services, there can be no guarantee the calculations will be performed correctly going forward. INVESTMENT STRATEGIES Overall investment strategies recommended to each client generally emphasize long-term ownership of a diversi�ied portfolio of marketable and non-marketable investments (if suitable), intended to provide long-term positive after-tax, in�lation-adjusted, economic returns. Running Point generally recommends broad diversi�ication via a long-term asset allocation strategy - diversi�ied across asset classes and often within asset classes - in an effort to improve the risk and return potential of client portfolios. More speci�ically, we may recommend multiple asset classes (both liquid and illiquid), market capitalizations, market styles, and geographic regions to provide diversi�ication. 11  Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s initial holdings, cost basis, start date, portfolio size, income desires, tax sensitivity, desire for simplicity, timing of additions or withdrawals, long-term wealth transfer objectives, time horizon, and choice of custodian are all factors that in�luence Running Point’s investment recommendations. Investment advice given to clients more often than not, includes recommending long-term purchases or holding on to certain assets. However, other investment strategies that may also be recommended include tax harvesting, short-term purchases, margin transactions, short-selling, options strategies and private placement life insurance and variable annuity policies. RISK OF LOSS Past performance is not a guarantee of future returns. Investing in securities and other investments recommended by Running Point involves certain investment risks. Securities and other investments may �luctuate in value or lose value. Running Point will assist clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a client will meet their investment goals. Investing in securities and other investments involves a risk of loss that each client should understand and be willing to bear. • Market Risk. Either the market as a whole, or the value of an individual company, goes down, resulting in a decrease in the value of client investments. This is referred to as systemic risk. • Equity (Stock) Market Risk. Common stocks are susceptible to �luctuations and to volatile increases/decreases in value as their issuers’ con�idence in or perceptions of the market change. Investors holding common stock (or common stock equivalents) of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. • Company Risk. There is always a certain level of company or industry speci�ic risk when investing in stock positions. This is referred to as unsystematic risk and can be reduced through appropriate diversi�ication. There is the risk that a company may perform poorly or that its value may be reduced based on factors speci�ic to it or its industry (e.g., employee strike, unfavorable media attention). • Fixed Income Risk. Investing in bonds involves the risk that the issuer will default on the bond and be unable to make payments. In addition, individuals depending on set amounts of periodically paid income, face the risk that in�lation will erode their spending power. Fixed-income investors receive set, regular payments that face the same in�lation risk. Bonds are also subject to price �luctuations due to interest rates. • ETPs and Mutual Fund Risk. ETPs and mutual fund investments bear additional expenses based on a pro-rata share of operating expenses, including potential duplication of management fees. The risk of owning an ETP or mutual fund generally re�lects the risks of owning the underlying securities held by the ETP or mutual fund. Clients also incur brokerage costs when purchasing ETPs. 12  • Real Estate Investment Trust (REIT) Risk: The value of REITs can be negatively impacted by declines in the value of real estate, adverse general and local economic conditions and environmental problems. REITs are also subject to certain other risks related speci�ically to their structure and focus, such as: (a) dependency upon management’s skills; (b) limited diversi�ication; (c) heavy cash �low dependency; (d) possible default by borrowers; and (e) in many cases, less liquidity and greater price volatility. • Management Risk. Client investments also vary with the success and failure of Advisor’s investment strategies, research, analysis and determination of portfolio securities. If Advisor’s strategies do not produce the expected returns, the value of a client’s investments will decrease. • Private Investment Risk. Some of the Advisor’s strategies utilize privately placed collective investment vehicles (e.g., hedge funds, private equity funds, etc.). Advisor does not directly manage these vehicles; these investment vehicles retain their own managers who make the investment decisions and underlying security selections for the vehicle. The managers of these vehicles have broad discretion in selecting the investments. Typically, there are few limitations on the types of securities or other �inancial instruments which may be traded or used, and no requirement to diversify. Some types of these investment vehicles may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because private investment vehicles are not registered investment companies, they are not subject to the same regulatory reporting and oversight of a registered entity. There are numerous risks in investing in these types of securities. Clients should consult each investment’s private placement memorandum and/or other prospectus or documents explaining such risks prior to