This Disclosure document is being offered to you by Triumph Capital Management (“TCM”) in connection with the investment advisory services TCM provides. This ADV Part 2A discloses information about the services that are provided by TCM, its Investment Advisor Representatives (“IARs”), and the way those services are made available to you, the client. TCM is an investment management firm with office sites located in Denver, CO; Louisville, CO; and Malibu, CA. TCM’s headquarters is located at 1610 Wynkoop Street, Suite 550, Denver, CO 80202. TCM specializes in investment advisory services for individuals, families, trusts, estates, retirement accounts, pension plans, and profit-sharing plans. The firm was established by Mr. Derek Eichenwald, the firm’s principal owner, in 2016. TCM is committed to helping clients build, manage, and preserve their wealth by providing strategic assistance to help clients achieve their stated financial goals. TCM may offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and TCM execute an engagement letter or one of TCM’s client agreement forms.
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• GoToStage: www.gotostage.com/channel/bcff543de66d4168a9b1a0e29c79e752 Investment Management and Supervision Services TCM offers discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. These services include investment analysis, allocation of investments, quarterly and monthly portfolio statements, financial commentaries, and ongoing monitoring of client portfolios. TCM will help in determining your portfolio composition based on your needs, portfolio restrictions, if any, financial goals, and risk tolerances. TCM will work with you to obtain necessary information regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This information enables TCM to determine the portfolio best suited for your investment objectives and needs. While performing services, TCM shall not be required to verify any information received from you or from other professionals about you. If you request, TCM may recommend and engage the services of other professionals for implementation purposes. You have the right to decide whether to engage the services of any such recommended professional. Once TCM has determined the types of investments to be included in your portfolio and allocated them, TCM will then provide ongoing portfolio reviews and management services to you. This approach requires us to periodically review your portfolio. TCM’s advisory services are tailored to meet the needs of its clients and seek to ensure that client portfolios are managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with TCM to refrain from investing in industries or invest in limited amounts of securities in the investment management agreement. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. TCM has limited authority to direct the custodian to deduct our investment advisory fees from your account(s). Only with the appropriate authorization, as indicated on your client agreement with TCM, can such fees be deducted. You are advised and are expected to understand TCM’s past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect an account’s performance. This could result in capital losses in your account. Risks are further described in Item 8 of this Brochure. For assets held in a multi-participant 401(k) account, TCM offers discretionary investment consulting. In these accounts, the client retains the right to act or not to act on the recommendations made by TCM. TCM’s advisory services are limited to recommendations for the purchase of investments for your account or sale of investments in your account, which in each case TCM believes would be appropriate for your account considering the agreed-upon investment objectives, risk tolerance, and restrictions if applicable. The client acknowledges that they are responsible for all purchases and sales made in their account(s). You should be aware the compensation to TCM and your IAR will diverge per the advisory program chosen. This compensation to TCM and your IAR may be more than the amounts TCM would otherwise receive if you participated in another program. Because of the differences in fee schedules among the various advisory programs and services offered by TCM through your IAR, there is a financial incentive to recommend a program or service over another program or service offered. Additionally, TCM has a financial incentive to recommend rolling over assets not managed by TCM to accounts that are managed by TCM and its IARs. This presents a conflict of interest because there may be an incentive to make recommendations based on the amount of compensation that TCM will receive rather than based on your needs. Your IAR will explain the specific costs of all programs recommended to you and it will also be outlined in your agreement with TCM. Managed by Triumph Capital Management at Security Benefit The Managed by TCM at Security Benefit Program utilizes six models to manage client accounts that are opened and held at Security Benefit. The mutual funds that are available on the Security Benefit platform will be the only options available in the allocation mix of these models. On a monthly basis, the models are reviewed, and the investments inside of the model are reallocated. However, the models may remain the same and may not be reallocated at the discretion of the manager and his/her team if they determine that the current allocation is appropriate. Tactical Model at Security Benefit: The Tactical