TEXAS YALE CAPITAL CORP.

Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 Texas Yale Capital Corp. d/b/a Yale Capital Corp. 6475 1st Avenue South, Saint Petersburg, FL 33707 (727) 823-0006 www.yalecapitalcorp.com This Brochure provides information about the qualifications and business practices of Yale Capital Corp. If you have any questions about the contents of this Brochure, please contact us at (727) 823-0006 or email us at info@yalecapitalcorp.com. The information in this Brochure has not been approved nor verified by the United States Securities and Exchange Commission or by any state securities authority. Yale Capital Corp. is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Yale Capital Corp. is also available on the SEC’s website at www.adviserinfo.sec.gov. This Brochure is dated 03.24.2025 and has been prepared according to the SEC’s rules and requirements.  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 Item 2 – Material Changes This Item lists material changes that are made to the Brochure. We will also reference the date of our last annual amendment of our Brochure. Date of Last Annual Amendment 03.26.2024 03.24.2025 Since our last annual amendment, we have made the changes to the following sections of the Brochure: • Added additional information regarding the compensation it receives in regard to its practice as a general partner for certain client accounts in Item 5– Fees and Compensation at (A), (D), and (E); • • Updated disclosures regarding cross trades in Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading at (B); Updated disclosure regarding personal trading in Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading at 3(B); Updated disclosure regarding trade aggregation at Item 12 – Brokerage Practices at 3(B); and • Updated disclosure regarding custody related to client-related partnerships for which we act as a general partner at Item 15. We will ensure that you receive a summary of any materials changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. Currently, our Brochure may be requested by contacting Jennifer Wheeler at (727) 823-0006 or info@yalecapitalcorp.com. We will provide you with a new Brochure at any time, without charge. Additional information about Yale Capital Corp. is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s Web site provides information about any persons affiliated with Yale Capital Corp. who are registered, or are required to be registered, as investment adviser representatives of Yale Capital Corp.  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 Item 3 -Table of Contents Item 1 – Cover Page ................................................................................................................................ i Item 2 – Material Changes .....................................................................................................................ii Item 3 –Table of Contents .................................................................................................................... iii Item 4 – Advisory Business ................................................................................................................... 1 Item 5 –Fees and Compensation............................................................................................................. 1 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 ................................................4 Item 9 – Disciplinary Information ..........................................................................................................5 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 5 Item 11 – Code of Ethics ........................................................................................................................ 6 Item 12 – Brokerage Practices ................................................................................................................ 9 Item 13 – Review of Accounts ............................................................................................................. 12 Item 14 – Client Referrals and Other Compensation ........................................................................... 12 Item 15 – Custody ................................................................................................................................ 13 Item 16 – Investment Discretion .......................................................................................................... 13 Item 17 – Voting Client Securities ....................................................................................................... 14 Item 18 – Financial Information ........................................................................................................... 