Overview

Assets Under Management: $395 million
Headquarters: SAN DIEGO, CA
High-Net-Worth Clients: 59
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting

Fee Structure

Primary Fee Schedule (SILVER COAST D/B/A PRACTICECFO INVESTMENTS DISCLOSURE BROCHURE AND SUPPLEMENT)

MinMaxMarginal Fee Rate
$0 $500,000 1.25%
$500,001 $1,000,000 1.00%
$1,000,001 $3,000,000 0.85%
$3,000,001 $10,000,000 0.65%
$10,000,001 $25,000,000 0.40%
$25,000,001 and above 0.30%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $11,250 1.12%
$5 million $41,250 0.82%
$10 million $73,750 0.74%
$50 million $208,750 0.42%
$100 million $358,750 0.36%

Clients

Number of High-Net-Worth Clients: 59
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 28.14
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 1,046
Discretionary Accounts: 1,046

Regulatory Filings

CRD Number: 167771
Last Filing Date: 2025-01-30 00:00:00
Website: https://www.linkedin.com/showcase/associates-on-fire

Form ADV Documents

Primary Brochure: SILVER COAST D/B/A PRACTICECFO INVESTMENTS DISCLOSURE BROCHURE AND SUPPLEMENT (2025-03-06)

View Document Text
Item 1 – Cover Page Silver Coast Investments LLC d/b/a PracticeCFO Investments Form ADV Part 2A – Disclosure Brochure Effective: March 6, 2025 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Silver Coast Investments LLC d/b/a PracticeCFO Investments (“PracticeCFO” or the “Advisor”). If you have any questions about this Disclosure Brochure's content, please get in touch with us at (800) 675-2712. PracticeCFO is a registered investment advisor with the U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or any state securities authority. Registration as an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about PracticeCFO to assist you in determining whether to retain the Advisor. Additional information about PracticeCFO and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov, where you can search for the Advisor’s firm name or CRD# 167771. Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255 San Diego, CA 92128 Phone: (800) 675-2712 Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about various topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of PracticeCFO. The Advisor has combined these documents into a single disclosure document for convenience. PracticeCFO believes that communication and transparency are the foundation of its relationship with clients and continually strives to provide you with complete and accurate information at all times. PracticeCFO encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes As of the last filing, there have been no material changes. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of PracticeCFO. You may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 167771. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (800) 675-2712. Page 2 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Item 3 – Table of Contents Contents Item 1 – Cover Page ..................................................................................................................................................... 1 Item 2 – Material Changes .............................................................................................................................................................................. 2 Item 3 – Table of Contents ............................................................................................................................................................................. 3 Item 4 – Advisory Services ............................................................................................................................................................................ 4 Item 5 – Fees and Compensation ............................................................................................................................................................... 8 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................................................... 10 Item 7 – Types of Clients .............................................................................................................................................................................. 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................... 11 Item 9 – Disciplinary Information .............................................................................................................................................................. 12 Item 10 – Other Financial Industry Activities and Affiliations .................................................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 13 Item 12 – Brokerage Practices ................................................................................................................................................................... 13 Item 13 – Review of Accounts .................................................................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ....................................................................................................................... 15 Item 15 – Custody ............................................................................................................................................................................................ 15 Item 16 – Investment Discretion ................................................................................................................................................................ 16 Item 17 – Voting Client Securities ............................................................................................................................................................ 16 Item 18 – Financial Information ................................................................................................................................................................. 16 Privacy Policy .................................................................................................................................................................................................... 