Overview

Assets Under Management: $1.4 billion
Headquarters: MIAMI, FL
High-Net-Worth Clients: 78
Average Client Assets: $18 million

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (SIERRA CAPITAL)

MinMaxMarginal Fee Rate
$0 $5,000,000 1.25%
$5,000,001 $10,000,000 0.85%
$10,000,001 $25,000,000 0.75%
$25,000,001 $50,000,000 0.65%
$50,000,001 and above 0.55%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,500 1.25%
$5 million $62,500 1.25%
$10 million $105,000 1.05%
$50 million $380,000 0.76%
$100 million $655,000 0.66%

Clients

Number of High-Net-Worth Clients: 78
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 95.91
Average High-Net-Worth Client Assets: $18 million
Total Client Accounts: 517
Discretionary Accounts: 488
Non-Discretionary Accounts: 29

Regulatory Filings

CRD Number: 110129
Last Filing Date: 2024-04-24 00:00:00
Website: HTTPS://WWW.SIERRACAP.COM

Form ADV Documents

Primary Brochure: SIERRA CAPITAL (2025-03-26)

View Document Text
Part 2A of Form ADV: Firm Brochure Sierra Capital LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Telephone: 212-867-3533 Email: Sierracapital@sierracap.com Web Address: www.sierracap.com March 13, 2025 This brochure provides information about the qualifications and business practices of Sierra Capital LLC. If you have any questions about the contents of this brochure, please contact us at 212-867-3533 or Sierracapital@sierracap.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Sierra Capital LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 110129. 1 Item 2 Material Changes The SEC adopted "Amendments to Form ADV" in July 2010. This Firm Brochure, dated 03/13/2025, is our new disclosure document prepared according to the SEC’s new requirements and rules. As you will see, this document is a narrative that is substantially different in form and content and includes some new information that we were not previously required to disclose. Consistent with the new rules, we will ensure that you receive a copy of the updated Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. 2 Item 3 Table of Contents Page 1 Item 1 Cover Page 2 Item 2 Material Changes 3 Item 3 Table of Contents 4 Item 4 Advisory Business 6 Item 5 Fees and Compensation 8 Item 6 Performance-Based Fees and Side-By-Side Management 8 Item 7 Types of Clients 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 10 Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations 11 Item 11 COE, Participation or Interest in Client Transactions and Personal Trading 11 Item 12 Brokerage Practices 12 Item 13 Review of Accounts 12 13 Item 14 Client Referrals and Other Compensation 13 Item 15 Custody 14 Item 16 Investment Discretion 14 Item 17 Voting Client Securities 14 Item 18 Financial Information 3 Item 4 Advisory Business FAMILY OFFICE SERVICES: Sierra Capital offers Family Office Services to a limited number of ultra-high net worth individuals and families to assist in achieving their goal of lasting legacy for future generations. Family Office Services are structured to offer an integrated, interdisciplinary approach to aggregating and focusing family resources and values to facilitate a common interest in financial management, cost control, financial education, and family philanthropy, among others. Sierra Capital's Family Office Services provides specific, custom solutions and relationship management. Depending on each client's particular needs and circumstances, the services provided through Sierra Capital's Family Office Services may include, but are not necessarily limited to: Development of "Investment Policy" memorializing the goals and values of the family Portfolio Consulting and Monitoring Portfolio Management Risk Management Consulting Overview of Investment Strategies Selecting and Monitoring Third Party Money Managers Working with Client's Third-Party Professionals to Coordinate the Implementation of Solutions Performance Reporting Services Financial Planning Services A more detailed description of each discreet offering encompassed by our Family Office Services is set forth below. Through its Family Office Services, Sierra Capital assists families to define legacy goals and design a long-term plan to try to maximize the probability of achieving these goals. Sierra Capital LLC is a SEC-registered investment adviser with its principal place of business located in Florida. Sierra Capital LLC was established in 1998 and is doing business as Sierra Capital Partners, LLC in the state of Florida. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). • Rafael Jose de la Sierra, Managing Member • Carlos Alfonso Pedroso, Managing Member/Chief Compliance Officer Sierra Capital LLC offers the following advisory services to our clients: INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our initial conversation, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior 4 investment history, as well as family composition and background. Because all types of investments involve certain additional degrees of risk, they will only be implemented for discretionary clients and recommended for non-discretionary clients when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Sierra Capital LLC offers advisory management services to clients through our Individual Portfolio Management Program. We provide the client with an asset allocation strategy developed through personal discussions in which the client's goals and objectives are established based on the client's particular circumstances. This investment strategy will be implemented into a client's Investment Policy Statement. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (ie. Investment horizon, risk tolerance, return expectations). Sierra Capital LLC performs investment manager selection through various sources when selecting managers based on client’s individual circumstances and needs. Factors considered in making this determination include but are not limited to: account assets, risk tolerance, custodian and client objectives. Clients should refer to each fund’s prospectus/offering memorandum or brochure for a full description of services offered. Our investment recommendation will generally include but are not limited to advice regarding the following securities: • Exchange-listed securities • Securities traded over-the-counter. • Foreign issuers • Corporate debt securities (other than commercial paper) • Commercial paper • Certificates of deposit • Municipal securities • Hedge Funds • Currencies • United States governmental securities • Interests in partnerships • Mutual funds • Structured Products • Commodities • Options • Master Limited Partnership • Real Estate Investment Trusts 5 • Real Estate Sierra capital provides the same Family Office Services described above provided on a non- discretionary basis as a consultant in a sub-advisory capacity. Because some types of investments involve certain additional degrees of risk, they will only be implemented for discretionary clients and recommended for non-discretionary clients when consistent with their stated investment policy and after discussion with the client about the additional potential risks associated with these products. Sierra Capital LLC also provides financial planning and consulting services on a standalone basis. These services include advice on investment and non-investment related matters, such as retirement planning, education planning, estate planning, and insurance planning. We do not provide financial planning or consulting services to all clients. We determine in our sole discretion whether to offer or provide these services for a given client based on the client’s needs, preferences, and objectives. Financial planning differs from consulting services in that we will prepare a financial plan for a client and the term of advisory services will end, whereas consulting services generally do not include the preparation of a financial plan and are long term in nature. The client retains the sole responsibility for determining whether to implement any recommendations we make and for placing any resulting transactions. We do not have discretionary authority with respect to the client’s assets unless the client enters into a wealth management agreement with us. A conflict of interest exists if the advice we provide in connection with financial planning or consulting services includes recommendations for other services that we provide. A client is under no obligation to act upon our recommendation. If a client elects to act on any of our recommendations, the client is under no obligation to effect the transaction through us. ASSETS UNDER MANAGEMENT As of 12/31/2024 we were actively managing $1,406,582,265 of clients' assets on a discretionary basis plus $51,474,895 of clients' assets on a non-discretionary basis. Item 5 Fees and Compensation INVESTMENT SUPERVISORY SERVICES FOR INDIVIDUAL PORTFOLIO MANAGMENT We are paid based on a percentage of the client's assets under management (excluding any margin balances) which typically ranges from .25% to 1.25%, depending on the size of the relationship. Our Standard Pricing is: $0 - $5,000,000 1.25% Next $5,000,000 to $10,000,000 0.85% Next $10,000,000 to $25,000,000 0.75% Next $25,000,000 to $50,000,000 0.65% Next $50,000,000 and Above 0.55% but can be altered as needed. However, at times, a combination of assets under management and performance-based fees (refer to Item 6) are arranged as well as fixed flat fees. Sierra Capital’s billing system will calculate the fee based on end of quarter asset balances not adjusting for credits or debits during the quarter. 6 Our firm has the ability to directly debit fees from client’s accounts on an account-by-account basis. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. In addition, Sierra Capital uploads quarterly invoices to the client’s portal. PLEASE COMPARE OUR MONTHLY INVOICES VS. OFFICIAL CUSTODIAL STATEMENTS. Statements and/or electronic feeds from custodians are used by Sierra Capital to calculate fees. This may differ from custodian statements due to timelier third party pricing. Clients should contact us directly if they believe that there may be an error in their statement or bill. Our firm is deemed to have custody for certain clients. A minimum of $10,000,000 of assets under management is required for our services. This account size may be negotiable under certain circumstances. Sierra Capital LLC may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Limited Negotiability of Advisory Fees: Although Sierra Capital LLC has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between Sierra Capital and each client. Sierra Capital LLC does not control the fees or the billing arrangements of any selected investment manager. For a complete description of the fee arrangement including billing practices, minimum account requirements and account termination provisions, clients should review the independent investment manager's Prospectus/Offering Memorandum /Firm Brochure or other disclosure document. The underlying manager can charge a fee of up to 3% annually of assets under management and up to 30 % of the net profits each year. Sierra Capital provides consulting sub-advisory services where the fee schedule is the same as our standard fee schedule and may be negotiated. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, according to client investment management agreement. As disclosed in the investment management agreement,certain fees are paid in advance or arrears of services provided. Upon termination of any account, any prepaid, unearned fees will be refunded. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. Mutual Fund, Hedge Fund and Other Investment Product Fees and ETFs: All fees paid to Sierra Capital LLC for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds, Hedge Funds, ETFs or other investment products to 7 their shareholders. These fees and expenses are described in each fund's prospectus and offering memorandum. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund, hedge fund, ETF or investment product are most appropriate for each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transaction for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. ERISA Accounts: Sierra Capital LLC is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (“ERISA”). As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Sierra Capital LLC may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Although Sierra Capital may charge quarterly fees in advance, under no circumstances do we require or solicit payment of fees of more than $1200 for more than six months in advance of services rendered. Reporting/Supervision Fees: Some clients pay a separate fee for consolidated reporting or supervision of assets. Fees are negotiable and can either be fixed or asset based. Item 6 Performance-Based Fees and Side-By-Side Management Sierra Capital LLC does charge performance-based fees at the request of the client as long as the client meets the minimum account size. As this could result in a conflict of interest, the client is asked to sign a letter acknowledging the potential conflict of interest. Performance based fees are calculated by charging on a % of gains net of flows this amount will be defined and approved by the client before moving forward. Item 7 Types of Clients Sierra Capital LLC provides advisory services to the following types of clients: • Individuals • Trusts 8 • High Net Worth Individuals • Pension and profit-sharing plans (other than plan participants) • Charitable Organizations • Corporations • Insurance Companies Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Asset Allocation. We believe that a sound investment policy designed to achieve long-term objectives begins with a carefully constructed asset allocation. The appropriate balance between stocks, bonds, alternative investments, and cash, in our opinion, is the most important aspect of an overall investment policy. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Investment Manager Selection: In order to help our clients achieve their objectives, we identify, hire and monitor a select group of asset managers who are specialists in their respective asset classes. Sierra Capital LLC believes that astute selection and blending of these managers may help to deliver consistent and sustainable performance, thereby enhancing an investor’s prospects of meeting their financial goals. Sierra Capital LLC applies a rigorous and regimented approach to the manager selection process in our role as a “manager of managers”. Sierra Capital may also use ETFs/basket of securities/individual stocks instead of active managers. A risk of the investment manager selection is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. INVESTMENT STRATEGIES We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment policy, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase investments with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when: • we want exposure to a particular asset class over time. A risk in a long-term purchase strategy is that by holding the investment for this length of time, 9 we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, an investment may decline sharply in value before we make the decision to sell. Short-term purchases. When utilizing this strategy, we purchase investments with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the investments we purchase. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Margin transactions. With client authorization, we will purchase securities for the portfolio with money borrowed from the brokerage account. This allows the purchase of more investments than one would be able to purchase with available cash and allows the purchase of investments without selling other holdings. Option writing. We use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative because it derives its value from an underlying asset. The two types of options are calls and puts: • A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we have determined that the stock will increase substantially before the option expires. • A put gives us the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we have determined that the price of the stock will fall before the option expires. We may use options to speculate on the possibility of a sharp price swing. We may also use options to "hedge" a purchase of the underlying security; in other words, we may use an option purchase to limit the potential upside and downside of a security we have purchased for the portfolio. We may use "covered calls", in which we sell an option on securities owned. In this strategy, one may receive a fee for making the option available, and the person purchasing the option has the right to buy the security at an agreed-upon price. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. 10 Item 10 Other Financial Industry Activities and Affiliations Rafael Jose de la Sierra and Carlos Alfonso Pedroso have no other financial affiliated business. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Sierra Capital LLC and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the code. Our Code of Ethics includes policies and procedures for the review of securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Our code also provides for oversight, enforcement, and recordkeeping provisions. Sierra Capital LLC's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to compliance@sierracap.com, or by calling us at 212- 867-3537. Sierra Capital LLC and individuals associated with our firm are prohibited from engaging in principal transactions. Sierra Capital LLC and individuals associated with our firm are not permitted to engage in agency cross transactions. Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts, securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. It is the expressed policy of our firm that no person employed by us may purchase or sell any security immediately prior to a transaction(s) being implemented for an advisory account, thereby preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. 11 Item 12 Brokerage Practices Sierra Capital does not accept the discretionary authority to determine the broker dealer used or the commission rates paid to executing brokers on a trade-by-trade basis. As such, clients must direct the firm as to which broker dealer to use for trades placed in the client’s account. Not all registered investment advisers require their clients to direct brokerage to specific broker-dealers. By directing brokerage, Sierra Capital may be unable to achieve most favorable execution of client transactions and this practice may cost clients more money. Sierra Capital reserves the right to decline acceptance of any client account for which the client directs the use of a particular custodian or broker dealer if we believe that the client’s choice would hinder our ability to service the account. In directing the use of a particular broker dealer, clients should note that Sierra Capital will not have authority to negotiate commissions on a trade-by-trade basis and best execution may not be achieved. In addition, a disparity in commission costs may exist between the commissions charged to the client and those charged to other clients that direct the use of a different broker dealer. As a matter of policy and practice, Sierra Capital LLC does not generally block client trades and, therefore, we implement client transactions separately for each account. Consequently, certain client trades may be executed before others, at a different price and/or commission rate. Additionally, our clients may not receive volume discounts available to advisers who block client trades. Some financial institutions may charge custody fees while others may not. Both banks and broker dealers are compensated by account holders through commissions and other transaction-related or asset-based fees for security trades that are executed through their platform or that settle into their accounts. Some Financial institutions assist us in managing and administering our clients’ accounts through the use of software and other technology that: i. provide access to client account data (such as trade confirmations and account statements); ii. facilitate trade execution and allocate aggregated trade orders for multiple client accounts; iii. provide research, pricing and other market data; iv. facilitate payment of our fees from clients' accounts; and v. assist with back-office functions, recordkeeping and client reporting. Some financial institutions also offer other services intended to help us manage and further develop our business enterprise. These services may include: i. compliance, legal and business consulting; ii. publications and conferences on practice management and business succession. Item 13 Review of Accounts On an ongoing basis, we monitor the performance of the Investment manager(s). If we determine that a particular manager is not meeting the investment objectives, then we may move the client’s investment to a different investment manager. With discretionary accounts, 12 our firm retains the ability to hire and fire the investment manager. Sierra Capital requires an account minimum of $10,000,000 for these advisory services, but at our discretion may accept a smaller account. In addition, third party managers to whom clients may be referred may also impose minimum account requirements, and we refer clients to those managers’ disclosures. At least annually, we meet with the client and sub advisory client, and should there be any material change in the client's or sub advisory client’s personal and/or financial situation, we should be notified immediately to determine whether any review and/or revision of the client's or sub advisory client’s Investment Policy Statement is warranted. Once the client's and sub advisory client’s portfolio has been established, we periodically review the portfolio, and if necessary, rebalance it as we see fit based on the client's or sub advisory client’s individual needs. As per ADV Part 1 Sierra Capital does not engage in any soft dollar arrangements with third parties / broker dealers in connection with client security transactions. Item 14 