Description of Firm CYStein Management LLC is a Mexico-based registered investment advisor that completed its Delaware limited liability company filing during August of 2017. Typically operating under the trade name CYStein, the firm is not a subsidiary of nor does it control another financial services industry entity. CYStein became registered as an investment advisor with the United States Securities and Exchange Commission (SEC) in November of 2017. The firm may notice-file (register) or meet exemptions to registration in other jurisdictions in which investment advisory business is conducted. Pedro I. Padierna, is the firm’s Chief Compliance Officer (supervisor), Chief Executive Officer, Managing Member and maintains 50% of the controlling interest in the firm. Additional information about Mr. Padierna and his background may be found in his Form ADV Part 2B brochure supplement. Pedro Padierna Sr., is the firm’s Chief Marketing Officer, Managing Member and maintains the other 50% of the controlling interest in the firm. Description of Services CYStein provides ongoing supervision of its clients’ portfolios as well as educational seminars involving a broad range of investing topics. Our firm does not offer traditional financial planning services, serve US retirement accounts, or sponsor or serve as a portfolio manager in an investment program involving wrapped (bundled) fees. As of our last fiscal year end, our firm managed $4.2 million USD1 of client assets on a discretionary basis. An initial interview with the client is conducted to discuss their current situation, goals and the scope of services that may be provided by our firm. Prior to or during this first meeting the client will be provided with this Form

ADV Part 2 firm brochure that includes a statement involving the firm’s privacy policy, as well as a brochure supplement about the firm’s representative serving the client. Any material conflicts of interest will be disclosed involving the firm and its associates that could be reasonably expected to impair the rendering of unbiased and objective advice; such as information found in Items 10 and 11 of this brochure. Our portfolio management services focus on long term investing with low turnover; we do not attempt to time markets. Holdings are oriented toward low cost, widely traded securities that provide adequate diversification. 1 Rounding per the SEC’s General Instructions for Part 2 of Form ADV. Page 5 of 18 We begin with the development of investment guidelines that reflect the client’s objectives, time horizon, tolerance for risk, as well as any reasonable account constraints involving their portfolio. For example, the client has the right to exclude certain securities (e.g., derivatives, “sin stocks,” etc.) at their discretion. Portfolio guidelines will be designed to be specific enough to provide future guidance while allowing flexibility to work with changing market conditions. Our firm will then develop a customized portfolio for the client based on their unique situation, and involve the employment of investment strategies and vehicles detailed in Item 8 of this brochure. Client portfolios are managed by the firm on either a discretionary or nondiscretionary basis (defined in Item 16). CYStein educational seminars are complimentary and topics include investment strategies and current economic events. Events are educational in nature and do not involve the solicitation of insurance or investment products.