investing. • Illiquid Securities Risk. Portfolios may invest in private market securities or other illiquid investments, which may make it dif�icult or impossible to dispose of such investments at desired times, resulting in less liquidity and thereby increasing the risk of loss. • Margin Risk. Advisor may use margin in its investment strategies. Margin is often used for overdraft protection on behalf of the client. When you purchase securities, you may pay for the securities in full or borrow part of the purchase price from your account custodian or clearing �irm. If you borrow part of the purchase price, then you are engaging in margin transactions and there is risk involved with this. The securities held in your margin account are collateral for the custodian or clearing �irm that loaned you the money. If those securities decline in value, then the value of the collateral supporting your loan also declines. As a result, the brokerage �irm is required to take action in order to maintain the necessary level of equity in your account. The brokerage �irm may issue a margin call and/or sell other assets in your account. It is important that you fully understand the risks involved in trading securities on margin, including: • • You can lose more funds than you deposit in your margin account The account custodian or clearing �irm can force the sale of securities or other assets in your account 13  • • • • • The account custodian or clearing �irm can sell your securities or other assets without contacting you You are not entitled to choose which securities or other assets in your margin account may be liquidated or sold to meet a margin call The account custodian or clearing �irm may move securities held in your cash account to your margin account and pledge the transferred securities The account custodian or clearing �irm can increase its “house” maintenance margin requirements at any time and are not required to provide you advance written notice You are not entitled to an extension of time on a margin call Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our �irm and our management personnel have no reportable legal, regulatory or disciplinary events to disclose. Item 10 Other Financial Industry Activities and Af�iliations In addition to providing the advisory services described in Item 4, above, Running Point also provides the following services to its clients. FAMILY OFFICE SERVICES Running Point offers comprehensive family of�ice services which encompasses both strategic and tactical advisory consulting. • • • • • • • Strategic consulting may include, but is not limited to: Culture, Values, and Vision Alignment Family and Business History Governance & Decision Making Role Clari�ication and Succession Learning and Development Family Meetings and Retreats Philanthropic Services and Legacy Planning • • • • • • Tactical consulting may include, but is not limited to: Enterprise Administration and Reporting Cash and Liquidity Management Estate Planning and Business Transitions Risk Assessment and Mitigation Banking and Credit Consulting Thematic and Impact Investing 14  WEALTH PLANNING SERVICES Running Point provides wealth planning services to its clients. This generally includes �inancial planning, estate planning, tax planning, tax return preparation, expense management, retirement planning, risk management, insurance planning, compensation and bene�its planning and INSURANCE SERVICES philanthropy. Running Point may provide a review of your current life, disability, annuity, life settlement and/or long-term care insurance. Insurance analysis and recommendations may be facilitated through the personal, business and or estate planning process based on our client’s goals and objectives. We take an unbiased approach to search for suitable insurance to meet your needs by collaborating with other advisors, including your tax professional and/or attorney. Our goal is to provide you with a greater understanding of your insurance policies through integrated planning. Running Point conducts an analysis of your insurance policies known as an insurance performance evaluation. The performance evaluation is a client-driven process focused on examining the performance of your life insurance policy. The review will determine if your current policy is performing as expected based on original premium payments and assumed interest rates and mortality charges as provided by the insurance company. In addition, we will evaluate the market to see if there is a product that may better suit your needs. This analysis may be done at no cost to you, and you are not required to implement the recommendations through Running Point. A commission may be paid by an insurance company to Running Point or its employees if the recommendation is implemented. This �inancial incentive may create a con�lict of interest because the �irm may receive additional compensation for the placement of certain insurance products. Running Point may recommend that you purchase insurance products through our af�iliated insurance agency, for your insurance needs. This presents a con�lict of interest between Running Pint and its clients, in that we have an incentive to recommend our af�iliated entity. However, you are under no obligation to use our af�iliated insurance agency. TAX COMPLIANCE AND CONSULTING Running Point provides clients, in a separate tax engagement, income tax consultation and preparation, including individual, business, estate and trust taxation. Running Point will work in collaboration with the client and the client advisory team. Running point’s tax services are generally provided for high-net-worth individuals or families and closely held business owner clients. While general tax advice by Running Point will be provided as part of the client’s integrated �inancial planning process, tax preparation and project-based consulting will be facilitated through a separate engagement. For example, �iling a client’s 1040 federal personal return and or a request to complete a pro forma for a client’s closely held business would require a separate engagement versus calculating the estimated Federal and State Taxes on a required minimum distribution, which would be part of the advisory engagement. 