17 Page 3 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Item 4 – Advisory Services A. Firm Information Silver Coast Investments LLC d/b/a PracticeCFO Investments (“PracticeCFO” or the “Advisor”) is a registered investment advisor located with the U.S. Securities and Exchange Commission. The Advisor is organized as a limited liability company (“LLC”) under the laws of California and is a wholly-owned subsidiary of PracticeCFO LLP, which Wesley W. Read, CFP®, CPA, beneficially owns. PracticeCFO was founded in April 2013 and is operated by President Wesley W. Read, CFP®, CPA, and Chief Investment Officer and Chief Compliance Officer Brandon W. Hobson, CFA®, CPA. This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services offered by PracticeCFO. B. Advisory Services Offered PracticeCFO offers various advisory services to individuals, high-net-worth individuals, pension and profit- sharing plans, charitable organizations, trusts, estates, retirement plans, endowments, and corporate accounts (each referred to as a “Client”). Advisory services include strategic personal and business financial planning, investment management, tax and accounting services, and insurance planning. The Advisor is a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith toward each Client and seeks to mitigate potential conflicts of interest. PracticeCFO’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Financial Planning Services PracticeCFO will typically provide financial planning services to individuals, families, and business Clients under a written Financial Planning Agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including, but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. Generally, PracticeCFO initiates its services by completing a high-level but comprehensive review of their personal and business financial conditions and goals. Once complete, the delivered plan provides the context for the Advisor’s other wealth management services. This process begins by establishing and defining the terms of the relationship between PracticeCFO and the Client. Once the relationship is defined and agreed upon, PracticeCFO will collect and assemble relevant financial planning documents and goal information, including assets, liabilities, income, expenses, insurance policies, estate documentation, and other appropriate information. PracticeCFO will then analyze the information to offer a written set of recommendations that can increase the likelihood of achieving their financial goals if implemented by the Client. The Client will have the option to accept, reject, or modify the information. The effectiveness of the personal financial plan (the “Plan”) will depend mainly on the amount and accuracy of information provided to PracticeCFO by the Client. Because the projections used in the Plan and the accompanying results are calculated over many years, small changes can create significant differences in future results. Consequently, the Plan will not convey any assurance on those projections' achievability or the underlying results' reasonableness. In addition, the Plan does not provide any legal advice. Before making decisions with legal ramifications, Clients should consult appropriate professionals for advice specific to their situation. Any investment recommendations developed from the personal financial plan should be implemented by a licensed investment professional. PracticeCFO does not take any responsibility for the outcome of any specific investment strategy[ies] recommended by other advisors. If the Client wishes to engage PracticeCFO to implement the investment recommendations, PracticeCFO may offer to provide such services under a separate agreement. Financial planning recommendations pose a conflict between the interests of the Advisor and the Page 4 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations the Advisor makes or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Investment Management Services PracticeCFO provides discretionary investment management services for its Clients. Each engagement commences with a review of the Client’s investment goals and objectives, risk tolerance, and financial situation to create a portfolio strategy. PracticeCFO will then construct a portfolio primarily of exchanged traded funds (“ETFs”) to achieve the Client’s investment goals. PracticeCFO may also utilize mutual funds, individual securities, or other types of securities to meet the needs of its Clients. PracticeCFO’s investment approach is primarily focused on the long term. Still, the Advisor may buy, sell, or re- allocate positions held for less than one year to meet the Client's objectives or due to market conditions. PracticeCFO will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the Advisor's acceptance. We use a hybrid investment management approach that combines passive asset management with tactical asset allocation. Low-cost, passive exchange-traded funds (ETFs) form the core of our portfolios, and tactical asset allocation may be used to capitalize on market opportunities. PracticeCFO follows a four-step process to define and monitor Client investment objectives. STEP 1: Understanding the Client. To begin, the Advisor always starts by developing a Client-specific financial profile. This profile consists of: 1. Client’s goals—Generally, this information is obtained through the Advisor’s financial planning service. If this service is not selected, PracticeCFO will collect baseline information on the money's purpose and timing. 2. Client’s financial capacity for risk—PracticeCFO collects information on the Client’s financial condition, which, coupled with their financial goals, helps determine what level of risk is necessary for the Client to meet their established goals. 