model at Security Benefit seeks to provide absolute returns during any market cycle or condition by employing a strategic rotation model between commodities, REITs, bonds and other fixed income investments, international equities, domestic equities, and cash. Utilizing the funds available on the Security Benefit platform, the Tactical model will select and weigh heavily into a selection of asset classes from the categories listed above that TCM believes is experiencing the most strength, while attempting to avoid those asset classes which the manager and his/her team believe are in a downward trend or do not show as much promise to the upside. Conservative Model at Security Benefit: The Conservative model at Security Benefit seeks to protect principal over seeking appreciation. Utilizing the funds available on the Security Benefit platform, the Conservative model focuses on an investment strategy that emphasizes capital preservation and risk minimization through a diversified and balanced portfolio of commodities, REITs, bonds and other fixed income investments, international equities, domestic equities, and cash. Moderate-Conservative Model at Security Benefit: The Moderate-Conservative model at Security Benefit values principal preservation but will accept a small degree of risk and volatility to seek some degree of appreciation. The Moderate-Conservative model seeks to accept lower returns, while accepting minimal losses. Utilizing the funds available on the Security Benefit platform, the Moderate-Conservative model focuses on an investment strategy through a diversified and balanced portfolio of commodities, REITs, bonds and other fixed income investments, international equities, domestic equities, and cash. Moderate Model at Security Benefit: The Moderate model at Security Benefit seeks to reduce risks and enhance returns equally. The Moderate model accepts modest risks to pursue higher long-term returns and may endure a short-term loss of principal in exchange for long-term appreciation. Utilizing the funds available on the Security Benefit platform, the Moderate model focuses on an investment strategy through a diversified and balanced portfolio of commodities, REITs, bonds and other fixed income investments, international equities, domestic equities, and cash. Aggressive-Moderate Model at Security Benefit: The Aggressive-Moderate model at Security Benefit values higher long-term returns and is willing to accept significant risk. The Aggressive-Moderate model is willing to endure large losses in favor of potentially higher long-term returns. Utilizing the funds available on the Security Benefit platform, the Aggressive-Moderate model focuses on an investment strategy through a diversified and balanced portfolio of commodities, REITs, bonds and other fixed income investments, international equities, domestic equities, and cash. Aggressive Model at Security Benefit: The Aggressive model at Security Benefit seeks to maximize returns and is willing to accept substantial risk. The Aggressive model is willing to risk losing money to achieve potentially better results. Utilizing the funds available on the Security Benefit platform, the Aggressive model focuses on an investment strategy through a diversified and balanced portfolio of commodities, REITs, bonds and other fixed income investments, international equities, domestic equities, and cash. All six models involve risk including the loss of principal. Past performance is not a guarantee of future results. The Managed by TCM at Security Benefit models may not achieve their goals. Market and economic risk may adversely affect the Managed by TCM at Security Benefit models that could result in capital losses in your account. Investing involves risk of loss which you should be prepared to bear. Please consider the charges, risks, expenses, limited investment options, and your overall objectives carefully before investing in any of the Managed by TCM at Security Benefit models. The mutual funds, ETFs, and/or sub-accounts that are available on the Security Benefit platform will be the only options available in the allocation mix in these models. The Managed by TCM at Security Benefit models are not intended to manage all client assets or to address all of their needs. The models intend to provide clients, who are suitable and have a covered account with Security Benefit, options for managing those assets. Accounts enrolled in the Managed by TCM at Security Benefit program will be managed inside of the model selected on the client agreement but may change based on the client’s ongoing investment objectives and goals. Model allocations are not personalized to individual investors. Accounts in the Managed by TCM at Security Benefit models are custodian with Security Benefit. Clients should receive at least quarterly statements from Security Benefit. TCM urges you to carefully review these statements and compare them to the account statements that TCM may provide you, if applicable. You should verify that the transactions in your account are consistent with your investment goals and the objectives for your account. TCM also encourages you to contact your IAR or our Chief Compliance Officer should you have any questions or concerns regarding your account. The Managed by TCM at Security Benefit Program is limited in nature and is not intended to address all your advisory needs. Additional services are available by separate agreement. Please review this brochure thoroughly and consult with