15  TRUSTEE ADVISOR SERVICES Running Point’s Certi�ied Trust Advisor will work directly with trustees on behalf of trust bene�iciaries to facilitate the trust provisions in collaboration with both your estate attorney and CPA. Running Point will generally gather all pertinent trust documents, healthcare directives, durable power of attorney’s, wills, and inventory all assets of the estate, including investments, retirement plans, insurance, bank accounts, debts, real estate, social security, personal property and any other types of assets that would be included in the estate. Through the trust planning process with you as trustee and in collaboration with your estate attorney, we will assist in putting a plan in place including keeping accurate records, �iling timely tax returns and reporting to bene�iciaries as the trust requires. We also are available to provide �inancial planning services to bene�iciaries and to provide portfolio management services to the trust and its bene�iciaries. BOOKKEEPING AND BUSINESS MANAGEMENT Running Point provides clients, in a separate engagement, bookkeeping and business management services upon request. Running Point will work in collaboration with the client and the client advisory team. Business Management services include, but are not limited to, monthly household pro�it and loss statements, tax consulting, payroll coordination, estate planning, wealth management, and risk management. ACCOUNTING SERVICES Running Point may provide accounting services to clients in a separate engagement. Running Point’s goal of providing account services is to integrate tax planning and preparation with careful �inancial record keeping. Accounting services include, but are not limited to, tax preparation for corporations and partnerships, state and local tax �ilings, tax and �inancial consulting, year-end tax planning and �inancial integration, and accounting policies and procedures. PRIVATE FUND ACCOUNTING SERVICES Running Point Tax and Consulting LLC, an af�iliate of Running Point, provides accounting services to certain private funds that we recommend to our clients. None of these private funds are managed or sponsored by Running Point or its af�iliates. Running Point Tax and Consulting LLC receives fees for such accounting services from the applicable private funds and/or their sponsors. The amount of such fees does not depend on whether or not clients of Running Point invest in any of these private funds. None of these fees will be applied towards or otherwise reduce the amount of fees payable to Running Point by its clients. This arrangement represents a con�lict of interest for us because it creates an incentive for us to recommend the applicable private funds to our clients instead of recommending similar private funds that do not pay such fees to our af�iliate. Running Point seeks to mitigate this con�lict of interest by using factors other than this arrangement as the basis for recommending any particular private fund to its clients. 16  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our �irm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. The Code of Ethics includes standards of business conduct requiring covered persons to comply with the federal securities laws and the �iduciary duties an investment advisor owes to its clients. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the �irm’s access persons. Our Code of Ethics also requires the prior approval of acquisition of certain securities in order to mitigate risk of potential con�licts with client accounts. Employees are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with Running Point’s policies and procedures. Employees are required to report their personal securities transactions to the �irm or the �irm’s designee each quarter. Our Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. Running Point’s Code of Ethics further includes the �irm's policy prohibiting the use of material non-public information. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by calling or emailing Jim Schlager at 424-502-3501 or jim@runningpointcapital.com. Item 12 Brokerage Practices Clients generally are required to give Running Point discretion and authority to manage their assets. Consequently, Running Point determines which securities to buy or sell, the broker or dealer through which the securities will be bought or sold, and the commission rates at which transactions are affected. Any limitations or restrictions, with respect to the exercise of this investment discretion, will be those established by the client, in writing, at the commencement of the advisory relationship or thereafter. In selecting or recommending broker-dealers to execute portfolio transactions, we make a good faith judgment in determining which broker-dealer would be appropriate. We take into consideration not only the available prices and rates of brokerage commissions, but also other relevant factors that may include (without limitation): execution ability, clearance procedures, operational facilities, and custodial and other services provided by the broker-dealer. If an account is maintained on behalf of a plan subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) or similar government regulation, client represents that the broker designated by client is capable of providing best execution for the client’s brokerage transactions, and that the commission rates that the client negotiated are reasonable in relation to the brokerage and other services received by the applicable retirement or other bene�it plan. Client agrees that it is the client’s, not Running Point’s responsibility, to monitor the services provided by the broker designated by client to assure that the applicable retirement or other bene�it plan continues to 17 receive best execution and pay reasonable commissions. Client will represent that the use of the  broker designated by client is for the exclusive bene�it of the applicable retirement or other bene�it plan participants. Running Point may block trades where possible. Blocking of trades permits the trading of aggregate orders for a security and transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading may allow us to execute equity trades in a timely and equitable manner at an average share price. Generally, Running Point will execute all securities transactions through the client’s custodian. Running Point will typically aggregate trades of clients whose accounts can be traded at a given broker, and generally will rotate or vary the order of brokers through which it places Running Point block trading policy and procedures are as trades for clients on any particular day. follows: 1) Transactions for any client account may not be aggregated for execution if the practice is prohibited by or inconsistent with the client's advisory agreement with Running Point, or our �irm's order allocation policy. 2) The portfolio manager, in concert with the trading desk, must determine that the purchase or sale of the particular security is appropriate for the client and consistent with the investment objectives of the account, and with any applicable investment guidelines or restrictions. 3) The portfolio manager must reasonably believe that the order aggregation will bene�it, and will enable Running Point to seek, best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price. 4) Prior to entry of an aggregated order, a written or electronic order ticket must be completed which identi�ies each client account participating in the order and the proposed allocation of the order, upon completion, to those clients. 5) If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day, will be allocated pro rata among the participating client accounts in accordance with the initial order ticket or other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating client accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in accounts. 6) 18 Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions made to �ill the order and must share in the  commissions on a pro rata basis in proportion to the client's participation. Under the client’s agreement with the custodian/broker, transaction costs may be based on the number of shares traded for each client. 7) If the order will be allocated in a manner other than that stated in the initial statement of allocation, a written explanation of the change must be provided to, and approved by, the Chief Compliance Of�icer, no later than the morning following the execution of the aggregate trade. 8) Running Point client account records separately re�lect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, the account. 9) Funds and securities for aggregated orders are clearly identi�ied on Running Point records and to the broker-dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. 10) No client or account will be favored over another. On occasion, better execution may be available from other broker-dealers. We monitor equity and �ixed income trades to ensure that your account is receiving best execution. Best execution of client transactions is an obligation Running Point takes seriously and is a catalyst in the decision of using an account custodian. While quality of execution at the best price is an important determinant, best execution does not necessarily mean lowest price and it is not the sole consideration. When Running Point has discretion as to placement of transactions, it considers the following: • • • • Financial stability, reputation, willingness to commit capital and clearing and settlement capabilities. A brokerage �irm’s research and investment ideas that directly impact a client’s portfolio. Price (the amount of commission paid). All trades are negotiated to the appropriate level based on the size of the trade and its complexity to execute. The operational aspects of brokerage �irms’ back of�ice (will the client receive payment of securities on a timely basis), and custodian or other administrative service. Because of these considerations, Running Point may pay a brokerage commission in excess of that which another broker might have charged for having affected the same transaction in recognition of the value of brokerage or research services provided by the broker. RESEARCH AND OTHER SOFT DOLLAR BENEFITS Running Point does not engage in formal soft dollar arrangements with broker-dealers, and we do not receive client referrals from broker-dealers. Certain custodians or broker-dealers provide Running Point with access to their institutional trading and custody services, which