3. Client’s emotional capacity for risk—We analyze their emotional and psychological tolerance for market and portfolio volatility. This information is gathered through various questionnaires, including one on the Client’s financial goals, circumstances, and feelings toward investment risk. Throughout this process, PracticeCFO will assess the client's understanding of financial and investment concepts, such as market returns, different types of investment products, market volatility, and inflation. This information provides the context for PracticeCFO to define an appropriate investment objective for the assets the Advisor manages for the Client. STEP 2: Develop an Investment Policy Statement. Once sufficient information about the Client is gathered to develop an investment objective, PracticeCFO formalizes a plan to deploy the investments consistent with that objective. This plan includes: 1. A target allocation between equity, fixed income, and cash. This is the Client’s strategic asset allocation. 2. A target allocation between asset classes within the investment portfolio's equity and fixed income 3. portions. This is the Client’s tactical allocation. Identify the investment managers used within each asset class. Review existing investment holdings, their embedded taxes, restrictions, and redemption fees. 4. The development of specific steps to manage concentrated positions, illiquid investments, stock options, Page 5 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page and restricted stock. 5. Timing guidelines for moving their investment assets into the market if they are current in cash. 6. The preparation of a cash distribution plan (if the Client is relying on investment assets for spending needs) 7. The preparation of rebalancing guidelines. This information, collectively, is assembled into a document, as a matter of best practices, the Investment Policy Statement (“IPS”). This document and other potential analyses the Advisor provides may include specific investment projections. These projections are intended strictly for the use of PracticeCFO. PracticeCFO does not offer any level of assurance of these projections. PracticeCFO believes that markets and investment performance cannot be predicted in the short run and may not repeat itself in the long run. Although the Advisor believes capital markets will continue to offer returns over time to capital investors, PracticeCFO expresses no assurance for their investment assets. In other words, past performance is not a predictor of future performance. However, PracticeCFO strongly believes that the Advisor’s portfolios are structured to offer Clients a share in broad market returns according to their exposure to those markets. That level of exposure is Client-specific and is documented in the IPS. STEP 3: Execute the Investment Policy Statement. After the IPS is complete, PracticeCFO executes the policy instructions by selling all securities that are not consistent with the Advisor’s target portfolio and using the proceeds to purchase those securities that are. The timing of this transition may be phased according to security restrictions, Client preferences, and tax constraints. Once executed, the Client will be notified and provided a report illustrating that the investment portfolio is consistent with the target design. STEP 4: Monitor the Investment Portfolio. PracticeCFO does not attempt to time the market cycles. Please see Item 8 - Methods of Analysis. Instead, PracticeCFO designs a portfolio that maintains its current strategic allocation and adjusts for two reasons only: 1. Shift the portfolio back to its target allocation after market changes have altered it. 2. Reconfigure the portfolio to a new strategic allocation motivated by changes to a Client’s circumstances. Such changes will be documented in an updated IPS. Monitoring the investment portfolio produces more significant discipline in the PracticeCFO investment process. It removes many behaviorally motivated investment decisions that often erode long-term investment returns. However, PracticeCFO will not, at any time, restrict Clients from making the investment decision they ultimately wish to make. Any decisions made by Clients that are inconsistent with the PracticeCFO recommendations will be documented and saved in the Advisor’s archives. Suppose the client's decisions are inconsistent with the goals agreed upon or make it impossible to carry out the investment plan outlined in the Investment Policy Statement. In that case, PracticeCFO will revisit the advisory relationship. PracticeCFO Advisory Persons will meet with Clients periodically to review the portfolio holdings and performance. These meetings may be scheduled annually, semi-annually, or, if necessary, quarterly. If the Client has also obtained a personal financial plan, from time to time, PracticeCFO will review the investment portfolio in conjunction with the financial plan. Doing so allows PracticeCFO to compare the portfolio returns to those projected in the financial plan and assists in the Advisor’s ongoing financial planning reviews and updates. Lastly, Clients will receive periodic reports, electronically or on paper, on the portfolio holdings, gains, losses, fees, trading costs, and investment performance. We will also generally coordinate with their tax accountant to reduce taxes where permitted. PracticeCFO only evaluates and selects investments for inclusion in Client portfolios after applying its internal due diligence process. PracticeCFO may recommend, on occasion, redistributing investment allocations to diversify the portfolio. PracticeCFO may recommend specific positions to increase sector or asset class weightings. PracticeCFO may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating Page 6 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page cash to meet the Client's needs or any risk deemed unacceptable for the Client’s risk tolerance. At no time will PracticeCFO accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian under the Client investment management agreement. Please see Item 12 – Brokerage Practices. Insurance Planning Services