your IAR about the additional services that are available to you. Inclusion in this program is limited and subject to TCM’s discretion. TCM may prohibit any person from participating for any reason or no reason at all. Third Party Asset Managers TCM provides investment advice and recommendations on the investment strategies of Third-Party Asset Managers (“TPAM” or “Managers”). Selected Managers are evaluated by TCM for client use. TCM’s services include assisting you in identifying your investment objectives and matching personal and financial data with a select list of Managers. The intent of this service is to have a selected list of high- quality third-party investment management firms from which TCM selects one or more Managers to handle the day-to-day management of your account(s). TCM’s IARs assist you with identifying your risk tolerance and investment objectives. IARs will recommend Managers in relation to your stated investment objectives and risk tolerance. TCM helps you select a recommended Manager based upon your needs. TCM may act in either a “Manager of Managers” or “sub-advisor” capacity when it offers TPAM programs to you. Managers selected for your investments need to meet several quantitative and qualitative criteria established by TCM. Among the criteria that may be considered are the Manager’s experience, assets under management, performance record, client retention, the level of client services provided, investment style, buy and sell disciplines, capitalization level, and the general investment process. You are advised and should understand that:
• A Manager’s past performance is no guarantee of future results.
• There is a certain market and/or interest rate risk which may adversely affect any Manager’s objectives and strategies, and could cause a loss in a client's account(s); and
• Client risk parameters or comparative index selections provided to TCM are guidelines only, and there is no guarantee that they will be met or not be exceeded. TCM’s IARs shall be available to answer questions you may have regarding your account and act as the communication conduit between you and the Manager. Managers may take discretionary authority to determine the securities to be purchased and sold for the client. Information collected by TCM regarding Managers is believed to be reliable and accurate, but TCM does not necessarily independently review or verify it on all occasions. Performance reports may be produced by the respective Manager. Such performance reports will be provided directly to you and TCM. TCM does not audit or verify that these results are calculated on a uniform or consistent basis as furnished by a Manager directly to TCM or through

the consulting service utilized by the Manager. However, TCM does monitor the results of the Manager. TCM has entered into agreements with various independent program Managers. Under these agreements, TCM offers clients various types of programs sponsored by these Managers. All TPAMs to whom TCM will refer you will be licensed as investment advisors by your resident state and any applicable jurisdictions or registered investment advisors with the Securities and Exchange Commission. TPAMs generally have account minimum requirements that will vary from investment advisor to investment advisor. A complete description of the Manager’s services, fee schedules, and account minimums will be disclosed in the Manager’s Form ADV or similar disclosure brochure which will be provided to clients before an agreement for services is executed and the account is established. Manager of Managers: When acting as a Manager of Managers for the TPAM program, your IAR assists you in selecting one or more TPAM programs believed to be suitable for you based on your stated financial situation, investment objectives, and financial goals. TCM and your IAR oversee your investment with the TPAM. TCM can track the performance of each Manager and has the authority to fire ineffective Managers and hire replacements on your behalf. TCM and your IAR are compensated for referring you to the TPAM program. This compensation generally takes the form of the TPAM sharing a percentage of the advisory fee you pay to the TPAM with TCM and your IAR. You will receive a written disclosure statement describing the nature of our relationship with the TPAM program, if any; the terms of our compensation arrangement with the TPAM program, including a description of the compensation that TCM will receive for referring you to the TPAM program; and the amount, if any, that you will be charged in addition to the advisory fee that you will pay to the TPAM as a result of our referral of you to the TPAM program. As part of establishing a new account, you will receive TCM’s disclosure brochure as well as the TPAM’s disclosure brochure. Advisor of Sub-Advisor: Under an advisor or sub-advisor relationship between TCM and the sponsor of the TPAM program, TCM and the sponsor are jointly responsible for the ongoing management of the account. Your IAR is responsible for assisting you with completing the investor profile questionnaire. While each TPAM may have a different name for the questionnaire, your responses will assist the IAR with understanding your investment objectives, financial situation, risk tolerance, investment time horizon and other personal information. Based on the information that you provide to the IAR, he or she will assist you in determining which TPAM model or portfolio strategy is appropriate for you. Triumph Turnkey