UNCONVENTIONAL INVESTOR, LLC

PART 2A ITEM 1: COVER SHEET Unconventional Investor, LLC P.O. Box 1119 Portsmouth, NH 03802 (415) 235-3729 paul@unconventionalinvestor.com www.unconventionalinvestor.com January 21, 2025 This brochure provides information about the qualifications and business practices of Unconventional Investor, LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number and/or e-mail address above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Our e-mail for regulatory compliance is uicompliance2@gmail.com. Unconventional Investor, LLC is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. The verbal and written communications of an investment adviser provide you with information you need to determine whether to hire or retain the advisor. Additional information about Unconventional Investor, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The Firm’s CRD number is 317333.  PART 2A ITEM 2: MATERIAL CHANGES Unconventional Investor, LLC Our previous annual update was dated March 3, 2024. Following is a summary of the material changes made to Part 2 since that submission. Item 4: As of December 31, 2024, we manage assets of $267.4 million on a discretionary basis. Item 5: Added disclosure related to the option to have Unconventional Investor direct debit advisory fees. Item 12: We are in the process of moving all client assets to Schwab and require that all new accounts be opened with Schwab as custodian. Item 15: If you give us authority to deduct our fees from your account, we have custody of those assets. In order to avoid additional regulatory requirements in these cases, we follow the procedures outlined in Item 5. You will also receive quarterly statements directly from custodian of the account that details all transactions in the account. We do not maintain physical custody of any client assets. Please contact us at (415) 235-3729 or paul@unconventionalinvestor.com if you would like a copy of our updated Part 2. Additional information about us is also available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 3 TABLE OF CONTENTS Item 1: Cover Sheet Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business...................................................................................................................... 1 Who we are ......................................................................................................................................... 1 Services we offer ................................................................................................................................. 1 Assets under management.................................................................................................................... 2 Item 5: Fees and Compensation .............................................................................................................. 2 Portfolio Evaluation/Financial Planning............................................................................................... 2 Ongoing Portfolio Management ........................................................................................................... 2 Other Costs Involved ........................................................................................................................... 3 Item 6: Performance-Based Fees and Side-By-Side Management............................................................ 3 Item 7: Types of Clients ......................................................................................................................... 3 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 3 Item 9: Disciplinary Information............................................................................................................. 4 Item 10: Other Financial Industry Activities and Affiliations .................................................................. 4 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading................ 4 Code of Ethics ..................................................................................................................................... 4 Personal Trading for Associated Persons.............................................................................................. 4 Item 12: Brokerage Practices .................................................................................................................. 5 Selection of Brokers ............................................................................................................................ 5 How We Select Brokers/Custodians to Recommend............................................................................. 5 Your Brokerage and Custody Costs ..................................................................................................... 5 Products and Services Available to Us From Schwab........................................................................... 6 Aggregation of Orders ......................................................................................................................... 7 Soft Dollars ......................................................................................................................................... 7 Item 13: Review of Accounts.................................................................................................................. 7 Item 14: Client Referrals and Other Compensation ................................................................................. 8 Item 15: Custody .................................................................................................................................... 