are typically not available to retail investors. These services generally are available to investment advisors on an unsolicited basis, at no charge to them, so long as a certain amount of the advisor's clients' assets 19 are maintained in accounts at the custodian. These services are not contingent upon Running Point  committing to the broker-dealer any speci�ic amount of trading commissions. These services often include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a signi�icantly higher minimum initial investment. These custodians also make available, to our �irm, other products and services that bene�it Running Point, but may not directly bene�it all of our clients' accounts. Some of these products and services may be used to service all, or some substantial number, of our client accounts, including accounts In evaluating whether to recommend that clients not maintained at that particular custodian. custody their assets at a particular custodian, we may take into account the availability of some of the foregoing services and other arrangements as part of the total mix of factors we consider thus, we might not solely consider the nature, cost or quality of custody and brokerage services provided by the custodian, which may create a potential con�lict of interest. No client is obligated to use Schwab, Fidelity, nor any other speci�ic custodian. Schwab Advisor Services Running Point may recommend that clients establish brokerage accounts with the Schwab Advisor Services of Charles Schwab & Co., Inc. (Schwab), a FINRA registered broker-dealer, Member SIPC, to maintain custody of client’s assets and to effect trades for their accounts. Running Point is independently owned and operated and not af�iliated with Schwab. Schwab Advisor Services™ is Schwab’s business serving independent investment advisory �irms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we do not have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that bene�it you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a signi�icantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally bene�it you and your account. Services that may not directly bene�it you. Schwab also makes available to us other products and services that bene�it us but may not directly bene�it you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • • 20 Provides access to client account data (such as duplicate trade con�irmations and account statements) Facilitates trade execution and allocates aggregated trade orders for multiple client accounts  • • • Provides pricing and other market data Facilitates payment of our fees from our clients’ accounts Assists with back-of�ice functions, recordkeeping, and client reporting Services that generally bene�it only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • • • • Educational conferences and events Consulting on technology, compliance, legal, and business needs Publications and conferences on practice management and business succession • Access to employee bene�its providers, human capital consultants, and insurance providers Marketing consulting and support Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other bene�its, such as occasional business entertainment of our personnel. Fidelity Brokerage Services Running Point may recommend that clients establish brokerage accounts with Fidelity Brokerage Services (“Fidelity”) to maintain custody of clients’ assets and to effect trades for their accounts. Running Point is independently owned and operated and not af�iliated with Fidelity. Running Point has an arrangement with National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all af�iliates, "Fidelity") through which Fidelity provides Running Point with Fidelity's "platform" services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like Running Point in conducting business and in serving the best interests of their clients but that may bene�it Running Point. For our client accounts maintained in its custody, Fidelity does not charge separately for custody services but is compensated by account holders through brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees may be charged for certain no-load mutual funds, commissions may be charged for individual equity and debt securities transactions). Fidelity enables Running Point to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates, however, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to Running Point, at no additional charge to Running Point, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by Running Point (within speci�ied parameters). 21  Item 13 Review of Accounts PORTFOLIO MANAGEMENT REVIEWS: Client account reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s �inancial situation, or large deposits or withdrawals in the Client’s account. The Client is encouraged to notify Running Point if material changes occur in the Client’s �inancial situation that might positively or adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic, or political events. REPORTS: In addition to monthly statements provided by the Custodian, Running Point will provide clients with performance reports for accounts held at Custodians when suf�icient data is provided by the Custodian to properly calculate performance. FINANCIAL PLANNING SERVICES REVIEWS: While reviews may occur at different stages, depending on the nature and terms of the speci�ic engagement, typically no formal reviews will be conducted for Financial Planning clients, REPORTS: unless contracted. Financial Planning clients will receive a completed �inancial plan. Additional reports will