14  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 Item 4 – Advisory Business (A) Business Description Yale Capital Corp. (YCC) is an independent and owner-operated investment adviser, registered with the SEC since 2004. The firm is controlled by Cheyne Pace, Chairman, Chief Investment Officer, and President. (B) Description of Advisory Services Offered YCC provides investment advice and asset management to high-net-worth families. YCC manages exchange-traded securities and bonds, with an additional specialization in tax-advantaged holdings such as master limited partnerships. Assets are supervised on a discretionary or non-discretionary basis according to the client/adviser investment advisory agreement. YCC also provides financial planning services. (C) Customized Advisory & Financial Services YCC customizes advisory and financial services for clients as a cornerstone objective. With a dedication to client services, YCC is able to engage in regular conversations with its clients, to ensure clients are kept informed and as in touch with their portfolios as they wish to be. Investment strategies are designed for the individual client and all accounts are managed separately according to the specific goals and risk tolerance of each client. Client service employees manage recurrent and rare transactions for clients as a matter of daily routine. Client wishes are followed exactly, and any client-imposed restrictions are respected. Furthermore, YCC can offer particular assistance to clients with restricted securities and has a long history of helping clients following the sales of their companies. (D) YCC does not participate in “wrap-fee” programs. (E) As of 2.28.25, YCC manages $4,043,423,172 on a discretionary basis (112 accounts). YCC calculates the number of accounts by household. Item 5 – Fees and Compensation (A) Yale Capital Corp. (YCC) charges a percentage of assets under management. All fees are subject to negotiation and will be set forth in the investment advisory agreement. Because the adviser’s fees are negotiated, not all clients will pay the same fee. Our fee range varies from 0 – 1.5% of assets under management, per household, depending on amount of work and attention involved in managing account. Clients can choose for YCC to serve as general partner for client-related limited partnerships which can result in YCC charging the client-related partnerships outside of this range. These practices are potential conflicts of interest because some clients will pay more than others for YCC’s services. To mitigate these potential conflicts, YCC makes clients aware of this difference to assure they are aware of these potential conflicts prior to engagement of our services. 1  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 (B) The specific manner in which fees are charged by YCC is established in a client’s written investment agreement with YCC. YCC will generally bill its fees quarterly. Clients authorize YCC to directly debit fees from client accounts. (C) Clients incur charges imposed by mutual funds, exchange traded funds, custodians, brokers, and other third parties (examples: fees charged by third-party managers, custodial fees, deferred sales charges, odd- lot differentials, transfer taxes, electronic fund fees, fed wire fees, trading commissions, prime brokerage fees, and other fees on brokerage accounts and transactions – if clients wish to engage in such transactions). Such charges, fees, and commissions are exclusive of and in addition to YCC’s fee, and YCC shall not receive any portion of these commissions, fees, or costs. In certain instances, YCC has negotiated to deduct brokerage transaction and money movement costs (e.g., commissions, ticket charges, fed wire fees) from the fee owed to YCC. To the extent that YCC reimburses a client for these costs, the client’s net performance will be greater than that of a client that does not receive reimbursement. Item 12 further describes the factors that YCC considers when selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). As a rule, YCC avoids investing in fee intensive products unless specifically directed by clients. (D) YCC’s general practice is to bill advisory fees quarterly in advance unless otherwise set forth in its agreement with the client. Each calendar quarter, accounts are billed based upon the value of the account on the last day of the previous quarter and according to details included in the investment advisory agreement (IAA). New client accounts will also be charged a prorated fee for the remainder of the initial quarter. Upon request, clients may obtain a refund of pre-paid fees if the account is terminated during the quarter, providing the account has been in effect for the minimum term of the IAA; the refund amount will be calculated on a pro-rata basis according to the number of days left in the quarter ([pre- paid fee/number of days in quarter] x number of days left in quarter). For accounts closed before minimum length stated in IAA, a pro-rated fee will be charged according to the signed investment advisory agreement ([assets under management at last quarter-end x quarterly fee percentage] x number of quarters left in the agreement). YCC also charges a client a prorated fee for the remainder of the quarter on any deposit made to the client’s account after the quarterly fee has been deducted which exceeds one million dollars ($1,000,000). This prorated fee will be set forth in the investment advisory agreement and deducted from the client’s account. At its discretion, YCC may waive this fee for certain clients. (E) YCC and its supervised persons do not accept compensation for the sale of securities or other investment products (including asset-based sales charges or service fees from the sale of mutual funds). In our view, such a practice incentivizes advisers to recommend products based on commissions received, rather than on a client’s needs; to avoid such a conflict of interest, YCC receives compensation solely through its quarterly management fee (no commissions and no mark-ups) and partnership charges. YCC, nor any of its employees, are registered