PracticeCFO may offer non-variable life insurance placement services for Clients as necessary. This service will only occur if deemed appropriate based on the Advisor’s review of the Client’s financial circumstances. Generally, insurance products are only recommended and placed after a financial plan has been completed and a full review of the Client’s risk of loss has occurred. If placed, a life insurance policy will result in a commission paid to an Advisory Person in their separate capacity as an insurance agent executing the transaction. Clients are under no obligation to implement any recommendations made by the Advisor. Please see Item 10 – Other Financial Industry Affiliations and Activities. Retirement Plan Advisory Services PracticeCFO provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: • Plan Participant Enrollment and Education Tracking • Investment Policy Statement (“IPS”) Design and Monitoring • Investment Due Diligence • Investment Management Services (ERISA 3(38)) • Ongoing Investment Recommendation and Assistance These services are provided by PracticeCFO, serving as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of PracticeCFO’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Before engaging PracticeCFO to provide investment advisory services, each Client must enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Policy Statement—PracticeCFO will develop a strategy for the Client, in consultation with the client, to achieve the Client’s objectives. • Asset Allocation—PracticeCFO will develop a strategic asset allocation tailored to each client's investment objectives, time horizon, financial situation, and risk tolerance. • Portfolio Construction—PracticeCFO will develop a portfolio for the Client intended to meet the client's stated goals and objectives. • Investment Management and Supervision—PracticeCFO will continuously manage and oversee the Client’s investment portfolio. D. Wrap Fee Programs PracticeCFO does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by PracticeCFO. E. Assets Under Management As of December 31, 2024, PracticeCFO managed $332,054,543 in Client assets on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Page 7 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for investment management services provided by the Advisor. Each Client shall sign one or more agreements that detail the responsibilities of PracticeCFO and the Client. A. Fees for Advisory Services Investment Management Services Investment management fees are paid quarterly, at the end of each calendar quarter, under the terms of the investment management agreement. Investment management fees are based on the average daily market value of assets under management during the quarter. Specific legacy Clients may be charged before the quarter under a separate fee schedule. Investment management fees are calculated on a graduated basis, where the first tier is charged at one rate while assets managed in higher tiers are charged at a lower rate. Investment management fees are based on the following schedule: Assets Under Management First $500,000 Next $500,000 Next $2,000,000 Next $7,000,000 Next $15,000,000 Above $25,000,000 Annual Rate (%) up to 1.25% Up to 1.00% up to 0.85% up to 0.65% up to 0.40% up to 0.30% The investment management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will consider the aggregate assets under management with the Advisor. PracticeCFO may also offer a lower fee schedule to institutional accounts. The Custodian will independently value all securities held in accounts managed by PracticeCFO. PracticeCFO will not have the authority or responsibility to value portfolio securities. The Advisor’s fee is exclusive of, in addition to, any applicable securities transaction and custody fees and other related costs and expenses described in Item 5. C, which the Client may incur. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services PracticeCFO offers financial planning services on a fixed fee basis, ranging from $500 to $5,000, depending on the services' scope, complexity, and duration. The Client will be provided with an estimate of the costs before engaging in these services. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.25%. Fees may be negotiable depending on the size and complexity of the Plan. Specific existing Clients may have fee schedules that differ from the schedule below. Fees ranges are generally based on the following schedules: Participant-Directed Plans: Fees are paid quarterly in arrears, based on the quarter-end balance of assets under management. Assets Under Management First $1,000,000 Next $2,000,000 Next to $7,000,000 Next to $15,000,000 Above to $25,000,000 Annual Rate up to 1.00% up to 0.85% up to 0.65% up to 0.40% up to 0.30% Page 8 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Pooled Plans: Fees are paid quarterly in arrears, based on the average daily market value of assets under management during the quarter. Assets Under Management First $500,000 Next $500,000 Next $2,000,000 Next $7,000,000 Next $15,000,000 Above $25,000,000 Annual Rate (%) up to 1.25% Up to 1.00% up to 0.85% up to 0.65% up to 0.40% up to 0.30% The Advisor’s fee is exclusive of and in addition to brokerage fees, transaction fees, and other related costs and expenses that the Client may incur. However, the Advisor shall not receive any portion of these commissions, fees, and expenses. The hourly fees are determined after considering many factors, such as the level and scope of the services. B. Fee Billing Investment Management Services Fees will be calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. At the Client's request (and acceptance by the Advisor), fees may be invoiced to the Client. The Advisor or its delegate shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter-end date. The amount due is calculated by applying the average daily balance (the sum of the daily AUM balance of the billing period divided by the number of days in the billing period) multiplied