Raleigh Capital Management, LLC (“RCM,” “Firm,” “we,” “our,” and “us”) is an investment adviser registered with the United States Securities and Exchange Commission and is a corporation formed under the laws of the State of North Carolina. Brian Raleigh is the President and sole owner of RCM. RCM has been registered as an investment adviser since February 2009. Prior to forming RCM, Brian Raleigh worked with a Fortune 500 company for 10 years, where he was registered as a securities representative of a broker dealer. General Description of Primary Advisory Services The following are brief descriptions of RCM’s primary services. A detailed description of RCM’s services is provided in Item 5 – Fees and Compensation so that clients and prospective clients can review the description of services and description of fees in a side-by-side manner. Financial Planning Services – RCM provides financial planning services. Financial planning services do not involve the active management of client accounts, but instead focus on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Outside Money Managers – RCM provides advisory services by referring clients to outside unaffiliated money managers that are registered or exempt from registration as investment advisers. Third-party money managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. These money managers typically are granted discretion by their clients, meaning that the managers can buy or sell securities without seeking or obtaining the client’s permission. Manager of Managers – RCM provides advisory services wherein it acts as “manager of managers.” Under this service offering, RCM is granted investment discretion by the client and leverages its access to certain third-party sponsored investment platforms to select unaffiliated third-party money managers to implement investment strategies and model portfolios which best fit the client’s investment objectives, needs, and limitations. The third-party money managers will have discretionary trading authority and be responsible for all research, day-to-day trading decisions, and the overall

implementation of the investment strategies and models selected by RCM for the client’s account. RCM’s role is to monitor the client’s accounts on an ongoing basis and to use its investment discretion to allocate and re-allocate the client’s funds between money managers, strategies, and models available on the platform as necessary and appropriate, acting as the client’s fiduciary. At present, RCM has entered into co-advisory or sub-advisory arrangements to utilize the investment management platforms sponsored by AE Wealth Management, LLC (“AEWM” and the “AEWM Platform”) and Verity Asset Management, LLC (“VAM” and the “VAM Platform”) to implement these services. AEWM and VAM are independent SEC registered investment advisor firms. We may enter into similar arrangements with other investment platform providers in the future. Investment Management – RCM may also offer direct discretionary management by one or more of RCM’s investment adviser representatives. Clients who select this service grant discretion to RCM to invest, allocate, re-invest and re-allocate their designated investment account(s) held in the custody of an independent qualified custodian (i.e., a licensed broker- dealer, bank, or trust company) in one or more securities. This service may also be provided on a non-discretionary basis, meaning that RCM makes recommendations and receives client permission before executing transactions. Types of Investments RCM does not limit its advice to certain types of investments, but instead advises on a broad range of investments, including without limitation, the following types of investments:
• no-load (i.e., no trading fee) and load-waived (i.e., trading fee waived) mutual funds;
• exchange-listed securities (i.e., stocks);
• securities traded over-the-counter (i.e., stocks); Raleigh Capital Management Inc. Page 5 of 15 ADV Part 2A Disclosure Brochure
• fixed income securities (i.e., bonds);
• closed-end funds and exchange traded funds (“ETFs”);
• foreign issues;
• warrants;
• corporate debt securities (other than commercial paper);
• commercial paper;
• certificates of deposit;
• municipal securities;
• variable life insurance;
• variable annuities;
• United States government securities;
• options contracts on securities; and
• interests in partnerships investing in real estate and oil and gas interests. We may make recommendations regarding other types of investments not listed above based on the client’s specific investment objectives, needs, and limitations. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, for more information on the types of investments and investment strategies we typically recommend to clients. Tailored Advisory Services RCM’s services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. Client Assets Managed by RCM The amount of client assets managed by RCM on a discretionary basis totaled $262,799,059 as of February 1, 2024. The amount of clients’ assets managed by RCM on a non-discretionary basis totaled $0 as of February 1, 2024.