with, nor receive any compensation from any bank or brokerage firm. 2  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 (F) YCC recommends that clients verify the accuracy of the fees deducted from their accounts as errors are possible (though controls are in place to avoid them). Clients are responsible to pay for services rendered until the termination of the investment advisory agreement. The client can cancel the agreement without penalty within five days of signing the investment advisory agreement. Investment advisory services begin on the effective date of the investment advisory agreement. Item 6 – Performance-Based Fees and Side-By-Side Management Upon request from client, Yale Capital Corp. (YCC) may have performance fee arrangements with said qualified clients; fees are subject to individual negotiation with each client. YCC will structure any performance or incentive fee arrangement subject to Section 205(a)(1) of the Investment Advisers Act of 1940 (“The Advisers Act”) in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205-3. In measuring clients' assets for the calculation of performance-based fees, YCC shall include realized and unrealized capital gains and losses. Performance-based fee arrangements may create an incentive for YCC to recommend investments which may be riskier or more speculative than those that would be recommended under a different fee arrangement. Such fee arrangements could also create an incentive to favor higher fee-paying accounts over said clients’ other accounts in the allocation of investment opportunities. YCC has procedures designed and implemented to ensure that all clients are treated fairly and equally and to prevent this conflict from influencing the allocation of investment opportunities among clients. Item 7 – Types of Clients Yale Capital Corp. (YCC) provides portfolio management services to high-net-worth individuals/families, private investment funds, and U.S. institutions. The minimum account size is $10,000,000. However, YCC has discretion to waive the account minimum: accounts that do not meet the account minimum may be set up when the client and YCC anticipate the client will add additional funds to the accounts bringing the total up to $10,000,000 within a reasonable time frame. Other exceptions may apply to employees of YCC and their relatives, relatives of existing clients, or other circumstances as YCC deems appropriate. When YCC provides investment advice to a client regarding the client’s retirement plan or individual retirement account, YCC is a fiduciary within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way YCC makes money creates some conflicts with retirement clients’ interests, so YCC operates under a special rule that requires YCC to act in retirement clients’ best interests and not put YCC’s interest ahead of them. Under this regulation’s provisions, YCC must: • Meet a professional standard of care when making investment recommendations (give prudent advice); 3  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 • Not put YCC’s financial interests ahead of a retirement client’s when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that YCC gives advice that is in a retirement client’s best interest; • Charge no more than is reasonable for our services; and • Give a retirement client basic information about conflicts of interest. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An a retirement investor may use a combination of those options, such as; (i) leave the funds in their former employer’s plan, if permitted, (ii) roll over the funds to a new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an IRA, or (iv) cash out the account value (which could, depending upon the individual’s age, result in adverse tax consequences). YCC has an economic incentive to encourage a client to rollover a retirement plan or IRA into an IRA that YCC manages. This arrangement creates a conflict of interest in that it creates an incentive for YCC to recommend that a client rollover their account YCC to manage rather than retaining it with an unaffiliated third party. Retirement clients are under no obligation to roll over retirement plan assets to an account managed by YCC. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Yale Capital Corp. (YCC) customizes investment strategies for each client depending on their particular circumstances and requirements. YCC engages its clients in detailed discussions in order to construct and manage customized portfolios – with suitable investments and management styles. The following considerations contribute to effective discussions, portfolio construction and management: (i) Client’s unique circumstances: age, objectives, income and cash-flow requirements, emotional tolerance for volatility, familial and charitable giving intentions, restrictions on particular securities (ii) Capital market conditions (iii) Appreciation and income over time (iv) Tax-efficiency, with engagement of client’s accounting and additional investment counsel when necessary Yale Capital Corp. advisers continuously monitor individual client portfolios and make adjustments to reflect significant changes in the aforementioned variables. (A) YCC applies fundamental analysis of securities, the broader market, and other economic factors to contribute to the formulation of its investment advice. YCC’s primary strategy involves investing in dividend-bearing and tax-efficient asset