ABOUT DGS CAPITAL MANAGEMENT, LLC DGS Capital provides direct indexing services to individuals and institutions through intermediaries such as wealth managers, RIAs, and multi-family offices. The firm's direct indexing offerings specialize in tax-efficient, factor-based, and values-based investing. DGS offers turnkey asset management services (TAMP) for a subset of clients and manages domestic fixed-income portfolios. DGS Capital Management was founded in 2016 and is structured as an LLC registered in Delaware. Ashish Sharma solely owns DGS Capital Management. Ownership interests are outlined in Part 1 of Form ADV. TYPE OF ADVISORY SERVICES Direct Indexing DGS provides discretionary direct indexing equity strategies with three key focus areas: 1) Tax-managed investing 2) Factor-based investing 3) Values-based investing The direct indexing strategies offered by DGS provide three primary benefits relative to mutual funds and ETFs: improved after-tax returns, systematic and low-cost approach to factor-based and values-based investing, and client- specific customizations. The strategies managed by DGS aim to either track the returns of a broad market-based index (the benchmark index) or outperform the relevant benchmark on a risk-adjusted basis using investment styles including, but not limited to, quality, value, and low volatility. In addition to the standard, pre-configured set of direct indexing strategies that DGS offers, clients can tailor the strategy to meet their needs and requirements. These customizations may include restrictions against certain companies, elimination of or adjustment to specific industries/sectors/countries, including factor tilts, or adding customized values-based constraints (also called environmental, social, and governance - or ESG - investing). Each strategy has its own expected risk and return characteristics relative to broad market indices, and clients may select investment strategies consistent with their requirements and objectives. DGS helps intermediaries and their clients select the investment strategy that would best serve their specific needs. Once the Client has chosen the investment strategy and target asset class, DGS is responsible for implementing the strategy and its ongoing management and supervision. Clients are free to change their strategy at any time by contacting DGS in writing and should also inform DGS if there are any changes to their investment objectives, goals, or constraints. DGS's direct indexing strategies form the core of its service offering. Please refer to Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss for more information regarding these strategies. Fixed Income Strategies DGS provides discretionary fixed-income separate account management for a limited number of clients. The primary focus area of fixed income separate account management is building treasury bond strategies. Once the clients have selected

the target duration for the portfolio, DGS is responsible for implementing the strategy and its ongoing management and supervision. Turnkey Asset Management Program DGS offers a turnkey asset management program ("TAMP") to select advisors currently utilizing DGS's direct indexing strategies or intend to use DGS's direct indexing strategies. In addition to managing the direct indexing strategies, DGS provides several other services related to investment management, trading, and operations. These may include, but are not limited to, the selection of ETFs, mutual funds, and other pooled investment vehicles, the creation of model portfolios, firm-wide rebalancing, ad-hoc trading, performance reporting, billing and fee calculation, and invoice generation. DGS does not provide these TAMP services in isolation. They are only offered to advisors currently using DGS's direct indexing strategies or those who intend to use them. There is no guarantee that DGS will accept the TAMP relationship, even for existing direct indexing strategy clients, and DGS determines eligibility on a case-by-case basis. For advisors offered the TAMP services, the primary advisor will work with the end client to determine the appropriate asset allocation and notify DGS of any adjustments that may be needed in the target asset allocation based on changes in the Client's investment goals, needs, or constraints. Wealth Management Services For a limited number of clients, DGS offers discretionary wealth management services. In addition to providing direct indexing strategies, these services may include asset allocation, security selection, and the purchase of publicly available mutual funds and ETFs. These services may also summarize a client's assets, liabilities, and current and anticipated income and expenditures. However, the wealth management services are not comprehensive and focus primarily on managing investment portfolios. DGS is currently not accepting any new wealth management relationships. Advisory Agreements Written and signed advisory agreements govern the terms and conditions of the relationship between DGS and the Client accounts that DGS manages. DGS uses two types of agreements: Sub-Advisory Agreements and individual Investment Advisor Agreements. RIAs and wealth managers ("Intermediaries") acting as the primary advisor on a client account enter into a master Sub- Advisory agreement with DGS when DGS is selected to manage portfolios for the Intermediaries' clients as a sub- advisor. The Intermediaries are responsible for providing the Client with DGS's ADV and the master Sub-Advisory Agreement before the Client signs the LPOA forms that grant DGS trading authority to manage the account on a sub- advisory basis. Client accounts not managed on a sub-advisory basis enter into an individual Investment Advisory Agreement with DGS. As of 03/29/2024, DGS has $446,675,066 assets under management on a discretionary basis.