ABOUT OUR FIRM This Disclosure document is being offered to you by Alpha Capital Management Group, LLC (“Alpha Capital”) in connection with our investment advisory services. It discloses detailed information about our services and how they are made available to you, the Client. We are an investment management Firm located in Colorado and have been registered with the SEC since May 2016. We provide investment advice to individuals, high-net-worth individuals, estates, trusts, and small and medium-sized businesses with employer-sponsored retirement plans. GC Capital, LLC, Elevate Wealth Management, LLC, and Business Wealth Strategies, LLC own the Firm. Mark Ell, Garrison Campbell, and Ian Campbell are indirect owners of Alpha Capital Management Group, LLC through the aforementioned entities. We are committed to helping Clients build, manage, and preserve their wealth and providing assistance to help Clients achieve their stated financial goals. We will offer an initial complimentary meeting at our discretion; however, investment advisory services are initiated only after you and Alpha Capital execute an engagement letter or Client agreement. INVESTMENT MANAGEMENT & FINANCIAL PLANNING SERVICES We offer discretionary and non-discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management or on a flat dollar fee. These services include investment analysis, allocation of investments, quarterly portfolio statements, financial commentaries, financial planning services (as described below), and ongoing monitoring of client portfolios. We primarily allocate client assets among various mutual funds, cash, and other public and private securities or investments, exchange-traded funds (“ETFs”), and individual debt (bonds) and equity securities in accordance with their stated investment objectives. All of which are considered asset allocation categories for the client’s investment strategy. We 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 us to determine the portfolio best suited for your investment objective and needs. In performing our services, we shall not be required to verify any information received from you or from other professionals. If you request, we may recommend and/or 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 we have determined the types of investments to be included in your portfolio and allocated them, we will provide ongoing portfolio review and management services. This approach requires us to review your portfolio at least quarterly. We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios and rebalance them on a discretionary basis based on our market views and on your objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. PART 2A. V.|3.2024 - PAGE | 6 In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate authorization from you. Where appropriate, we may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage us to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our 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. Through your individual Private Financial Website supported by e-Money, our firm is able to conduct an analysis of your current situation and identify appropriate financial planning and investment management techniques to help you to meet your specific financial objectives. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, answers to outside assets and periodic updates. In preparing your analysis, we may address any or all of the six areas of financial planning established by the National Endowment for Financial Education and endorsed by the Certified Financial Planner Board of Standards, depending on your specific needs. These include financial position, protection planning, investment planning, income tax planning, retirement planning, and estate planning. ADMINISTRATIVE SERVICES PROVIDED BY ORION ADVISOR SERVICES, LLC We have contracted with Orion Advisor Services, LLC (referred to as “Orion”) to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, Client database maintenance, quarterly performance evaluations, payable reports, web site administration, models, trading platforms, and other functions related to the administrative tasks of managing Client accounts. Due to this arrangement, Orion will have access to Client accounts, but Orion will not serve as an investment advisor to our Clients. Alpha Capital and Orion are non-affiliated companies. EMONEY ADVISOR PLATFORM Our Firm makes available to Clients the “eMoney Advisor” through your individual Private Financial Website platform to provide periodic comprehensive reporting services that can incorporate all the Client’s investment assets, including those investment assets that are not part of the assets managed by our Firm (“Excluded Assets”). The Client and their other advisors who maintain trading authority, not our Firm, shall be exclusively responsible for the investment performance of the excluded assets. Unless otherwise expressly agreed to in writing, our Firm’s service relative to the excluded assets is limited to reporting only. Therefore, we shall not be responsible for the investment performance of the excluded assets. Instead, the Client and the Client’s designated outside investment professional(s) maintain supervision, monitoring, and trading authority for the excluded assets. If our Client prefers, we’ll make recommendations as to any excluded assets, the Client has no obligation to accept the recommendation, and we shall not be responsible for any implementation error (timing, trading, etc.) PART 2A. V.|3.2024 - PAGE | 7 relative to the excluded assets. The Client may engage us under the terms and conditions of a Consulting or Investment Advisory Agreement between our Firm and the Client. eMoney Advisor Platform may also provide access to other types of information, including financial planning concepts, which should not be construed as our Firm’s personalized investment advice or recommendations. We shall not be held responsible for any adverse results a Client may experience if the Client engages in financial planning or other functions available on the eMoney Advisor Platform without our assistance or oversight. If engaged in Investment management, our Firm may include financial planning services. Our specific services in preparing your plan may include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position, including cash flow, balance sheet, investment strategy, risk management, and estate planning.
• Create 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, qualified plans, and taxable and trust accounts that require special attention.
• Design a risk management plan that includes risk tolerance, risk avoidance, mitigation, transfer, liquidity, and various insurance and possible company benefits.