classes. YCC believes that, as a general rule, relative to a high- net-worth individual’s potential benefit, frequent trading involves an unjustifiable amount of cost, and 4  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 that the impact of taxes and transactions can be detrimental to performance. Analysts and advisers continuously monitor portfolios and market conditions, making judicious portfolio adjustments according to the best interests of the client. Investing in securities involves risk of loss that clients should be prepared to bear. (B) YCC believes all forms of investment management pose market risks. The following risks are most relevant to our asset groups: interest rate, market volatility, market events, terrorism, and company management. (C) YCC offers a specialization in Master Limited Partnerships. There are always risks involved in investing. Amongst MLP risks are the following: interest rate fluctuations, market volatility, market events, terrorism, company management, potential tax changes, and alternative energy competition. Item 9 – Disciplinary Information Registered investment advisers must disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of the adviser or the integrity of adviser’s management. Yale Capital Corp. has no past or present legal or disciplinary events, or any administrative proceedings, to report. Item 10 – Other Financial Industry Activities and Affiliations (A) Yale Capital Corp. (YCC) and its principal executive officers are solely in the business of providing investment advice to clients. YCC does not sell products or other services to clients. Neither YCC, nor its management persons, are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. (B) Neither YCC, nor its management persons, are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. (C) YCC utilizes Charles Schwab & Co. as its custodian, though the two firms are not linked through common ownership or subsidiary arrangements. YCC would consider using another custodian on a per client basis if requested to do so. YCC and its management persons are not affiliated with any of the below types of firms. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) 5  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 3. other investment adviser or financial planner 4. futures commission merchant, commodity pool operator, or commodity trading adviser 5. banking or thrift institution 6. accountant or accounting firm 7. lawyer or law firm 8. insurance company or agency 9. pension consultant 10. real estate broker or dealer 11. sponsor or syndicator of limited partnerships. (D) In the event that YCC agrees to select other investment advisers for a client, the firm will disclose all material conflicts of interest, direct or indirect compensation from advisers, and all practices related to addressing conflicts of interest. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Yale Capital Corp’s (YCC) clients, or prospective clients, may request a copy of the firm's Code of Ethics by contacting the firm directly. (A) YCC has a Code of Ethics for all supervised persons describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other considerations. All supervised persons at YCC must acknowledge the terms of the Code of Ethics annually, or as amended. (B) It is YCC’s policy that the firm will not affect any principal transactions for client accounts. YCC will also not cross trades between proprietary and client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account (Although YCC has no affiliated hedge fund). YCC has implemented a program that allows for the realization of tax losses by allowing cross-trades for client assets between certain client accounts. However, not all clients will participate in cross-trades. Accounts excluded from cross trading may not (i) receive the benefit of lower transaction costs realized from a cross trade versus trading in the open market and (ii) may not receive the same price as clients participating in cross transactions. 6  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 Cross trades can benefit both clients by potentially reducing transaction costs and market impact. However, cross trading could lead to one client receiving more favorable treatment than another. Additionally, cross trading creates a conflict in that YCC advises clients on both sides of the transaction. To ensure that YCC fulfills its fiduciary obligations to selling and buying clients. YCC only executes cross trades after establishing in good faith that the trades benefit both parties, comply with applicable client restrictions and limitations, align with investment objectives, and follow the guidelines for the client accounts involved in the cross. Additionally, these trades are executed through a third-party dealer at market price via the clients’ custodian broker-dealer. Cross transactions are subject to evaluations for best execution. (C) YCC and its related persons do not recommend to clients, or buy and sell in client accounts, securities in which it or a related person has a material financial interest or conflict of interest. YCC and its related persons do, however, own securities that clients also hold – please see Item 11, Section D. (D) YCC anticipates that, if consistent with clients’ investment objectives, it will recommend to investment advisory clients or prospective clients the purchase or sale of securities that YCC or its employees hold in their corporate/personal portfolios. YCC’s employees and persons associated with YCC must follow YCC’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors, contractors, and employees of YCC may trade in their own accounts securities that YCC’s clients also hold or receive recommendations for. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the employees of YCC will: (i) not interfere with making decisions in the best interest of advisory clients, and (ii) allow employees to invest for their own accounts, while implementing such decisions. Under the Code of Ethics certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of YCC’s clients – for example, mutual funds. In addition, the Code of Ethics requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity created by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, to reasonably prevent conflicts of interest between YCC and its clients. (E) YCC’s employees buy or sell securities that we recommend to clients or recommend securities transactions in which they have some financial interest. Such transactions create a conflict of interest; however, YCC does not engage in trading that operates to the client’s disadvantage if the employees buy or sell at or around the same time as the client. 7  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 (F) Privacy Policy YCC collects Nonpublic Personal Information from clients at account inception and occasionally thereafter, primarily to determine clients’ investment objectives and financial goals, and to assist in providing clients with a high level of service. While YCC strives to keep client information up to date, we request that clients advise of changes to their Personal Information. For purposes of this policy, "Nonpublic Personal Information" means: • Personally identifiable financial information, including any information a client provides to obtain a financial product or service; any information about a client resulting from any transaction involving a financial product or service; or any information otherwise obtained about a client in connection with providing a financial product or service to that client; and • Any list, description, or other grouping of clients (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available information. Examples of Nonpublic Personal Information include: name, address, phone number (if unlisted), social security and tax identification numbers, financial circumstances and income, and account balances. YCC will not disclose a client’s Nonpublic Personal Information to anyone unless it is permitted or required by law, at the direction of a client, or is necessary to provide Yale Capital Corp.’s services to the client. • YCC limits sharing with non-affiliates to information necessary to run our everyday business. YCC does not share personal information with non-affiliates to market to you. • YCC will restrict access to Nonpublic Personal Information to individuals within YCC, and its affiliates, who require the information in the ordinary course of servicing clients’ accounts. Clients’ Nonpublic Personal Information is used only for business purposes. • YCC has developed procedures to safeguard client records and Nonpublic Personal Information. • Nonpublic Personal Information may only be given to third parties under the following circumstances: • To broker/dealers to open a client’s brokerage account • To other firms as directed by clients, such as accountants, lawyers, etc. • To specified family members (as authorized by law and/or the client) • To third parties as needed to provide requested services; and • To regulators and third-party auditors when required by law. • At times, outside service providers (i.e. – accountants, lawyers, consultants, etc.) may review Nonpublic Personal Information. Such firms must sign a Non-Disclosure Agreement. YCC will review the firm’s Privacy Policy to prevent misappropriation of client Nonpublic Personal Information and/or to avoid contradictions to YCC’s Privacy Policy. 8  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 • YCC shall provide a Privacy Notice to clients (i.e. “natural persons”) upon inception of the • relationship and annually thereafter if required by law. YCC will record the dates we send our Privacy Notice to clients. In the event of a change to the Privacy Policy, YCC will provide its clients with a sufficient amount of time to opt out of any disclosure provisions. • Employees must report suspected Privacy Policy breaches to the CCO and/or the Chairman. • • If an Employee receives a complaint regarding a potential identity theft issue (be it from a client or other party), the employee should immediately notify the CCO/Chairman. The CCO/Chairman will thoroughly investigate any valid complaint and maintain a log of all complaints as well as the result of any investigations. In the event that unintended parties receive access to Nonpublic Personal Information of California residents, YCC will promptly notify those clients of the privacy breach. See Senate Bill No. 1386. • YCC and its affiliates will destroy any obtained customer credit information when no longer needed to conduct its business. Item 12 – Brokerage Practices (A) Yale Capital Corp. (YCC) considers various factors when selecting or recommending a broker-dealer for client transactions and for determining their compensation (e.g., commissions): YCC participates in the Charles Schwab Institutional (“Schwab”) program, sponsored