Reichard Capital is a registered adviser with the SEC. Reichard Capital was organized as a limited liability company under the laws of the State of North Carolina in March 2019 and became a registered investment adviser in October 2019. Our principal equity owner (controlling more than 25% or more of this Firm) is James N. Reichard who is the sole Manager of our Firm, Partner and Chief Compliance Officer. Advisory Services Offered Reichard Capital offers the following advisory services to its clients. Portfolio Management Services – Our Firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. Primarily we manage advisory accounts on a discretionary basis although we may accept nondiscretionary accounts under certain circumstances. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Reichard Capital manages clients’ assets primarily utilizing no-load mutual funds, taking into consideration the overall management style selected by the client. The mutual funds are selected on the basis of one or more of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure. The weighting of a client’s portfolio between funds and market sectors is determined by each client’s individual needs and circumstances. Clients have the opportunity to place reasonable restrictions on the types of investments which are made on their behalf. Clients retain individual ownership of all securities in a portfolio. Certain clients’ portfolios may contain various types of individual securities when they initially engage our Firm for asset management services. Over time, Reichard Capital may liquidate these holdings with the objective of fully investing the client’s assets in accordance with their Investment policy statement. While client assets will be invested in no-load mutual funds, Reichard Capital may also render investment advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Municipal securities
• United States governmental securities
• Corporate debt securities (other than commercial paper) Subadvisory Services – Reichard Capital will sometimes serve as sub-adviser to other firms to assist in the investment of those firms' clients' assets. We currently serve as sub-adviser to a firm that has appointed us to manage a portion of its clients' assets, and those clients have agreed to have us provide them with advisory services. That investment adviser has established investment policies for those clients based on a questionnaire or using those clients' own investment policies. We generally consider individual clients for whom we serve as sub-adviser to be our clients for all purposes, including bonding insurance, suitability and fiduciary liability. Use of Sub-Advisers and Third-Party Managers – We may also, when appropriate, engage a sub–adviser for certain portions of a client portfolio. These sub–advisers are independent third-party managers. We may also recommend direct investment with independent third-party managers. These strategies are used typically when those third–party managers demonstrate knowledge and expertise in a particular investment strategy. Our Firm will conduct appropriate due diligence on all independent third-party managers, making reasonable inquiries into their performance calculations, policies and procedures, Code of Ethics, and other operational and compliance matters deemed important to account performance and risk management. As part of this service, we perform management searches of various unaffiliated registered investment advisers. Based on a client’s individual circumstances and needs (as exhibited in the client’s investment objectives, investment policy statement (“IPS”) or similar suitability document) we will determine which selected third–party manager’s portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected third-party manager. We will provide and encourage clients to review each third-party manager’s disclosure document regarding the particular characteristics of any program and managers selected by us. Once we determine which third-party manager(s) are most appropriate for the client, we will provide the selected third-party managers with the client’s IPS or similar suitability document. Each selected third-party manager will then create and manage the client’s portfolio based upon the client’s individual needs as exhibited in the client’s IPS or similar suitability document. We will regularly and continuously monitor the performance of the selected third-party manager(s). If we determine that a

particular selected third-party manager is not providing sufficient management services to the client, or is not managing the client’s portfolio in a manner consistent with the client’s IPS or similar suitability document, we will remove the client’s assets from that third-party manager and place the client’s assets with third-party manager at our discretion and without prior consent from the client. Consulting 529 College Savings Plans – Reichard Capital provides investment advice to individuals participating in a 529 College Savings Plan by providing periodic recommendations on the allocation of investments across the menu of investment choices available in their plan. In its capacity as a non- discretionary adviser, Reichard Capital will evaluate the 529 Plan’s age-based and market-based options and provide investment recommendations. The client is responsible for making the recommended changes to the asset allocation of the account and may or may not in a timely manner follow any and all of the recommendations provided. Reichard Capital’s consulting services for 529 College Savings Plans participants require that clients furnish Reichard Capital with the menu of investment choices available and any restrictions imposed on plan investments. We will initially review the investment choices available to an account, and we will develop a recommended allocation, identifying what percent of the account should be invested in the choices available. Thereafter, on a periodic basis, we will review the investment choices available in the account and performance of the current choices and recommend allocation changes. We may make recommendations to switch funds within the 529 Plan, either to reduce risk or to take advantage of perceived attractive opportunities. The client is responsible to inform Reichard Capital of any changes to his/her 529 Plan. Financial Planning – Reichard Capital offers financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client’s current income tax and future tax liability.1
• INVESTMENTS: We analyze investment alternatives and their effect on the client’s portfolio.
• INSURANCE: We review existing policies to ensure client’s desired coverage goals for life, health, disability, long-term care, liability, home and automobile are being met.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client’s current financial status, tax status, future goals, return on investment objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we recommend that the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely the responsibility of the client. 1 Reichard Capital does not provide legal or tax advice and clients/potential clients should consult counsel or their accountant about their individual legal or tax circumstances. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically the financial plan is presented to the client within three months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Clients are under no obligation to act upon Reichard Capital’s recommendation. If the client does elect to act on any of the recommendations, the client is under no obligation to effect the transaction through Reichard Capital. Assets Under Management: As of December 31, 2023, we were managing $323,993,627 in assets on a discretionary basis in 190 accounts and $0 in assets in 0 accounts on a non-discretionary basis.