by the annual rate and the billing period factor (number of days in the billing quarter divided by the total number of days in a year (365)) at the end of each quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the advisory fee. The Client is responsible for verifying the accuracy of these fees as listed on the custodian’s brokerage statement, as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by PracticeCFO to be paid directly from their accounts held by the Custodian as part of the investment management agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees are invoiced and due upon completion of the agreed-upon deliverable[s]. Retirement Plan Advisory Services Depending on the terms of the retirement plan advisory agreement, retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the plan's assets. C. Other Fees and Expenses Clients may incur fees or charges imposed by third parties other than PracticeCFO in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all securities and custody fees the Custodian charges if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other investments. The fees charged by PracticeCFO are separate and distinct from these custody and execution fees. In addition, all fees paid to PracticeCFO for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and costs are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of PracticeCFO, but would not receive the services provided by PracticeCFO, which are designed, among other things, to assist the Client in determining which products or services are most appropriate to each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees Page 9 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page charged by PracticeCFO to fully understand the total fees to be paid. Please see Item 12 – Brokerage Practices. D. Payment of Fees and Termination Investment Management and Retirement Plan Services PracticeCFO is compensated for its services at the end of the quarter in which services are rendered. Either party may terminate the investment management agreement with PracticeCFO at any time by providing advance written notice to the other party. The Client may terminate the contract within five (5) business days of signing the Advisor’s investment management agreement at no cost to the Client. After the five days, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. The Client shall be responsible for costs up to and including the effective termination date. Upon termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination to the end of the quarter. The Client’s agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services PracticeCFO is compensated for its financial planning services upon completing the engagement deliverable[s]. Either party may terminate a planning agreement by providing written notice to the other party. The Client may also terminate the agreement within five (5) business days of signing the Advisor’s financial planning agreement at no cost to the Client. After the five days, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or, in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor at the agreed-upon hourly rate. The Client’s investment management agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Either party may terminate the retirement plan advisory agreement with PracticeCFO in whole or part by providing advance written notice to the other party. Either party may terminate the retirement plan advisory agreement at any time by providing advance written notice to the other party. The Client may also terminate the agreement within five (5) business days of signing the Advisor’s retirement plan advisor agreement at no cost to the Client. After the five days, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective termination date to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities PracticeCFO does not buy or sell securities or receive compensation for securities transactions in any Client account other than the investment management fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management PracticeCFO does not charge performance-based fees for its investment advisory services. The fees charged by PracticeCFO are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. PracticeCFO does not manage proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients PracticeCFO offers investment advisory services to individuals, high-net-worth individuals, pension and profit- sharing plans, charitable organizations, trusts, estates, retirement plans, endowments, and corporate accounts. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. PracticeCFO generally does not impose a minimum size for establishing a relationship. Page 10 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis PracticeCFO’s objective is to rely on the body of academic research dating back to the 1950s, which is known as Modern Portfolio Theory (“MPT”). MPT tries to maximize returns and minimize risk by carefully assembling a portfolio of assets with differing economic characteristics. Each set of similar assets (an “asset class”) has its own risk and return profile, where risk is defined as the amount of volatility in the investment, also known as Standard Deviation. By combining different asset classes whose returns are not correlated, MPT seeks to reduce the total variance of the portfolio while still providing a competitive weighted average return. PracticeCFO deploys this investment theory primarily using ETFs. In doing so, it avoids stock picking and timing and instead relies on capital market growth to generate portfolio returns. Once PracticeCFO is comfortable that a Client’s portfolio is broadly allocated to capital markets, the Advisor turns to reducing costs and taxes. PracticeCFO reduces costs by selecting investment options that meet the MPT screening requirements and have very low fund internal expenses. PracticeCFO also selects funds with very low turnover to minimize trading costs within the funds. PracticeCFO seeks to reduce