A. Firm Information Capital CS Group, LLC (“CCSG” or the “Advisor”) is an SEC registered investment adviser. CCSG is organized as a limited liability company under the laws of the State of California. CCSG was founded in 2019 and has been in business as an investment adviser since that time. CCSG is owned by Jessica McConnell and Todd Carbone. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by CCSG. For questions regarding this Disclosure Brochure, please contact Jessica McConnell, Chief Compliance Officer at (844) 390-2797. B. Advisory Services Offered CCSG offers investment advisory services to high-net-worth individuals, families, trusts, estates, and businesses (each referred to as a “Client”). CCSG provides comprehensive investment management, planning and consulting services tailored to the individual needs of each Client. Investment Advisory Services CCSG provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management, planning and related advisory services. CCSG typically offers these as a bundled advisory engagement, but may, in certain circumstances, offer as individual services. CCSG works closely with each Client to develop an investment strategy that seeks to achieve the goals of the Client. Investment Management CCSG customizes its investment management services for its Clients. Portfolios are primarily constructed using mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. For certain Clients, the Advisor may also utilize alternative investments and other types of investments, as appropriate, to meet the needs of particular Clients. For some Clients, CCSG has the ability to employ a hedging strategy involving concentrated or restricted stock positions held at a Custodian. The Advisor generally constructs portfolios in alignment with its internal strategies but may retain legacy securities due to portfolio fit and tax considerations. CCSG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. CCSG’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. If it is consistent with the Client’s goals, the Advisor may also engage in an investment strategy that utilizes frequent trading in securities, please see Item 8 for more information. CCSG will construct, implement and monitor the Client’s portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. CCSG, in its discretion, may redistribute investment allocations to diversify the portfolio. CCSG may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. CCSG may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. CCSG will provide investment management and related advisory services. At no time will CCSG accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees and dispersing client funds to a third party under a standing letter of instruction. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the investment advisory agreement. CCSG serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. CCSG will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. CCSG will continue to provide Page 5 oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. CCSG does not receive any compensation from these Independent Managers or Investment Platforms, other than its investment advisory fee (described in Item 5). *Use of Pontera® to manage assets “held away”: We provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. Portfolio Monitoring CCSG may also provide for general asset allocation guidance within parameters of a plan held with outside custodians. This guidance is solely consultative in nature and involves no on-going supervision, trading, or discretion with respect to securities transactions. Clients are responsible for placing and executing their own trades, either on their own or with another investment adviser. We provide non-continuous and periodic outside account monitoring. Account Monitoring This service provides for safekeeping/housekeeping of Client Assets on Client’s behalf. CCSG is not authorized to effectuate securities transactions unless specifically requested by the Client. Otherwise, Client is responsible for the execution of trades on their own or with another registered investment adviser. CCSG will provide financial planning or consulting services with respect to the Assets. Financial Planning and Consulting Services CCSG will typically provide a variety of financial

planning services to Clients. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings and other areas of a Client’s financial situation. For some Clients, CCSG has the ability to employ a hedging strategy involving concentrated or restricted stock positions held at a Custodian. A financial plan developed, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. CCSG may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. CCSG may utilize the sub-advisory services of a third-party investment advisory firm or individual advisor to aid in the formation of a financial plan. Before selecting a firm or individual, CCSG will ensure that the chosen party is properly licensed or registered. Consulting/Margin Loan Program - CCSG has partnered with its custodian and negotiated low interest rate margin loans to be offered to its Clients. In this program, CCSG is engaged as a consultant to assist in procuring the margin loan between the Client and the custodian. CCSG provides ongoing consulting and other related services to these accounts as requested by the Client. CCSG will consult and assist in securing low rate margin loans with its custodians while also providing research and other advice to their clients. Page 6 Retirement Plan Consulting Services CCSG provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education. Retirement Plan Consulting services typically include:
• Establishing an Investment Policy Statement – CCSG will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.
• Investment Options – CCSG will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – CCSG will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk.
• Investment Monitoring – CCSG will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. In providing services for retirement plan consulting, CCSG does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to Client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the Client accounts are part of a Plan, and CCSG accepts appointment to provide services to such accounts, CCSG acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Please note: CCSG does not determine if securities held by Clients are the subject of a class action lawsuit or whether Clients are eligible to participate in class action settlements or litigation nor does CCSG initiate or participate in litigation to recover damages on a Client’s behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by Clients. C. Client Account Management Prior to engaging CCSG to provide investment advisory services, each Client is required to enter into one or more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – CCSG, in connection with the Client, will develop an investment strategy targeted to achieve the Client’s investment goals and objectives.
• Asset Allocation – CCSG will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – CCSG will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – CCSG will provide investment management and ongoing oversight of the Client’s portfolio.
• Financial Planning and Consulting – For Clients engaging for investment advisory services, the Advisor provides ongoing financial planning and related services regarding the Client’s overall financial situation. D. Wrap Fee Programs CCSG does not manage or place Client assets into a wrap fee program. Page 7 E. Assets Under Management As of 12/31/2022, CCSG manages $104,415,836 worth of assets on a discretionary basis and $17,825,895 worth of assets on a non-discretionary basis, totaling $122,241,731.