Client Referrals and Other Compensation CLIENT REFERRALS Our firm does pay referral fees to independent persons or firms ("Promoters") for introducing clients to us. In the event we pay a referral fee, we require the Promoter to provide the prospective client with a copy of this document (our Firm Brochure) and a separate disclosure statement that includes the following information: • the Promoter's name and relationship with our firm; • the fact that the Promote is being paid a referral fee which is a % of the assets paid to Sierra Capital. • whether the fee paid to us by the client will be increased above our normal fees in order to compensate the promoter. As a matter of firm practice, the advisory fees paid to us by clients referred by promoters are not increased as a result of any referral. Item 15 Custody We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm has the ability to directly debit advisory fees from client accounts and does in some circumstances. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. It is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Please contact Sierra Capital directly in the event that you 13 have not received an official statement. Although we report on client assets, we cannot accept client credentials for accounts where we have the ability to deposit or withdraw funds. Sierra Capital has Standing Letters of Authorizations for certain clients but the firm follows the guidance set forth in the SEC’s February 2017 No Action Letter to the IAA whereby Sierra Capital is not deemed to have custody as the client provides written signed instructions to qualified custodian, Custodian verifies the instruction (Signature review), client can change/terminate instructions, Sierra Capital has no authority to change instructions, and Annual notice reconfirming instructions are in place. Item 16 Investment Discretion Clients hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • Determine the investment to buy or sell; and/or • Determine the amount of the investment to buy or sell • Determine when to buy or sell Clients give us discretionary authority when they sign the investment management agreement/investment advisory agreement with our firm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Item 17 Voting Client Securities As a matter of firm policy, we do not vote proxies but can vote on corporate actions on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted. However, Sierra Capital can make elections on behalf of the clients relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets, to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. We do not offer any consulting assistance regarding proxy issues to clients. It is the client’s responsibility to vote proxies. Item 18 Financial Information Sierra Capital LLC has no additional financial circumstances to report. Sierra Capital LLC has not been the subject of a bankruptcy petition at any time. 14 Sierra Capital does not charge any fees six months or more in advance of services rendered to any client. 15 BROCHURE SUPPLEMENT (Part 2B) Rafael de la Sierra Sierra Capital, LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Tel: 212-867-3533 E-mail: rafael.delasierra@sierracap.com Website: www.sierracap.com March 13, 2025 This brochure supplement provides information about Rafael de la Sierra and supplements the Sierra Capital LLC brochure. You should have received a copy of that brochure. Please contact Rafael de la Sierra if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Rafael de la Sierra (CRD #2206086) is available on the SEC’s website at www.adviserinfo.sec.gov. 16 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Rafael de la Sierra • Year of birth: 1968 Item 2 - Educational Background and Business Experience Educational Background: • Boston College; BS Finance; 1990 Securities Industry Examinations: • Series 65, Uniform Investment Adviser Law Exam, 07/23/2019 Business Experience: • Sierra Capital LLC; Managing Member 02/1998 – Present • Pangea Asesores, LLC; CCO/Investment Advisor Representative; 08/2019 – 12/2021 Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Rafael de la Sierra is not engaged in any other investment related activities but does have an interest in real estate rental properties. Item 5 - Additional Compensation Rafael de la Sierra does not receive any additional compensation. Item 6 – Supervision Carlos Pedroso is responsible for all supervision and monitoring of investment advice offered to clients by Rafael de la Sierra. Mr. de la Sierra will adhere to the policies and procedures as described in the firm’s Compliance Manual. Carlos Pedroso can be reached at 212-867-8795. 17 BROCHURE SUPPLEMENT (Part 2B) Carlos Pedroso Sierra Capital, LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Tel: 212-867-3533 E-mail: carlos.pedroso@sierracap.com Website: www.sierracap.com March 13, 2025 This brochure supplement provides information about Carlos Pedroso and supplements the Sierra Capital, LLC brochure. You should have received a copy of that brochure. Please contact Carlos Pedroso if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Carlos Pedroso (CRD #4869337) is available on the SEC’s website at www.adviserinfo.sec.gov 18 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Carlos Alfonso Pedroso • Year of birth: 1981 Item 2 - Educational Background and Business Experience Educational Background: • University of Florida; Bachelor’s in Art History; 2004 Securities Industry Examinations: • Series 7, General Securities Representative, 11/09/2004 • Series 63, Uniform Securities Agent State Law Exam, 12/07/2004 • Series 65, Uniform Investment Adviser Law Exam, 09/11/2019 Business Experience: • Sierra Capital, LLC; Managing Member; 09/2007 – Present • Pangea Asesores LLC; Investment Advisor Representative; 09/2019 – 12/2021 Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Carlos Pedroso is not engaged in any other investment related activities but does have an interest in real estate rental properties. Item 5 - Additional Compensation Carlos Pedroso receives no additional compensation. Item 6 – Supervision Carlos Pedroso is solely responsible for all supervision and formulation and monitoring of investment advice offered to clients. His advisory activities are monitored by Rafael de la Sierra who is a Partner of the firm. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at 212-867-8795. 19 BROCHURE SUPPLEMENT (Part 2B) Kevin Hernandez Sierra Capital, LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Tel: 212-867-3533 E-mail: kevin.hernandez@sierracap.com Website: www.sierracap.com March 13, 2025 This brochure supplement provides information about Kevin Hernandez and supplements the Sierra Capital, LLC brochure. You should have received a copy of that brochure. Please contact Kevin Hernandez if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Kevin Hernandez (CRD #5784381) is available on the SEC’s website at www.adviserinfo.sec.gov 20 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Kevin Hernandez • Year of birth: 1983 Item 2 - Educational Background and Business Experience Educational Background: • Monterrey Institute of Technology and Higher Education – 2005 • HEC Paris 2006 Securities Industry Examinations: • Series 7, General Securities Representative, 11/15/2010 • Series 63, Uniform Securities Agent State Law Exam, 11/01/2011 • Series 65, Uniform Investment Adviser Law Exam, 05/17/2021 Business Experience: • UBS Investment Bank London – Chemicals M&A • UBS Corporate Advisory Group – LATAM M&A • JP Morgan Chase, LATAM Asset Management– Vice President • Sierra Capital, LLC; 10/2013– Present Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Kevin Hernandez is not engaged in any other investment related activities. However, he has formed an LLC to invest in real estate transactions in the US. This does not create any conflict of interest with our existing client base. Item 5 - Additional Compensation Kevin Hernandez does not receive any additional compensation. Item 6 – Supervision Supervisor: Carlos Pedroso is responsible for all supervision and monitoring of investment advice offered to clients by Kevin Hernandez. Mr. Hernandez will adhere to the policies and procedures as described in the firm’s Compliance Manual. Carlos Pedroso can be reached at 212-867-8795. 21 BROCHURE SUPPLEMENT (Part 2B) Norman Chamorro Sierra Capital, LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Tel: 212-867-3533 E-mail: norman.chamorro@sierracap.com Website: www.sierracap.com March 13, 2025 This brochure supplement provides information about Norman Chamorro and supplements the Sierra Capital, LLC brochure. You should have received a copy of that brochure. Please contact Norman Chamorro if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Norman Chamorro (CRD #7418595) is available on the SEC’s website at www.adviserinfo.sec.gov 22 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Norman Chamorro • Year of birth: 1991 Item 2 - Educational Background and Business Experience Educational Background: • University of Virginia- 2013 Securities Industry Examinations: • Series 65, Uniform Investment Adviser Law Exam, 05/20/2021 Business Experience: • Sierra Capital, LLC; 06/2015– Present Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Norman Chamorro is not engaged in any other investment related activities. Item 5 - Additional Compensation Norman Chamorro does not receive any additional compensation. Item 6 – Supervision Supervisor: Carlos Pedroso is responsible for all supervision and monitoring of investment advice offered to clients by Norman Chamorro. Mr. Chamorro will adhere to the policies and procedures as described in the firm’s Compliance Manual. Carlos Pedroso can be reached at 212-867-8795. 23 BROCHURE SUPPLEMENT (Part 2B) Charles Flynn, CFA® Sierra Capital, LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Tel: 212-867-3533 E-mail: charles.flynn@sierracap.com Website: www.sierracap.com March 13, 2025 This brochure supplement provides information about Charles Flynn and supplements the Sierra Capital, LLC brochure. You should have received a copy of that brochure. Please contact Charles Flynn if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Charles Flynn (CRD #6571768) is available on the SEC’s website at www.adviserinfo.sec.gov 24 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Charles Flynn • Year of birth: 1993 Item 2 - Educational Background and Business Experience Educational Background: • Manhattanville College – 2015 Securities Industry Examinations: • Series 7, General Securities Representative Exam, Dec. 2015 • Series 66 Uniform Combined State Law Exam, Jan 2016 • CFA® * Business Experience: • UBS Financial Services; 11/2015-03/2021 • Sierra Capital, LLC; 03/2021– Present *Designations, Qualifications and Related Criteria Chartered Financial Analyst® (CFA®) Mr. Flynn has earned the right to use the Chartered Financial Analyst® or CFA designation from the CFA Institute, a global, not for profit organization of investment professionals. Candidates must have in-depth knowledge of securities types and investment vehicles, and have earned at least a bachelor’ degree from an accredited school. To earn the CFA® designation, Mr. Flynn, successfully passed all three exam levels (six-hour each, covering ethics, quantitative methods, economics, corporate finance, financial reporting and analysis, security analysis, and portfolio management), completed at least four years of qualified investment work experience, and became a member of the CFA Institute. To maintain the designation, he must annually renew his pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct and maintain his membership in a local CFA member society.