by Charles Schwab & Co. We recommend Schwab to clients in need of brokerage and custodial services. If a client does not direct YCC to use a particular broker or dealer, the adviser generally uses Schwab as its broker for trade executions. Other broker-dealers, including discount brokers, may charge higher or lower commission rates for identical or similar transactions. YCC considers the negotiated commission rates available through Schwab to be competitive, although there may be lower commission rates at other broker-dealers. YCC realizes benefits of being able, through direct computer access, to view and evaluate current client account positions held at Schwab, to process trades quickly and efficiently in client accounts, to execute cost-effective "block" trades on behalf of multiple clients, to receive consolidated client statements and confirmations, and year-end summaries, and to review and automatically download a wide range of information regarding client transactions. Schwab also has the capability of transacting and holding an extensive variety of mutual funds, including no load and institutional funds, in client accounts. Finally, Schwab directly debits YCC’s management fees from client accounts (providing client has provided on-going permission). For certain securities transactions, however, YCC may recommend other broker-dealers to process trades on behalf of clients. 9  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 As part of the Schwab program, YCC receives benefits that it would not receive if it did not provide investment advice to clients. While there is no direct affiliation between the investment advice given to clients and YCC’s participation in the Schwab program, economic benefits are received by YCC which would not be received if YCC did not have an established relationship with Schwab. Additional benefits to Schwab Institutional membership include: consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. In addition, Schwab may make available, arrange and/or pay for fees of a third-party providing these services to YCC. These benefits do not depend on the amount of transactions directed by YCC to Schwab, though YCC is required to maintain a minimum custody of $10,000,000 of client assets with Schwab to utilize Schwab Institutional. Benefits include: a dedicated trading desk that services YCC’s clients, a dedicated service group and an account service manager dedicated to YCC’s accounts, access to a real-time order matching system, research, pricing information and other market data, ability to block client trades, electronic download of trades, duplicate and batched client statements, confirmations and year-end summaries; the ability to have advisory fees directly debited from client accounts (in accordance with federal and state requirements), and the ability to have custody fees waived. 1. Research and Other Soft Dollar Benefits While YCC can access research, services, and products generally available to advisers through the Schwab Institutional website, the firm does not have any specific soft dollar arrangements for particular benefits. This means we do not mark up or mark down client commissions to obtain products, services, or research. Were YCC to engage in soft dollar arrangements with a broker, the benefits would not be limited to those clients who generated a particular benefit. 2. Brokerage for Client Referrals YCC does not currently receive client referrals from a broker-dealer in exchange for recommending a broker-dealer to clients. Were this to be the case, YCC would have to make additional disclosures concerning conflicts of interest and procedures concerning directing client transactions to broker-dealers in return for referrals. 3. Directed Brokerage YCC prefers clients utilize a broker with which the firm has an established relationship. While YCC is not affiliated with a particular broker-dealer, the firm uses Charles Schwab & Co. to custody client assets, transact journals and wires, and to execute trades. Should a client direct brokerage, it may not be possible to achieve the same timeliness/general level of service, or best execution as YCC may not be able to negotiate commissions or obtain volume discounts. When a client selects the broker to be used for his/her account, the client negotiates commission rates with his/her broker. Therefore, a disparity in commission charges may exist between the commissions charged to self-directed brokerage clients and clients who hold their assets at Charles Schwab & Co. 10  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 (B) Aggregate Orders YCC generally processes transactions for each client account independently; however, it may be advantageous to buy or sell a large quantity of securities, in which event and at our discretion,. we may combine or batch such orders to obtain best execution, and/or to negotiate more favorable commission rates or other transaction costs (that might not be available for independent orders). In these instances, we will average the price and transaction costs and allocate to client accounts according to the proportion of buy/sell orders placed in each client account. In the event that we decide not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, or the liquidity of the securities, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. (C) Trade Error Policy While YCC employees follow clear procedures to execute trades with