Asset Management Program Similar to outside TPAMs, TCM offers Triumph Turnkey Asset Management Program (“TTAMP”) that is available to unaffiliated IARs, and licensed Financial Professionals (“FP”) to utilize when evaluating investment options for their clients. TCM IARs are also able to enroll their clients in the TTAMP. Inside and outside FPs and IARs can access TTAMP which provides model portfolios and other portfolio management solutions that are managed by TCM. Clients enrolled in the TTAMP will pay TCM a monthly or quarterly fee to cover the cost of administering the program and for providing portfolio management. A portion of the TTAMP fee may be shared with the account custodian for providing custody, clearing, and other services. TCM will typically not accept a client into the program that is not introduced by a FP or IAR. The services to be provided and the expectations of the client, FP, IAR, and TCM are outlined in the client agreement, which may be amended in writing from time to time. Clients are free to direct the account in any manner that meets their objectives to include determining the asset allocation, models that may be used, as well as any restrictions the client wishes to place on the account. Full model allocation may be limited due to account size. Small account values may result in allocation variances that deviate from the intended TTAMP model. The introducing FP or IAR serves as a liaison between TCM and the client, and is responsible for gathering and communicating the client’s financial information, risk tolerance, and investment objectives. Clients grant TCM discretionary authority to place trades for the account and when appropriate – relative to the client’s investment objectives or any restrictions placed on the account by the client – to make changes to the asset allocation or model selection. By executing a Limited Power of Attorney, clients may also grant their FP or IAR the authority to effect changes to the account such as the model selection. Once an account is established, TCM continuously monitors the asset allocation and/or models and executes trades for the account. The FP or IAR will continue to service the client relationship by meeting with the client at least annually and communicating to TCM any necessary changes to the client’s account. For these reasons, the client should acknowledge information sharing between the FP, or IAR and TCM, which can include personal non-public information. FPs and IARs may provide other clerical or administrative duties for the client’s account and may also provide other services outside and in addition to the services offered through the program. This brochure describes the products and services offered by TCM and its IARs only. Since FPs and IARs may offer other third-party services in conjunction with, or outside those provided through the program, clients should read and review the introducing firm’s disclosure brochure to fully understand the services being rendered to the client by the introducing firm through the FP or IAR. You should be aware that the compensation to TTAMP and your IAR may be more than the amounts you would otherwise pay if you participated in another TPAM program. Because of the differences in fee schedules among the various advisory programs and services offered by TCM through your IAR, there is a financial incentive to recommend the TTAMP service over another TPAM program or service. This presents a conflict of interest because there may be an incentive to make recommendations based on the amount of compensation that TCM and the IAR receive rather than based on your needs. Your IAR will explain the specific costs of all programs recommended to you, and it will also be outlined in your agreement with TCM. Client Information Provided to Portfolio Managers and Client Contact Non-public information is information about you not accessible to the public. Your social security number, net worth, and annual income are examples of non-public information. Public information is information about you readily accessible to the public. Public information may include your name, phone number, and address. For all accounts, including those in the programs described in this brochure, your IAR will have access to the non-public information provided by you in the account opening process. This information is protected in accordance with TCM’s Privacy Policy. TCM’s Privacy Policy is available on TCM’s website and is provided upon opening your account and annually thereafter. Retirement Plan Advisory Services Retirement Plan Advisory Services consist of assisting employer plan sponsors to establish, monitor, and review their company's retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment selection and monitoring, plan structure, and participant education. TCM will help establish your plans needs and objectives through an initial meeting to collect data, review plan information, and assist you in developing or updating the plans provisions. Ongoing services to you may include recommendations regarding the selection and review of unaffiliated mutual funds, ETFs, and other investment products that, in TCM’s judgment, are suitable for the investment of plan assets. TCM will periodically review the investment options you select and make recommendations to keep or to replace plan investment options as TCM feels appropriate. TCM will perform a comprehensive review of potential service providers or vendors and will assist you with converting from your incumbent