15 Equity, LLC (“15 Equity” or the “Firm”) is an investment adviser registered with the United States Securities and Exchange Commission. The Firm is a limited liability company formed under the laws of the state of Delaware. The firm is 68% owned and controlled by Raymond J. Lucia Jr. and 23% owned and by Joseph P. Lucia. The Firm offers a variety of programs that may be used by the Firm and investment adviser representatives (“adviser representatives”, “advisers”, or “IARs”) to provide services to you. These programs and services are more fully described in this brochure, and your account opening documents. We offer asset management services to individuals, trusts, estates, private foundations, high‐net‐worth individuals, and business owners. The process begins with a thorough interview and data collection process to help our team understand, among other things, your short‐term and long‐term financial objectives, risk tolerance, tax status, current investment holdings, and asset allocation. History In 2000, West Coast Asset Management, Inc. (“WCAM”) was co-founded by Lance Helfert, Managing Director and Co-Portfolio Manager of 15 Equity, who served as WCAM’s President. Atticus Lowe, Managing Director and Co-Portfolio Manager of 15 Equity, joined WCAM in 2002 and became the firm’s chief investment officer. In 2014, Lucia Capital Group (“LCG”) acquired WCAM’s managed accounts with Mr. Lowe and Mr. Helfert continuing to manage the focused equity strategy and fixed income portfolios for LCG’s clients. In 2020, LCG restructured its business model and established 15 Equity to focus on LCG’s legacy equity and fixed income strategies while serving private clients and delivering separately managed account solutions to independent investment advisers. Mr. Helfert and Mr. Lowe continue to manage the focused equity and fixed income portfolios for 15 Equity. ASSET MANAGEMENT SERVICES PRIVATE CLIENT PROGRAM Clients participating in the Private Client Program may do so on a discretionary or non‐discretionary basis. Clients will generally establish brokerage accounts directly with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), a FINRA‐ registered broker/dealer, member SIPC, to maintain custody of their assets and to effect trades for their accounts. The Firm has entered into a formal agreement with Schwab Advisor Services whereby Schwab will provide certain services to you and the Firm. In certain cases, the Firm may use the custodian or other broker/dealer(s) designated by the client to provide all clearing, trading, and brokerage services for the client account. PRIVATE CLIENT STRATEGY (DISCRETIONARY) The Firm provides personal discretionary

asset management services consisting of the active management of client accounts on an individualized basis to clients in its Private Client Program. The Firm may invest its clients' assets in exchange‐traded or OTC‐traded securities, mutual funds, warrants, equity and corporate debt securities. The Firm may also invest account assets in fixed‐income securities and may do so through investments in indexed bond funds as well as individual fixed‐income securities. The Private Client Program begins with the development of an Investment Policy Statement that balances a client's overall financial objectives with the client's individual attributes, including risk, income requirements, liquidity requirements, and investment horizon. The Firm often manages only a portion of a client's total investment portfolio, and the portion managed by the Firm may be concentrated in one or a few asset categories. Clients are under no obligation to implement the recommendations developed by the Firm and may specify any investment restrictions upon opening the account or at any time thereafter. The Firm will have discretionary trading authority to conduct trading activity in securities consistent with the Investment Policy Statement approved by the client, subject to any investment restrictions requested by the client. The Firm will determine at its sole discretion the specific securities that will be treated as falling within any restricted asset category that may be designated by the client. In making this determination, the Firm may rely on outside sources, such as standard industry codes and research from independent service providers. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. PRIVATE CLIENT STRATEGY (NON‐DISCRETIONARY) The Firm provides non‐discretionary asset management services to certain clients in its Private Client Advisory Program based on specific objectives of the client, including buy or sell transactions directed by the client subsequent to direct dialog between the client and the Firm, for each transaction. CLIENT ASSETS MANAGED BY 15 EQUITY As of 12/31/2023, client assets managed by 15 Equity totaled $116,380,336 of which $80,854,453 was invested in discretionary accounts and $35,525,884 was invested in non-discretionary accounts. Discretionary assets are the assets in which we have the authority to buy or sell securities. This may include the selection of model portfolios, or the selection and execution of securities transactions. Non-discretionary assets are assets in accounts where we do not have discretion to place orders to buy or sell assets without first receiving the client’s authorization.