accuracy, they may make errors in submitting a discretionary or client-requested trade order. When this occurs, YCC seeks to make client accounts "whole" again by placing a correcting trade with the broker-dealer that has custody of your account. If an investment gain results from the correcting trade, the gain will remain in your account (unless the same error involved other client account(s) that should have received the gain, it is not permissible for you to retain the gain) or we confer with you and you decide to forego the gain (e.g., due to tax reasons). If the gain does not remain in your account and Charles Schwab & Co. Inc. (“Schwab”) is the custodian, Schwab will donate the amount of any gain $100 and over to charity. If a loss occurs greater than $100, YCC will pay for the loss. Schwab will maintain the loss or gain (if such gain is not retained in your account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in your account, they are netted. In any trade error event, the client will incur zero costs for any error made by YCC. Moreover, YCC will not use "soft dollars" to correct trade errors. YCC also will not use future brokerage business to compensate a broker either directly or indirectly for absorbing the cost of correcting an error in an earlier transaction. YCC attempts to minimize trade errors by promptly reconciling confirmations with order tickets and intended orders, and by reviewing past trade errors to understand the internal control breakdown that caused any errors. (D) IPO Policy Occasionally, YCC may, to the extent allowable under FINRA rules, purchase equity securities that are part of an initial public offering (“new issues”) for client accounts. New issues shall, over time, be allocated to client accounts, on a roughly prorated basis, generally according to the assets under management. Sensitive allocation issues arise when YCC has the opportunity to participate in an offering that is expected to be over-subscribed, or to purchase a limited position in a security that might be appropriate for multiple advisory clients. Because hot issue premiums provide the potential of an immediate profit and since YCC typically receives only a small portion of the allotments sought, YCC 11  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 will exercise particular care in the allocation of these securities. YCC will prepare an Allocation Statement for IPOs that will clearly identify the proposed allocation for an IPO. In the event that an IPO is not suitable for certain clients, such clients will be excluded from the allocation. In addition, if a client is suitable but was not allocated a particular IPO due to the number of shares that were made available to YCC, then those clients will receive priority on the next IPO that YCC receives -- if the IPO is deemed by YCC to be suitable. Generally speaking, YCC will utilize a rotational methodology for allocating shares of new equity issues among eligible advisory accounts. In certain instances, YCC may execute over-the-counter securities transactions on an agency basis, which can result in advisory clients incurring two transaction costs for a single trade: a commission paid to the executing broker-dealer plus the market makers mark-up or mark-down. YCC will not receive any of these commissions. Item 13 – Review of Accounts (A) Yale Capital Corp. (YCC) reviews client accounts regularly to ensure appropriate allocation based on YCC’s assessments of market conditions and the circumstances of the client. YCC also monitors general conditions in the stock and bond markets. Chairman/Chief Investment Officer, Mr. Cheyne Pace, reviews all accounts. There is no set minimum or maximum in place with regard to the number of accounts that he will review. (B) Non-routine reviews and subsequent buy/sell recommendations occur when there are changes in client’s circumstances, changes in stock and bond market general conditions, and changes in mutual funds or individual securities owned by clients. (C) Clients should receive copies of all transaction confirmations and monthly statements directly from the custodian. YCC provides performance/account reviews on a quarterly basis, or as requested by the client. Additionally, YCC will provide customized reports according to the wishes and needs of the client; examples include income reports, realized gain/loss reports, and transaction ledgers. Item 14 – Client Referrals and Other Compensation (A) Yale Capital Corp. (YCC) receives economic benefit only from its clients and does not receive compensation from a third-party for providing advice to our clients. This is a cornerstone of our approach as we consider third-party payment to be a conflict of interest. YCC is an independent adviser, not affiliated with a broker-dealer and, thus receives compensation solely from its clients. (B) YCC has solicitor/referral agreements with third parties who refer YCC to prospective clients. For this service, we pay a commission percentage of the basic management fee to the third-party. The commission covers the referral provision, solicitation services and any costs incurred by these efforts; 12  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 this financial arrangement incurs no extra cost to the client and there are no manipulations made to management fees. Any sales information used by the solicitor is the responsibility of YCC. The solicitor does not provide investment advisory services. We