service provider to a new service provider selected by you. You are under no obligation to follow the recommendations that TCM may make. Services available under an investment advisory agreement may permit TCM to provide financial education to your plan participants. The scope of education provided to participants at your request will not constitute “investment advice” within the meaning of ERISA, and participant education will relate to general investment principles and information about the investment options currently in the plan. TCM may also participate in initial enrollment meetings, periodic workshops, and future enrollment meetings for new participants as agreed upon. All Retirement Plan Advisory Services shall be in compliance with all applicable Federal and State law(s) regulating the services provided by our agreement. This section applies to an account that is a pension or other employee benefit plan governed by ERISA. If your account is part of a qualified plan and TCM accepts appointments to provide our services to your account, TCM acknowledges that it is a fiduciary within the meaning of Section 3(21) of ERISA and within the meaning of Section 4975 of the Internal Revenue Code. Furthermore, TCM agrees to comply with the Department of Labor’s Impartial Conduct Standards which is implemented and enforced through TCM’s Code of Ethics. Self-Directed Brokerage Accounts A Self-Directed Brokerage Account (“SDBA”) is a brokerage window that allows participants to select investment options outside of their employer’s core offerings while staying within the plan and receiving the associated tax benefits. SDBAs provide more flexibility and control, enabling diversified, targeted and strategic retirement investing. The SDBA is for investors who acknowledge and understand the risks associated with many of the investments contained in the SDBA. Your IAR will work with you to identify your investment goals and objectives, as well as risk tolerance, in order to create a portfolio allocation designed to meet your objectives while staying within any plan specific restrictions. Advisory accounts typically involve the purchase and/or sale of securities. These accounts are managed on a discretionary or non-discretionary basis based on the plan and the participant’s needs. Many SDBAs prohibit the following:
• Selling short or using margin
• Trading in foreign securities (stocks, bonds)
• Trading in bulletin board or pink sheet stocks
• Trading real estate/property outside of approved REITs
• Trading currencies
• Trading limited partnerships
• Trading futures/commodities
• Trading promissory notes
• Trading collectibles
• Trading municipal bonds Financial Planning Services Financial advisory services provided by TCM will include the analysis of your financial situation and assistance in identifying and implementing appropriate financial planning and investment management techniques to help you meet your specific financial goals and objectives. Such services will include a written financial analysis and specific or general investment and/or planning recommendations. In preparing your financial plan, TCM may address five areas of financial planning. These include financial planning, money management, tax, estate and insurance planning. Our specific services in preparing your plan may include:
• Review and clarification of your financial goals and objectives.
• Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning.
• Creation of a unique plan for each goal you have including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals.
• Development of a goal-oriented investment plan around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, as well as taxable and trust accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as a tax advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death.
• Generation of a benefits plan, risk management plan, and succession plan for your business, if applicable. Should you choose to implement the recommendations contained in the plan, TCM suggests that you work closely with your attorney, accountant, insurance agent, and IAR/stockbroker. Implementation of financial plan recommendations is entirely at your discretion. Consulting Services TCM also provides clients investment advice on a more limited basis in one or more isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, TCM may provide advice on non-securities matters in connection with the rendering of estate planning, insurance, real estate, and/or annuity advice. In these instances, you may be required to select your own investment managers, broker-dealer, and/or insurance companies for the implementation of consulting recommendations. If your needs include brokerage and/or other financial services, TCM may recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies, or other FPs. You must independently evaluate these firms before opening an account or transacting business and have the right to affect business through any firm you choose. You are under no obligation to follow the consulting advice that TCM provides. Wrap Fee Programs TCM’s portfolio management services utilize a wrap fee program. Wrap fee programs allow the client to pay a comprehensive fee for management, brokerage, clearing, custody, and administrative services. TCM will receive a portion of the wrap fee for its services. Assets As of March 14, 2024, TCM has $421,132,382 in discretionary assets under management. TCM does not have any non-discretionary assets under management.