taxes by (1) tracking all fund-embedded taxes and tax ratios and (2) by advantageously placing investments between taxable, tax-deferred, and tax-free accounts where a Client has such accounts. PracticeCFO then follows a buy-and-hold strategy, making portfolio changes primarily to: 1. Shift the portfolio back to its target allocation after market changes have altered it. 2. Reconfigure the portfolio to a new strategic allocation motivated by changes to a Client’s circumstances. Such changes will be documented in an updated IPS. As noted above, PracticeCFO generally employs a long-term investment strategy for its clients consistent with their financial goals. PracticeCFO will typically hold all or a portion of a security for more than a year but may hold for shorter periods to rebalance a portfolio or meet clients' cash needs. PracticeCFO may also buy and sell more short-term positions depending on the client's goals and/or the fundamentals of security, sector, or asset class. B. Risk of Loss Investing in securities involves certain risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. PracticeCFO will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, Clients are not guaranteed to meet their investment goals. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the analyzed entity's overall strength and financial viability. Assets are deemed suitable if they meet specific criteria to suggest that they are a substantial investment with a value discounted by the market. While this type of analysis helps the Advisor evaluate a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included in Item 13. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for analyzing a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. The Client is responsible for informing the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. Page 11 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page The risks associated with a particular strategy are provided to each Client before investing in Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets and economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of an ETF is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based on market movements and may dissociate from the index being tracked by the ETF or the cost of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the ETF bought or sold a short time later. Mutual Fund Risks A mutual fund's performance is subject to market risk, including the possible loss of principal. The price of mutual funds fluctuates with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily, so a mutual fund purchased at one point in the day will normally have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving PracticeCFO or any of its management persons. PracticeCFO values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or by CRD# 167771. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliations Mr. Read is also a licensed insurance professional. Implementations of insurance recommendations are separate from and separate from Mr. Reads’ role as PracticeCFO. As an insurance professional, Mr. Read will receive customary commissions and related revenues from the various insurance companies whose products are sold. Mr. Read is not required to recommend the products of any insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain insurance companies' products. Clients are not obligated to implement any recommendations from the Advisor or Mr. Read. Accounting Services Mr. Read, in a separate capacity, is the President of PracticeCFO LLP d/b/a PracticeCFO (“PracticeCFO”), a tax and accounting firm. Clients of PracticeCFO Investments may be offered tax and accounting services under a separate agreement with PracticeCFO. Clients are under no obligation to engage Mr. Read or PracticeCFO. Mr. Read spends approximately half of his time working with Clients on tax and accounting matters. Mr. Read does not have signatory authority over any Client accounts or accounts serviced in his separate capacity with PracticeCFO. Clients are advised that PracticeCFO receives additional compensation for accounting and tax. Page 12 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Services pose a potential conflict of interest. Clients are not obligated to engage Mr. Read or the accounting firm to obtain investment advisory services from PracticeCFO. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics PracticeCFO has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with PracticeCFO (“Supervised Persons”). The Code was developed to provide general ethical guidelines and instructions regarding the Advisor’s duties to the Client. PracticeCFO and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of PracticeCFO associates to adhere not only to the specific provisions of the Code but also to the general principles that guide it. The Code covers various topics that address ethics and conflicts of interest. To request a copy of the Code, please get in touch with the Advisor at (800) 675-2712. B. Personal Trading with Material Interest PracticeCFO allows Supervised Persons to purchase or sell the same securities that may be recommended to them and purchased on behalf of Clients. PracticeCFO does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. PracticeCFO has no material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients PracticeCFO allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code, which addresses insider trading (material non-public information controls), gift and entertainment, outside business activities, and personal securities reporting procedures. Supervised Persons have a conflict of interest when trading for personal accounts if they are trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades or by trading based on material non-public information. This risk is mitigated by PracticeCFO requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While PracticeCFO allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will PracticeCFO or any