Description of Advisory Firm Capasso Planning Partners LLC (hereinafter “CPP LLC”) is a Limited Liability Company organized in the State of South Carolina. The firm was formed in January 2018 and has been in business since April 2018. The principal owner is Charles Dustin Capasso with Daniel Callahan owning a minority interest. Types of Advisory Services Portfolio Management Services CPP LLC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CPP LLC creates an Investment Policy Statement for each client and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. CPP LLC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CPP LLC will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. However, CPP LLC take each client through an investment education process along with the planning process so each client understands the strategy from the onset of the relationship. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CPP LLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CPP LLC’s economic, investment or other financial interests. To meet its fiduciary obligations, CPP LLC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CPP LLC’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CPP LLC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Planning Services Financial plans and financial planning may include but are not limited to investment planning, insurance planning, tax planning, estate planning, retirement planning, education planning, employee benefits planning, charitable gift panning, credit planning, debt strategies, income, spending, budgeting, savings, and credit card reward analysis. These services may include the following three steps: 1. Initial Consultation: Assess current financial situation and discuss the financial planning process and services. 2. Detailed Meeting: Review financial situation in depth to understand client’s financial goals and concerns. 3. Client Recommendation Meeting: Deliver and client walkthrough of financial plan, including current net worth (Balance Sheet), goals, and action items. Capasso Planning Partners LLC Page 5 of 16 Ongoing Financial Planning Services If providing ongoing financial planning services, CPP LLC will provide the following:
• Quarterly check-ins with clients to assess financial plan, implementation of the plan, limitations, adjustments needed, and assess new variables in a client’s financial picture.
• End of Year meeting to discuss financial plan.
• A live copy of the plan through CPP LLCs financial planning tools. Client

may or may not receive a written financial plan, depending on their particular needs and requests. Selection of Other Advisers CPP LLC may direct clients to third-party investment advisers. Before selecting other advisers for clients, CPP LLC will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where CPP LLC is recommending the adviser to clients. Clients will pay fees to these third-party advisers, as discussed in Item 5 of this brochure. Services Limited to Specific Types of Investments CPP LLC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), commodities, non-U.S. securities, venture capital funds and private placements, although CPP LLC primarily recommends mutual funds, and private equity funds. CPP LLC may use other securities as well to help diversify a portfolio when applicable. Pontera CPP LLC utilizes Pontera, a third-party platform, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows CPP LLC to avoid being considered to have custody of Client funds since the Firm does not have direct access to client log- in credentials to affect trades. CPP LLC is not affiliated with the Pontera platform in any way and receives no compensation from them for using their platform. In order for CPP, LLC to manage held away assets (assets not held at Fidelity or Schwab) a link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, CPP LLC will review the current account allocations. When deemed necessary, CPP LLC will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client-Tailored Services and Client-Imposed Restrictions CPP LLC will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by CPP LLC on behalf of the client. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CPP LLC from properly servicing the client account, or if the restrictions would require CPP LLC to deviate from its standard suite of services, CPP LLC reserves the right to end the relationship. Capasso Planning Partners LLC Page 6 of 16 Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. CPP LLC does not participate in any wrap fee programs. Assets under Management As of December 31, 2023, CPP LLC has approximately the following assets under management:
• Discretionary: $ 323,758,107
• Non-Discretionary: $ 9,002,110
• Total Regulatory Assets Under Management: $ 332,760,217