ACP Capital Management, LLC, (hereinafter “ACP Capital”) is a registered investment adviser that was organized in November 2005 as a Florida limited liability company. The firm is entirely owned by ACP Capital Holdings, LLC. Esteban Endere owns 33.34% and Ezequiel Bidau and Piero Siveroni each own 33.33 % of ACP Capital Holdings, LLC. The following paragraphs describe our services and fees. Each investment advisory service is listed below and describes how we tailor our advisory services to your individual needs. Also, you will see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Such persons are properly registered as investment adviser representatives in all required jurisdictions. Portfolio Management Services ACP Capital provides digital and traditional non digital investment advisory services. ACP Capital provides digital discretionary investment advisory services to clients through a digital platform called ACP Investor by utilizing algorithms and methodologies for developing and implementing Model Portfolios (described below) with differing risk criteria. Due to the discretionary nature of the services offered, ACP Capital will invest the available funds in a selected portfolio and make periodic adjustments and rebalancing transactions without asking clients for their concurrence or approval. ACP Capital provides its advisory services utilizing BCP Advisors LLC (d/b/a BCP Global) as a sub-adviser and using their proprietary online and mobile platform to digitize the processes of customer onboarding (individuals), account services, investment profile assessment, portfolio recommendation, and investment management. The digital offering is a Wrap Fee Program structure solely related to its web-based digital advisory accounts and services. Please see the Adviser’s separate Wrap Program Brochure for further details about the fees we receive as part of the wrap account. Under our sub-advisory agreement, BCP Global is responsible for operating the platform and its related services. ACP Capital will provide its clients with access to the BCP Global platform via its interactive website and mobile application. BCP Global has retained the services of Interactive Brokers LLC (member FINRA/SIPC) (“Interactive Brokers” or “custodian”) for all the execution, clearing, and custody services. Clients will open cash accounts at Interactive Brokers to maintain their assets. ACP Capital provides non-digital discretionary and, in limited circumstances, non-discretionary portfolio management services. Our investment advice is tailored to meet our Clients’ needs and investment objectives. At the inception of the advisory relationship, and at regular intervals thereafter, we meet with our clients to gather their financial information, determine their goals, and agree on their risk tolerance. The information we gather helps us implement an asset allocation strategy that is specific to our clients’ goals and needs. Unless otherwise specified and agreed to, clients grant ACP Capital complete and sole discretion to manage their account in accordance with the account's investment objectives, risk tolerance and investment time horizon, subject only to any reasonable restrictions that must be provided in writing. We monitor client portfolios performance on an ongoing basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions, their financial circumstances, or both. ACP Capital uses exchange-listed securities and securities traded over the counter, foreign issuers, warrants, corporate debt securities,

structured fixed income securities, commercial paper, certificates of deposit, municipal securities, mutual fund shares, United States government securities, options contracts on securities and commodities, futures contracts on tangibles, structured notes, interests in partnerships investing in real estate and oil and gas interests. ACP Capital Management, LLC - Form ADV Part 2 - Brochure 5 Currently, ACP Capital manages the following types of portfolios: Digital Investment Portfolios: ACP Capital offers the aforementioned discretionary portfolios via the digital platform. Traditional Investment Portfolios: ACP Capital offers a variety of traditional investment portfolios invested in stocks and bonds with different investment management styles. The portfolios are designed to suit the differing needs, objectives, and risk tolerances of clients. The different styles include cash management portfolio, conservative portfolio, balanced portfolio, and growth portfolio. Structured Products and Emerging Markets Fixed Income Portfolios: ACP Capital manages separate accounts for clients in the structured fixed income portfolio, an asset class consisting of debt instruments typically backed by collateral such as residential and commercial mortgages, equipment leases, small business loans, structured settlements, and other potential income generating investments. Manager and/or Investment Manager of Private Investment Vehicles and Private Funds: ACP Capital manages private investment vehicles that invest in unique opportunities that become available from time to time. In this regard, ACP assists with the implementation of the funds overall investment strategy and day to day operations of the vehicle. ACP is granted broad management via a management agreement giving it the authority to make decisions, manage and act as authorized agent. ACP Capital is responsible for "investing and managing the clients’ assets and has the power to, upon its own discretion with no other consent needed from the client to act and sell the assets owned by its client. ACP Capital’s role in some of the vehicles is to oversee and supervise that the Sub- advisor is executing the strategy as described in the Fund’s offering memorandum. ACP Capital Management, LLC - Form ADV Part 2 - Brochure 6 Securities selected are chosen based upon several criteria, including current yield, credit enhancement protection, liquidity, and measured default risk. Securities may be held to maturity, but the account could seek to take advantage of trading opportunities to realize short term gains. Not all accounts will have the same positions due to a number of considerations, including timing of capital contributions and withdrawals, liquidity in the account, account objectives, account size, size of the investments as well as manager discretion. ACP Capital is engaged by different parties to act as Investment Manager of funds and/or pooled investment vehicles with the mandate to oversee and supervise the activities of the sub-managers selected to perform day to day investments for the funds. Fees charged for this type of activities varies depending on vehicle’s size, type of investment and role for ACP Capital. Please be aware that ACP Capital has a conflict of interest when it advises clients to invest in the funds that they manage as they benefit from increased assets within the funds because it will have the opportunity to earn greater fees. Please see below. We mitigate this conflict by only providing investment advice that is in the best interest of the client. Assets Under Management As of December 31, 2023, ACP Capital manages $220,201,849 on a discretionary basis and $0 on a non- discretionary basis.