8 Item 16: Investment Discretion............................................................................................................... 8 Item 17: Voting Client Securities............................................................................................................ 8 Item 18: Financial Information ............................................................................................................... 8  ITEM 4: ADVISORY BUSINESS Who we are Unconventional Investor, LLC (referred to as “we,” “our,” “us,” or “Unconventional Investor”), submitted a succession filing in February 2022 to take over the business of its predecessor entity. This entity, also named Unconventional Investor, LLC was also wholly owned by Paul O'Leary and had been registered as an investment advisory firm since May 2007. Our principal officer is Paul P. O’Leary, Managing Member. Services we offer Unconventional Investor believes that asset allocation is the single biggest factor in investment return, and we design portfolios of quality asset classes offering well-understood long-term economics. For securities, we use low-cost index funds to target each asset class. We offer the following services: Portfolio Evaluation/Financial Planning At the commencement of a client relationship (and every 2-4 years thereafter, as circumstances evolve) we perform an evaluation of the client’s existing portfolio, as well as a forward-looking financial plan that incorporates their major financial goals, such as retirement, college, etc. The portfolio evaluation looks at the following areas: 1. asset allocation – look at underlying investments, including funds of funds, etc; look for overlap in asset classes; look at stocks/bonds; US/Europe/Asia/emerging markets; 2. fees/expenses; including funds of funds where fees can be disguised. 3. tax exposure (built in gains in non-tax sheltered investments) The financial plan is a basic spending capacity plan with investments, social security, pensions, inheritances, etc. Clients may impose restrictions on investing in certain securities or types of securities. However, due to the index allocation nature of the strategy, this isn't really relevant, nor has it arisen in our existing client base. Ongoing Portfolio Management For those who become clients and adopt our portfolio recommendations, Unconventional Investor may provide the following services, depending upon market conditions and their particular circumstances: 1. Initial portfolio recommendation and installation: a. Develop a target asset allocation based upon the individual’s risk tolerance and goals. b. Develop a tax-efficient way to reach the target allocation c. Consider stepping into the portfolio if a majority of the current portfolio is in cash. 2. Significant cash events, in or out a. A meaningful cash event is a good opportunity to review the portfolio and Page 1  b. determine the best way to invest inbound funds (inheritance, rollover, big bonus) or to the best place to generate funds needed for some purpose (down payment, other cash obligations) 3. Reallocation / Rebalance: As circumstances change or simply as time goes on, the target allocation may need to be adjusted or simply to bring the portfolio back towards target allocation. Whenever possible, try rebalancing through directing new investments, or in retirement accounts or consider a simple buy and hold approach. Clients may impost restrictions on investing in certain securities or types of securities. However, due to the index allocation nature of the strategy, this isn't really relevant, nor has it arisen in our existing client base. Assets under management As of December 31, 2024, we manage assets of $267.4 million on a discretionary basis. We do not manage assets on a non-discretionary basis. ITEM 5: FEES AND COMPENSATION Portfolio Evaluation/Financial Planning For these services, we receive an hourly fee of $250. An invoice will be presented upon completion of the services. You may terminate this service at any time by providing written notice. Upon termination, an invoice will be prepared for the time spent. Portfolio Evaluation/Financial Planning fees are waived for clients who also engage us for ongoing portfolio management. Ongoing Portfolio Management Fees for ongoing monitoring services are calculated as a percentage of assets under management. These fees are billed at the end of the quarter, based on the assets under management as of the last day of the calendar quarter. Our standard fee schedule is: Assets under Management Annual Fee On the first $500,000 Amounts over $500,000 0.40% 0.20% This fee may be negotiable in limited circumstances, such as a client placing a very large portfolio with us. Financial planning services are included in the above services. Payment for all services is due by check or ACH. You may end our ongoing monitoring services by providing written notice. We will prorate the advisory fees earned through the termination date and send you an invoice for the advisory fees due. Clients have the option to provide Unconventional Investor authorization to deduct advisory fees directly from the client’s investment account. Following are important disclosures about the deduction of management fees:  You must provide authorization for us to deduct fees when signing our client agreement. Page 2   You will receive a statement from your custodian which shows all transactions in your account, including the deduction of our fee.  