fully disclose such arrangements to relevant clients and document their written acknowledgement of such disclosure. Item 15 – Custody Clients must receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains clients’ investment assets. Yale Capital Corp. (YCC) urges clients to carefully review such statements and compare such official custodial records to the account statements/reviews that we provide to you. Our statements vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. YCC is deemed to have custody when clients authorize it, via standing letters of instruction, to direct funds to third parties from their custodial accounts. In connection with standing letters of instruction, a client must provide signed written instruction to the custodian to direct transfers to a third-party, which the client may instruct the custodian to terminate or change at any time. YCC has no authority or ability to designate or change the identity of the third-party, the address, or any other information about the third-party contained in the client’s instruction. The custodian will verify the instruction with an initial notice, provide the client with a transfer of funds notice promptly after each transfer, and an annual notice reconfirming the instruction. YCC and its employees cannot accept funds in connection with standing letters of instruction, nor can funds be delivered to locations where YCC conducts business. YCC has direct access to and the authority to obtain possession of client's funds or securities for client- related partnerships for which it acts as a general partner. This establishes a custody relationship for YCC. YCC has instituted procedures to ensure that all client funds and securities for these partnerships are maintained at a qualified custodian in a separate account. Clients receive confirmations and statements directly from the qualified custodian. YCC hires an independent public accounting firm to conduct an annual surprise verification examination. The purpose of this examination is to verify the funds and securities held in these accounts. Item 16 – Investment Discretion Yale Capital Corp. (YCC) usually receives discretionary authority from the client to select the identity and amount of securities to be bought or sold. In all cases, however, we exercise such discretion in a manner consistent with the stated investment objectives for the client account. The only limitations on YCC’s investment discretion will be those limitations imposed in writing by the client. YCC and the client may document investment guidelines or restrictions in writing. In order to provide YCC with the ability to trade in client accounts, clients sign the custodian’s applicable documents. The custodian will then permit YCC to trade, transfer funds between same-name accounts, and to deduct management fees. To transfer between accounts of different registrations, YCC must obtain signed client authorization. 13  Yale Capital Corp. www.yalecapitalcorp.com ADV Part 2A Brochure March 24, 2025 When selecting securities and determining amounts to buy or sell, YCC observes the investment policies, limitations, and restrictions of the clients for which it advises. For registered investment companies, YCC’s authority to trade securities are also limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Item 17 – Voting Client Securities It is the policy of Yale Capital Corp. (YCC) to vote client proxies in a way deemed in the interest of maximizing shareholder value. YCC will generally vote with the Board of Directors recommendations. If there is not a Board of Directors recommendation, YCC will, in most cases, abstain from voting. Any general or specific proxy voting guidelines provided by an advisory client or its designated agent in writing will supersede this policy. Clients may wish to have their proxies voted by an independent third- party or other named fiduciary or agent. Clients can opt to vote proxies themselves if they explicitly inform YCC in writing. YCC is not required to vote every client proxy, and such should not necessarily be construed as a violation of YCC’s fiduciary obligations. YCC shall at no time ignore or neglect its proxy voting responsibilities. However, there may be times when refraining from voting is in the client’s best interest. So long as there are no identified material conflicts of interest, YCC will vote proxies according to the policy set forth above. Absent special circumstances, which are fully described in YCC’s Proxy Voting Policies and Procedures, all proxies will be voted consistent with guidelines established and described in YCC’s Proxy Voting Policies and Procedures, as they may be amended from time-to-time. Clients may contact YCC to request information about how YCC voted proxies for their security investments or to get a copy of YCC’s Proxy Voting Policies and Procedures. Records of all proxy votes will be kept for a minimum of five years and will be made available to clients upon request by contacting us at (727)823-0006 or emailing us at info@yalecapitalcorp.com. Item 18 – Financial Information (A) Yale Capital Corp. (YCC) does not require prepayment of fees six months or more in advance; therefore, the firm does not include a balance sheet for the most recent fiscal year in this Brochure document. (B) YCC has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients. (C) YCC is not, and has not been, the subject of a bankruptcy petition. 14