• In conjunction with your estate and/or corporate attorneys as tax advisor, crafting and implementing 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. ALPHA INTELLIGENT PORTFOLIO SERVICES We offer an automated investment program through which Clients are invested in various investment strategies we have constructed and managed, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. The Client may instruct us to exclude up to three ETFs from their portfolio. The Client’s portfolio is held in a brokerage account opened by the Client at Charles Schwab & Co., Inc. (“Schwab”). We use the Institutional Intelligent Portfolios® platform (“IIPP”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Schwab, to operate

the automated investment program. We are independent of and not owned by, affiliated with, sponsored, or supervised by SPT, Schwab, or their affiliates (together, “Schwab”). We, and not Schwab, are the Client’s investment advisor and primary point of contact with respect to the automated investment program. We are solely responsible, and Schwab is not responsible for determining the appropriateness of the automated investment program for the Client, choosing a suitable investment strategy and portfolio for the Client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the IIPP, which consists of technology and related trading and account management services for the automated investment program. The IIPP enables us to make the automated investment program available to Clients online. It also includes a system that automates key parts of our investment process (the “System”). The System includes an online PART 2A. V.|3.2024 - PAGE | 8 questionnaire that helps us determine the Client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the Client’s answers to the online questionnaire. The Client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio. As the listed Adviser on the account, our Firm has the ability to select a portfolio that may be more suited to the Client’s objective based on the research and information regarding the Client’s financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. The System also includes an automated investment engine through which we manage the Client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the Client is eligible and elects). RETIREMENT PLAN ADVISORY - PLAN LEVEL ADVISORY SERVICES Our Services include helping employer plan sponsors 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. Pursuant to Section 402(c)(3) of ERISA, the Client may appoint us as the Plan’s “investment manager” with respect to the Plan’s portfolio of investment options. We acknowledge that we are registered as an investment adviser under the State Securities Statutes. Our Firm acts as a “fiduciary” within the meaning of Section 3(21) and 3(38) of ERISA with respect to the Plan. We offer advisory services to employer-sponsored retirement plans such as 401(k), 457, 403(b), and ROBS Plans (Rollovers as Business Start-Ups). On the plan level, we manage the investment line-up, making necessary changes and providing risk-based investment models for the participants. On the individual participant level, we manage risk-based models using the current investment lineup based on the individual investor's risk tolerance. For employer-sponsored retirement plans with participant-directed investments, our Firm provides its advisory services as an investment advisor as defined under Section 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(21) investment advisor, the plan sponsor and our Firm share fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Investment Adviser Agreement between our Firm and the plan sponsor. We may provide the following services to our plan sponsor Clients: assist plan sponsors in developing an Investment Policy Statement (“IPS”), provide ongoing investment monitoring and recommendations, assist in designating Qualified Default Investment Alternative and Non-Discretionary Model Portfolios, and provide Performance Reports. Our Firm may perform the following Plan Consulting services: serve as service provider liaison, provide education services to the Plan Committee, conduct Participant Enrollment, and provide Plan Search Support/Vendor Analysis. Adviser may provide these services or arrange for the Plan’s other providers to offer these services, as agreed upon between Adviser and Client. We are granted full trading authority over the Plan when serving in a 3(38) appointment. We are responsible for selecting and monitoring all investment options offered under the Plan per the investment policy statement and its underlying investment objectives and strategies for the Plan. Plan participants have the ability to exercise control over the investment selection from the plan lineup of investments, and we have no authority or discretion to direct the investment of assets of any participant’s account under the Plan. PART 2A. V.|3.2024 - PAGE | 9 RETIREMENT PLAN ADVISORY - PARTICIPANT LEVEL ADVISORY SERVICES We can also be engaged in providing financial education to plan participants. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA, and participant education will relate to general principles for investing and information about the investment options currently in the plan. We may also participate in initial enrollment meetings, periodic workshops, and enrollment meetings for new participants. DISCLOSURE REGARDING OUR FIRM’S POLICY ON PROVIDING EDUCATION ONLY REGARDING ROLLOVERS A Client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the Client’s age, result in adverse tax consequences). Our Firm will educate clients to consider all options and will not provide recommendations. Regarding rollovers, Clients and/or prospects will independently determine whether to proceed with transferring the assets to an IRA-managed advisory account. CONSULTING SERVICES We also provide Clients with investment advice on a more limited basis on one or more isolated areas of concern, such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we may advise on non-securities matters concerning the rendering of estate planning, insurance, real estate, and/or annuity advice. In these cases, you may be required to select your investment managers, broker-dealer and/or insurance companies to implement consulting recommendations. If your needs include brokerage and/or other financial services, we may recommend using one of several investment managers, brokers, banks, custodians, insurance companies, or other financial professionals ("Firms"). You must independently evaluate these Firms before opening an account or transacting business, and you have the right to effect business through any Firm you choose. You are under no obligation to follow the consulting advice that we provide. WRAP FEE PROGRAM Alpha Capital is the sponsor and manager of the Alpha Capital Wrap Program (the “Program”), a wrap fee program (i.e., an arrangement where the Firm absorbs brokerage commissions and transaction costs). The fee covers transaction costs or commissions resulting from managing your accounts; however, most investments trade without transaction fees today, so our payment of these and other incidental custodial- related expenses should not be considered a significant factor in determining the relative value of our wrap program. Participants in the Program may pay a higher aggregate fee than if brokerage services are purchased separately. Additional information about the Program is available in Alpha Capital’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV. We adhere to our fiduciary duty when trading in your accounts. Trades are made only based on the account’s stated investment objectives and without concern for the Firm’s trading costs and expenses that trading the accounts will create. We will fulfill our fiduciary duty by acting in the Client’s best interest to mitigate this conflict of interest. PART 2A. V.|3.2024 - PAGE | 10 Under LPL’s SWM II program, you will receive investment advisory services, the execution of securities brokerage transactions, custody, and reporting services for a single specified fee. The terms and conditions of a wrap program engagement are more fully discussed in LPL’s Disclosure Brochure, which was provided prior to opening your account. The “wrap” fee program at LPL may be more or less than the fees and commissions charged by other advisory Firms, third-party managers, and brokerage Firms if the services were acquired separately. The factors that bear upon the cost of services are the account size, the type of transaction, and whether trades are placed through a brokerage Firm other than the custodian, resulting in charged per-trade commissions. REGULATORY ASSETS UNDER MANAGEMENT As of December 31, 2023, our Firm has a total of $421,922,654 assets under management. We have $102,607,220 under discretionary management and $319,315,434 under non-discretionary management.