Viewpoint Capital Management LLC (referred to in this brochure as “Firm”, “Advisor”, “We”, “Us”, “Our”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). Viewpoint was founded in 2011. Ryan P. Sawyer is our managing member, sole owner and is also the Chief Compliance Officer. Advisory Services Viewpoint provides comprehensive investment advisory (portfolio management) services. These include the following:
• Identification of each client’s objectives and risk tolerances
• Asset allocation / recommendations
• Security selection, purchase, sale or hold decisions and,
• Overall portfolio management with investment discretionary authority, or alternatively without investment discretionary authority (i.e., non-discretionary which requires the client to be available to approve or not approve desired transactions recommended by Viewpoint during market open hours). If we cannot reach you, we cannot place transactions for your account without your explicit approval of those recommended transactions. We develop individual investment portfolios that integrate the long-term investment goals, risk tolerances and financial objectives of our clients as described in written, verbal communications and your investment policy statement. When you establish an advisory relationship with us, we document who you are and what your current investment goals and objectives are in the Client Profile. This Profile then guides our investment decisions and recommendations. We then manage your account assets with your unique circumstances in mind. We tailor our advice to you and your assets by:
• Making investment decisions (for discretionary accounts) in accordance with each Client’s profile. This means that we will determine which securities, the number of securities and timing of transactions to make for your account based on our professional determination (as guided by your profile)
• Developing recommendations (for non-discretionary accounts). This means you must authorize each transaction prior to our placing the transaction at Schwab, your independent, third-party qualified broker / custodian. In addition, you need to be available to our portfolio manager during open stock market hours. Portfolios contain investments from multiple asset classes based on objectives and the risk tolerance of each client. In client portfolios we employ primarily individual stocks and bonds and passively managed ETFs; mutual funds and cash. We can access other types of liquid securities, if required, consistent with your goals and objectives. Clients may place reasonable restrictions upon the type of securities or specific securities that are purchased, sold, or held in your account. These restrictions requested by each client must be made in writing to Viewpoint. They are not accepted until reviewed and accepted in writing by Viewpoint. Any restrictions that limit the ability of Viewpoint to manage the assets that have an adverse impact on portfolio diversification or return objectives are discussed and the impact of those restrictions. The result is they may be accepted or rejected. Assets Under Management As of December 31, 2022, we had the following assets under management. These numbers include fee paying and non-fee-paying assets managed by Viewpoint, including the assets of employees and families, both discretionary and non-discretionary: Investment Discretionary Authority $140,918,160 Non- Discretionary Authority $ 36,666,058 Fiduciary Advice Exemption: PTE 2020-02. This is a new Department of Labor exemption for investment advisers and other financial service providers to help them NOT run afoul of DOL and the Internal Revenue Code which covers IRA (Individual Retirement Accounts) for “retirement investors.’ It is big and complicated. PTE 2020-02 was adopted by the DOL (Department of Labor), and it applies to ERISA plans and IRAs and other “retirement investor” accounts. What this means is that it is a prohibited transaction for any investment adviser or broker dealer to recommend to a retirement investor to roll over a 401k to an IRA. It is a problem because the person recommending the change earns additional compensation (direct or indirect) on the retirement assets that were moved. Meaning: compensation would not have been paid if the recommendation was not made. 1. If a client decides to roll over the 401k to an IRA independently of Viewpoint and we just facilitate the transfer, then PTE 2020-02 does not apply. 2. The retirement fiduciary

definition was modified on December 15, 2020, and took effect February 24, 2021. 3. Types of IRAs covered: traditional, Roth, rollover, inherited, SEP and Simple IRAs. 4. Types of ERISA accounts covered: Employee Pension Benefit Plans; Employee Welfare Benefit Plans; Health Savings Accounts (HSA); Medical Savings Accounts (MSA), and Coverdell Savings Accounts (Educational IRAs). 5. Mandatory Requirements to comply with this PTE 2020-02 a. Impartial conduct standard, i.e., fiduciary responsibility. i. Give advice that is in the retirement investors best interest and not ours ii. Charge reasonable fees (consistent with our current fee schedule iii. Seek to obtain best execution, although all clients must direct brokerage to Schwab. iv. We prevent misleading statements. b. Require written disclosure where we acknowledge our fiduciary status. i. Provide a description of the services to provide to the retirement investor and disclosure of material conflicts of interest; and, ii. For rollovers, only: 1. Include a consideration of investment alternatives. 2. Address fees with the investors 401k and the IRA rolling over into 3. Consider whether the 401k employer pays plan fees. 4. Assess services and investment options available under the plan or IRA. c. Viewpoint has a PTE 2020-02 worksheet that must be completed and retained internally within 10 days of making a recommendation to a retirement investor. i. The requirement that retirement recommendations (401k to IRA or IRA to Roth IRA) require the exemption to be documented via the worksheet. d. We disclose here, that “Viewpoint does not generally recommend to any client that they roll over a 401k to an IRA.” i. This exemption is about the additional compensation we receive for making such a recommendation (for managing assets we would otherwise not manage). ii. Meaning: If Viewpoint does not make the recommendation to roll over a 401k to an IRA, the prohibited transaction exemption does not apply and the same for moving from an IRA to a Roth IRA. Yes, it is confusing. 6. Investment advice has been defined through The Impartial Conduct Standard which has three parts: a. Provide investment advice that is in the best interest of the retirement investor, which is advice that: provides advice that reflects the care, skill, prudence and diligence then prevailing that a prudent person in the same capacity acts, based on the investment objectives, risk tolerance, financial circumstances of the retirement investor and does not put the financial or other interests of Viewpoint or Ryan Sawyer. Meaning, we meet our fiduciary obligations to all our clients, including retirement investors. b. We charge only reasonable compensation (as disclosed in the next section, below). Security transactions for the retirement investor account (IRA, etc.) managed by Viewpoint are directed brokerage (see Item 12, below). c. We make no misleading statements to the retirement investor regarding the recommendation and relevant matters. Senior Safe Act Legislation and Compliance As required by law, via the Senior Safe Act, which provides immunity to Viewpoint when we see or suspect a senior client being exploited. To comply, we have in our policies and procedures information related to this topic and what we will do and must do. For a reader’s information:
• Viewpoint defines a senior investor at 65 years of age.
• We act as a fiduciary to all clients.
• Diminished capacity is the most often complaint our research has told us. This is now called major neurocognitive disorder.
• Financial Exploitation: Ryan looks for physical or emotional abuse, neglect and blocked access to the senior client accounts and assets, generally through a power of attorney that was not previously present, among many others. We ask that you be aware of Senior Safe Act issues and our compliance. In addition, we are now running reports of our clients owned by those 65 and over, and the assets held in these accounts. If we discover potential exploitation1, we are obligated to report to the police, social services and, if necessary, lock down the client’s account at Schwab. 1 The North American Securities Administrators (US and Canada), indicated in February of 2020 that in New York state alone, exploitation of seniors ranged from $352 million to $1.5 billion!