You are responsible for reviewing the accuracy of the fees being billed, as the custodian will not do so. You may elect to pay by check or ACH rather than having payment deducted directly from your account. Other Costs Involved In addition to our advisory fee shown above, you are responsible for paying fees associated with investing for your account. These fees include:  management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF or mutual fund and are a portion of the expenses of the ETF or mutual fund.  brokerage costs and transaction fees for any securities or fixed income trades. These are generally charged by your custodian and/or executing broker. Additional information about brokerage costs and services is provided in “Item 12: Brokerage Practices.” We believe the fees mentioned above are competitive; however you may be able to obtain similar services from other sources at a lower price. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not receive performance fees for managing accounts. ITEM 7: TYPES OF CLIENTS Our clients are typically individuals. Generally we require that ongoing monitoring clients maintain $250,000 under management with us. However, we may waive that minimum at our sole discretion. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS We use a strategy (originally developed by David Swensen of Yale University) advocating simple portfolio construction using equity index funds and US Treasury bonds / TIPS for bonds, plus cash. Unconventional Investor clients own the same basic securities, with the individual proportions reflecting their unique circumstance and risk profile. This "mass-customization" is the foundation of our low cost approach to managing investments. The main investment risk clients face is market risk, resulting from the broad index securities we use. The market indexes we track are the US stock market, the US REITs and US utilities and and international stock markets indexes. For fixed income, we prefer US Treasury bonds, since they lack credit risk and are exposed mainly to interest rates and inflation. We use mutual funds and exchange traded funds (ETFs) targeting specific equity index classes as well as certain bond mutual funds/ETFs and individual Treasury bonds. These low-cost securities, along with an infrequent trading philosophy, mean that the primary risk an investor takes is market risk. Market timing and security selection (aka stock picking) are less important, due to the approach of being fully invested (not timing the market). Page 3  Certainly all investments involve different degrees of risk. You should be aware of your risk tolerance level and financial situations at all times. We cannot guarantee the successful performance of an investment and we are expressly prohibited from guaranteeing accounts against losses arising from market conditions. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of the investment advisor and each investment advisor representative providing investment advice to you. We have no information of this type to report. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Neither Unconventional Investor nor our principal has outside business affiliations in the financial industry. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics We have adopted a set of enforceable guidelines (Code of Ethics), which describes unacceptable conduct by Unconventional Investor and our associated persons. Summarized, this Code of Ethics prohibits us from: placing our interests before yours,  using non public information gathered when providing services to you for our own gains, or   engaging in any act, practice or course of business that is, or might be considered, fraudulent, deceptive, manipulative, or in violation of any applicable law, rule or regulation of a governmental agency. Please contact us if you would like to receive a full copy of this Code of Ethics. Personal Trading for Associated Persons We may buy or sell some of the same securities for you that we already hold in our personal account. We may also buy for our personal account some of the same securities that you already hold in your account. It is our policy not to permit our associated persons (or their immediate relatives) to trade in a way that takes advantage of price movements caused by your transactions. We may restrict trading for a particular security for our accounts or those of our associated person if there is a pending trade in that security in a client account. Trades for our accounts (and those of our associated persons) will be placed after client trades have been completed. When our trades are placed after our client trades, we may receive a better or worse price than that received by the client. Unconventional Investor and its associated persons may purchase or sell specific securities for their own account based on personal investment considerations without regard to whether the purchase or sale of such security is appropriate for clients. All persons associated with us are required to report all personal securities transactions to us quarterly. Page 4  ITEM 12: BROKERAGE PRACTICES Selection of Brokers We require that our ongoing monitoring clients use who would like us to trade on their behalf use Vanguard or Charles Schwab & Co., Inc. (“Schwab”), as the qualified custodian. We are in the process of moving all client assets to Schwab and require that all new accounts be opened Schwab as custodian. Both are registered broker/dealers, and members of SIPC. We are independently owned and operated and are not affiliated with Vanguard or Schwab. Vanguard or Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we require that you use Vanguard or Schwab as custodian/broker, you will decide whether to do so and will open your account with one of them by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Schwab, then we cannot provide trading assistance for your ongoing portfolio monitoring account. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. How We Select Brokers/Custodians to Recommend We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including:  Combination of transaction execution services and asset custody services (generally without a separate fee for custody)  Capability to execute, clear, and settle trades (buy and sell securities for your account)  Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)  Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.)  Availability of investment research and tools that assist us in making investment decisions  Quality of services  Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.).  Reputation, financial strength, security and stability Prior service to us and our other clients   Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us From Schwab”) Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For clients holding an account at Schwab, we have determined that having Schwab execute most trades is consistent with our duty to Page 5  seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Brokers/Custodians”). Products and Services Available to Us From Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like 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. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. 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 don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. 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:  Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts  Provide pricing and other market data  Facilitate payment of our fees from our clients’ accounts   Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit 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 and business needs  Consulting on legal and related compliance needs Publications and conferences on practice management and business succession   Access to employee benefits providers, human capital consultants, and insurance providers  Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all Page 6  or a part of the third party's fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab we would be required to pay for these services from our own resources. Our Interest in Schwab’s Services. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our [selection/recommendation] of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. Aggregation of Orders Each purchase or sale of securities is done for a specific client. Since we do not hold custody and rather trade via limited power of attorney, we can ONLY trade on one client's account at a time, meaning that we cannot (and do not) aggregate orders for multiple clients. If we could aggregate, we conceivably could be able to save small amounts on transaction costs, though the small size of Unconventional Investor, LLC make this potential benefit small and unlikely. Soft Dollars The receipt of goods and/or services from the required custodian in connection with providing advice to clients is seen by the regulators as “soft dollars.” The additional services we receive from custodians, as disclosed in Item 14 below, would fall under this description of soft dollars. ITEM 13: REVIEW OF ACCOUNTS UI’s core asset classes and their associated index funds are continuously monitored to evaluate relative performance and to consider whether the underlying risk/return thesis for each asset class remains intact. We aim for securities and asset classes that are suitable for a holding period measured in decades. Using these quality index securities, UI is truly a buy and hold investor. Individual client accounts are monitored for asset class weightings. In addition to the continuous monitoring of accounts UI may conduct a separate account review for various reasons including but not limited to a change in investment strategy, a large addition or withdrawal of cash, change in account restrictions, or at the request of a client. Clients are responsible to advise UI of any changes in their investment objectives and/or financial situation. All clients are encouraged to review investment objectives and account performance with UI on an annual basis either in person, videocall or telephone. On a semi-annual basis, Paul O’Leary, Principal and Managing Member, evaluates the client account and rebalances the account back to target allocation if appropriate. We provide quarterly reports to clients containing account holdings by asset class levels. In addition, clients receive custodial statements (at least quarterly), from the custodian of the account. Page 7  ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION In recommending brokers to execute portfolio transactions, we make a good faith judgment of about which broker 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): the execution capabilities of the broker/dealer,   research (including economic forecasts, investment strategy advice, fundamental and technical advice on individual securities, valuation advice and market analysis),  custodial and other services provided by the broker/dealer that are expected to enhance our general portfolio management capabilities, the operational facilities of the broker-dealers involved, and  the quality of the overall brokerage and research services provided by the broker/dealer.  