not typically be provided unless contracted. Item 14 Client Referrals and Other Compensation Our �irm may pay referral fees to independent persons or �irms ("Solicitors") for introducing clients to us. Consistent with requirements under the Investment Advisers Act of 1940, as amended, Running Point enters into written agreements with Solicitors under which, among other things, Solicitors are required to disclose their compensation arrangements to prospective clients before they enter into an agreement with Running Point. Solicitors are not permitted to offer clients any investment advice on behalf of Running Point. As a matter of �irm practice, the advisory fees paid to us by clients referred by solicitors are not increased as a result of any referral. It is Running Point’s policy not to accept, or allow our related persons to accept, any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. We receive an economic bene�it from Schwab in the form of the support products and services it makes available to us and other independent investment advisers whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain amount. These products and services, how they bene�it us, and the related con�licts of interest are described above in Item 12 - Brokerage Practices. 22  Item 15 Custody We previously disclosed in the “Fees and Compensation” section (Item 5) of this Brochure that with client written authorization our �irm directly debits advisory fees from client accounts, and since a related person serves as trustee on a client account, we are deemed as having custody. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Running Point is also deemed to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and under that SLOA, authorize us to designate the amount or timing of transfers with the custodian. The SEC has set forth rules intended to protect client assets in such situations, which we follow. As a matter of policy and practice, Running Point does not permit employees or the �irm to accept or maintain custody of client assets other than as identi�ied above. Item 16 Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • • Determine the security to buy or sell; and/or Determine the amount of the security to buy or sell Clients give us discretionary authority when they execute a discretionary agreement with our �irm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by, once again, providing us with written instructions. Item 17 Voting Client Securities As part of our service offering, we or a sub-advisor will vote proxies for client accounts that we have discretionary authority over; however, clients always have the right to vote proxies themselves. Clients can exercise this right by instructing us in writing not to vote proxies on their behalf. This is addressed in the Investment Advisory Agreement. For voting proxies, Running Point will use Broadridge Financial Solutions (“Broadridge”) to ensure that voting is carried out and documented. Broadridge will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record 23  of each vote cast, a copy of any document created that was material to making a decision on how to vote proxies, and a copy of each written client request for information on how the proxy was voted. With respect to ERISA accounts, Broadridge will vote proxies unless the plan documents speci�ically reserve the plan sponsor’s right to vote proxies. Clients can instruct us to vote proxies according to particular criteria. Clients can also instruct us on how to cast their vote in a particular proxy contest. For clients who do not opt into having Broadridge �ile class action claims on their behalf (discussed below), we will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client's account(s), including, but not limited to, the �iling of "Proofs of Claim" in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. In an effort to continue to provide value-added service to you, we have engaged Broadridge to �ile class action claims on our clients’ behalf. Clients are not obligated to provide Running Point with the authority to permit Broadridge to process any claims. Charges for the processing of class action claims shall be subject to a contingency fee assessed directly by Broadridge in the event a recovery is made. The contingency fee shall be 20% of the total reimbursement of class actions settlement Broadridge collects for participating clients. Class action recoveries, including the contingency fee, shall be deposited directly by Broadridge into the account holding the shares subject to the class action. Running Point will then invoice the client for the 20% contingency fee due to Broadridge and pay Broadridge directly. Running Point does not receive any portion of the 20% contingency fee charged by Broadridge. For a complete copy of the proxy policy or guidelines and inquiries regarding how a speci�ic proxy proposal was voted, please contact Jim Schlager at 424-502-3501 or jim@runningpointcapital.com. Item 18 Financial Information Running Point has no additional �inancial circumstances to report. As an advisory �irm that maintains discretionary authority for clients’ accounts, we are also required to disclose any �inancial condition that is reasonably likely to impair our ability to meet our contractual obligations. Under no circumstances do we require or solicit payment of more than $1,200 in fees, six months or more in advance of services rendered. Therefore, we are not required to include a �inancial statement. Running Point has not been the subject of a bankruptcy petition at any time during the past ten years. 24