[Chartered Financial Analyst® and CFA® are trademarks owned by the CFA Institute.] Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Charles Flynn is not engaged in any other investment related activities. 25 Item 5 - Additional Compensation Charles Flynn does not receive any additional compensation. Item 6 – Supervision Supervisor: Carlos Pedroso is responsible for all supervision and monitoring of investment advice offered to clients by Charles Flynn. Mr. Flynn will adhere to the policies and procedures as described in the firm’s Compliance Manual. Carlos Pedroso can be reached at 212-867- 8795. 26 BROCHURE SUPPLEMENT (Part 2B) Maria Teresa Felix Cubero Sierra Capital, LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Tel: 212-867-3533 E-mail maria.felix@sierracap.com Website: www.sierracap.com March 13, 2025 This brochure supplement provides information about Maria Teresa Felix Cubero and supplements the Sierra Capital, LLC brochure. You should have received a copy of that brochure. Please contact Maria Teresa Felix Cubero if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Maria Teresa Felix Cubero (CRD #7612503) is available on the SEC’s website at www.adviserinfo.sec.gov 27 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Maria Teresa Felix Cubero • Year of birth: 1997 Item 2 - Educational Background and Business Experience Educational Background: • Universidad de Valencia, Spain and UNC Wilmington – 2019 Securities Industry Examinations: • Series 65, Uniform Investment Adviser Law Exam, 07/12/2022 Business Experience: • Sierra Capital, LLC; 05/2022– Present Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Maria Teresa Felix Cubero is not engaged in any other investment related activities. Item 5 - Additional Compensation Maria Teresa Felix Cubero does not receive any additional compensation. Item 6 – Supervision Supervisor: Carlos Pedroso is responsible for all supervision and monitoring of investment advice offered to clients by Maria Teresa Felix Cubero. Mrs. Felix Cubero will adhere to the policies and procedures as described in the firm’s Compliance Manual. Carlos Pedroso can be reached at 212-867-8795. 28 BROCHURE SUPPLEMENT (Part 2B) Zev Zaretsky, CFA® Sierra Capital, LLC 600 Brickell Avenue Ste. 2020 Miami, FL 33131 Tel: 212-867-3533 E-mail: zev.zaretsky@sierracap.com Website: www.sierracap.com March 13, 2025 This brochure supplement provides information about Zev Zaretsky and supplements the Sierra Capital, LLC brochure. You should have received a copy of that brochure. Please contact Zev Zaretsky if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Zev Zaretsky (CRD # 6088643) is available on the SEC’s website at www.adviserinfo.sec.gov 29 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Zev Zaretsky • Year of birth: 1989 Item 2 - Educational Background and Business Experience Educational Background: • Florida Atlantic University - 2012 Securities Industry Examinations: • Series 7, General Securities Representative Exam, Dec. 2015 • Series 66 Uniform Combined State Law Exam, Jan 2016 • CFA® * Charter, May 2016 Business Experience: • Capco; 12/2012 – 11/2014 • Deutsche Bank USA ; 11/2014 – 10/2015 • Macquarie Capital (USA) Inc.; 10/2015 – 8/2016 • Seacoast Bank ; 8/2016 – 3/2021 • Sierra Capital, LLC; 03/2021– Present *Designations, Qualifications and Related Criteria Chartered Financial Analyst® (CFA®) Mr. Zaretsky has earned the right to use the Chartered Financial Analyst® or CFA designation from the CFA Institute, a global, not-for-profit organization of investment professionals. Candidates must have in-depth knowledge of security types and investment vehicles, and have earned at least a bachelor’s degree from an accredited school. To earn the CFA® designation, Mr. Zaretsky successfully passed all three exam levels (six-hour each, covering ethics, quantitative methods, economics, corporate finance, financial reporting and analysis, security analysis, and portfolio management), completed at least four years of qualified investment work experience, and became a member of the CFA Institute. To maintain the designation, he must annually renew his pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct and maintain his membership in a local CFA member society.[Chartered Financial Analyst® and CFA® are trademarks owned by the CFA Institute.] Item 3 - Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. 30 Item 4 - Other Business Activities Engaged In Zev Zaretsky is not engaged in any other investment related activities. Item 5 - Additional Compensation Zev Zaretsky does not receive any additional compensation. Item 6 – Supervision Supervisor: Carlos Pedroso is responsible for all supervision and monitoring of investment advice offered to clients by Zev Zaretsky. Mr. Zaretsky will adhere to the policies and procedures as described in the firm’s Compliance Manual. Carlos Pedroso can be reached at 212-867-8795. 31