We do not directly or indirectly compensate anyone for client referrals. ITEM 15: CUSTODY If you give us authority to deduct our fees from your account, we have custody of those assets. In order to avoid additional regulatory requirements in these cases, we follow the procedures outlined in Item 5. You will also receive quarterly statements directly from custodian of the account that details all transactions in the account. We do not maintain physical custody of any client assets. ITEM 16: INVESTMENT DISCRETION You may provide discretionary authority for us to manage your assets. Discretionary authority means that you are giving us a limited power of attorney to place trades on your behalf. This limited power of attorney does not allow us to withdraw money from your account, other than advisory fees if you agree to give us that authority. You grant us discretionary authority by completing the following items:  Sign a contract with us that provides a limited power of attorney for us to place trades on your behalf. Any limitations to the trading authorization will be added to this agreement.  Provide us with discretionary authority on the new account forms that are submitted to the broker/dealer acting as custodian for your account(s). Some clients have individual stock holdings, such as the stock of an employer, that they wish to retain. ITEM 17: VOTING CLIENT SECURITIES We do not accept the authority to vote proxies on your behalf and we do not provide guidance about how to vote proxies. You will receive proxies and other related paperwork directly from your custodian. ITEM 18: FINANCIAL INFORMATION We do not charge or solicit pre-payment of more than $1,200 in fees per client six months or more in advance. We have never filed for bankruptcy and are not aware of any financial conditions that are reasonably likely to impair our ability to meet our contractual obligations to clients. Page 8  BROCHURE SUPPLEMENT ITEM 1: COVER SHEET Paul P. O’Leary Unconventional Investor, LLC P.O. Box 1119 Portsmouth, NH 03802 (415) 235-3729 January 21, 2025 This Brochure Supplement provides information about Paul P. O’Leary that supplements the Unconventional Investor, LLC Brochure. You should have received a copy of that Brochure. Please contact Paul P. O’Leary, Managing Member at (415) 235-3729 or paul@unconventionalinvestor.com if you did not receive Unconventional Investor, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about Paul P. O’Leary is available on the SEC’s website at www.adviserinfo.sec.gov. His CRD number is 1691967. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Paul P. O’Leary was born in 1965. He received a BA in Political Economy from Johns Hopkins University in 1987 and a MBA in Business Administration from University of Michigan, Ross School of Business in 1991. Employment Background Employment Dates: Firm Name: Type of Business: Job Title: 2/2007 - Present Unconventional Investor, LLC Investment Advisor Managing Member Employment Dates: Firm Name: Type of Business: Job Title & Duties: 2/2012 – 11/2013 Better Energy Systems Solar Company Interim Controller  Unconventional Investor, LLC Brochure Supplement Paul P. O’Leary Employment Background (continued) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 11/2009 - 2/2012 Curriculum Associates, LLC Supplemental Educational Publisher Director of Analytics. Help with data, analytics and other non investment matters. Employment Dates: Firm Name: Type of Business: Job Title & Duties: 1/2007 - 10/2009 Various Various Accounting and financial services to various companies on an interim basis. Employment Dates: Firm Name: Type of Business: Job Title & Duties: 4/2004 - 12/2006 Scientific Learning, Inc. Educational Software Director of Finance ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. O’Leary is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. O’Leary does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION Mr. O’Leary, Managing Member, is responsible for the supervision of all investment personnel. His telephone number is (415) 235-3729. Page 2  BROCHURE SUPPLEMENT ITEM 1: COVER SHEET C. Matthew O’Leary Unconventional Investor, LLC 1800 Truman Road Charlotte, NC 28205 (978) 846-2916 January 21, 2025 This Brochure Supplement provides information about C. Matthew O’Leary that supplements the Unconventional Investor, LLC Brochure. You should have received a copy of that Brochure. Please contact Paul P. O’Leary, Managing Member at (415) 235-3729 or paul@unconventionalinvestor.com if you did not receive Unconventional Investor, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about Matthew O’Leary is available on the SEC’s website at www.adviserinfo.sec.gov. His CRD number is 7092273. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE C. Matthew O’Leary was born in 1986. He received a BA in Math and French from College of the Holy Cross in 2008. Employment Background Employment Dates: Firm Name: Type of Business: Job Title: 1/2019 - Present Unconventional Investor, LLC Investment Advisor Advisor representative (beginning 3/2019). Employment Dates: Firm Name: Type of Business: Job Title & Duties: 4/2014 – 12/2018 Keyence Corporation Supplier of industrial automation equipment Sales engineer; consultative sales representative  Unconventional Investor, LLC Brochure Supplement C. Matthew O’Leary Employment Background (continued) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 5/2008 – 3/2014 United States Navy Military Commissioned Officer/Naval aviator; various ground jobs, aviation training naval aviator in several different airframes. ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. O’Leary is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. O’Leary does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION Mr. Paul O’Leary, Managing Member, is responsible for the supervision of all investment personnel. His telephone number is (415) 235-3729. Page 2