Supervised Person of PracticeCFO transact in any security to the detriment of any Client. Notice for California residents. PracticeCFO has disclosed all material conflicts of interest that could affect the judgment or ability to provide unbiased advice by the Advisor or its IARs under CCR Section 260.238(k). Item 12 – Brokerage Practices A. Recommendation of Custodian[s] PracticeCFO does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize PracticeCFO to direct trades to the Custodian as agreed in the investment management agreement. Further, PracticeCFO does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where PracticeCFO does not exercise discretion over the selection of the Custodian, it may recommend the Page 13 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a Custodian not recommended by PracticeCFO. However, the Advisor may be limited in its services if the recommended Custodian is not engaged. PracticeCFO may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the Custodian’s offices. PracticeCFO will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member of SIPC. Schwab will serve as the Client’s “qualified custodian.” PracticeCFO maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. The following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians. An advisor agrees to place security trades with a broker-dealer/custodian in exchange for research and other services. PracticeCFO does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor does receive certain economic benefits from Schwab. Please see Item 14 below. 2. Brokerage Referrals—PracticeCFO does not receive compensation from any third party regarding a recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis,” where PracticeCFO will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). PracticeCFO will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. The Custodian determines these costs. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results, considering such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. PracticeCFO will execute its transactions through the Custodian as directed by the Client. PracticeCFO may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts on the same trading day. If a block trade cannot be executed in full at the same price or time, the securities purchased or sold by the close of each business day must be allocated in a manner consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any Client’s accounts. Item 13 – Review of Accounts A. Frequency of Reviews Mr. Hobson, CCO of PracticeCFO, monitors securities in client accounts regularly and continuously. Formal reviews are generally conducted at least annually or more or less frequently, depending on the client's needs. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed because of significant changes in economic conditions, known changes in the Client’s financial situation, and/or Page 14 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify PracticeCFO if changes in their financial situation might adversely affect their investment plan. Material market, economic, or political events may trigger additional reviews. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by PracticeCFO PracticeCFO may refer Clients to various third parties to provide specific financial services necessary to meet its Clients' goals. Likewise, PracticeCFO may receive referrals of new Clients from a third-party. Participation in the Institutional Advisor Platform PracticeCFO has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like PracticeCFO. As a registered investment advisor participating on the Schwab Advisor Services platform, PracticeCFO receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor, and many, but not all, services provided by Schwab will benefit Clients. In fulfilling their duties to their Clients, the Advisor always endeavors to put their interest first. Clients should be aware, however, that receiving economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client—Schwab’s institutional brokerage includes access to a broad range of investment products, execution of securities transactions, and custody of the Client’s funds and securities. Through Schwab, the Advisor may access certain investments and asset classes that the Client could not obtain directly or through other sources. Further, the Advisor may be able to invest in mutual funds and other investments without adhering to the investment minimums required if the Client were to access the investments directly. Services that May Indirectly Benefit the Client—Schwab provides participating advisors access to technology, research, discounts, and other services. In addition, the Advisor receives duplicate statements for Client accounts and can deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to PracticeCFO that may not benefit the Client, including educational conferences and events, financial start-up support, consulting services, and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. PracticeCFO believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Client Referrals from Solicitors PracticeCFO does not engage paid solicitors for Client referrals. Item 15 – Custody Neither PracticeCFO nor the investment adviser representatives will accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. Investment Adviser Representatives do not have signatory authority over any Client accounts or accounts serviced in their separate capacity by the Page 15 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Accounting firm. All Clients must place their assets with a “qualified custodian.” Clients must engage the Custodian to retain their funds and securities and direct PracticeCFO to utilize the Custodian for the Client’s security transactions. PracticeCFO encourages Clients to review statements provided by the account custodian. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another, the Advisor may have custody of those assets. To avoid additional regulatory requirements in these cases, the Custodian and the Advisor has adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion PracticeCFO generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by PracticeCFO. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment management agreement containing all applicable limitations to such authority. All discretionary trades made by PracticeCFO will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities PracticeCFO does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies. However, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither PracticeCFO nor its management has any adverse financial situations that would reasonably impair the ability of PracticeCFO to meet all obligations to its Clients. Neither PracticeCFO nor its Advisory Persons has been subject to bankruptcy or financial compromise. PracticeCFO is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1200 or more for services to be performed for six months or more in the future. Page 16 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Privacy Policy Effective: March 6, 2025 Our Commitment to You Silver Coast Investments LLC d/b/a PracticeCFO Investments (“PracticeCFO” or the “Advisor”) is committed to safeguarding the use of your personal information, which we have as your investment advisor. PracticeCFO (also referred to as "we," "our," and "us" throughout this notice) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Our relationship with you is our most important asset. We understand that you entrusted us with your private information, and we do everything possible to maintain that trust. PracticeCFO does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and proper business purposes in connection with the servicing and management of our relationship with you, as discussed below. This Privacy Policy details our approach to privacy and how your personal non-public information is collected and used. Why do you need to know? Registered Investment Advisors (“RIAs”) share some of your personal information. Federal and State laws give you the right to limit some of this sharing. Federal and State laws require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What sources do we collect information from in addition to you? Custody, brokerage, and advisory agreements Account applications and forms Other advisory agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service the account How do we share your information? RIAs need to share personal information regarding their clients to implement the RIA’s services effectively. The section below lists some reasons we may share your personal information. Page 17 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Basis for sharing Sharing Limitations Servicing our Clients We may share non-public personal information with non- affiliated third parties (such as brokers, custodians, regulators, credit agencies, and other financial institutions) as necessary for us to provide agreed services to you consistent with applicable law, including but not limited to: PracticeCFO may share this information. Clients cannot limit the Advisor’s ability to share. • Processing transactions; • General account maintenance; • Responding to regulators or legal investigations; and • Credit reporting, etc. PracticeCFO may share this information. Clients cannot limit the Advisor’s ability to share. Administrators We may disclose your non-public personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to perform the requested service. PracticeCFO does not share personal information. Clients cannot limit the Advisor’s ability to share. Marketing Purposes PracticeCFO does not disclose and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Specific laws may give us the right to share your personal information with financial institutions where you are a customer and where PracticeCFO or the client has a formal agreement with the financial institution. We will only share information to service your accounts, not for marketing purposes. PracticeCFO does share personal information. Clients can limit the Advisor’s ability to share. Authorized Users In addition, your non-public personal information may also be disclosed to you and persons we believe to be your authorized agent[s] or representative[s]. Clients can limit the Advisor’s ability to share. PracticeCFO does not share personal information regarding former clients. Information About Former Clients PracticeCFO does not disclose, and does not intend to disclose, non-public personal information to non-affiliated third parties concerning persons who are no longer our clients. How do we protect your information? We maintain physical, procedural, and electronic safeguards to protect your personal information from unauthorized access and use. These include computer safeguards such as passwords and secured files and buildings. Our employees are advised about PracticeCFO's need to respect the confidentiality of each client’s non-public personal information. We train our employees on their responsibilities. We require third parties that assist in providing our services to you to protect the personal information they receive. This includes contractual language in our third-party agreements. Page 18 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com Item 1 – Cover Page Changes to our Privacy Policy. We will notify you annually of our Privacy Policy if you maintain an ongoing relationship with us. Periodically, we may revise our Privacy Policy and provide you with a revised one if the changes materially alter the previous Policy. However, We will not modify our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we notify you and provide you with an opportunity to prevent the information sharing. Questions: You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (800) 675-2712 Page 19 Silver Coast Investments LLC d/b/a PracticeCFO Investments 13400 Sabre Springs Parkway Suite 255, San Diego, CA 92128 Phone: (800) 675-2712 * Fax: (858) 477-8101 www.practicecfo.com