A. Firm Information SineCera Capital, LLC (“SineCera Capital” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as an LLC under the laws of the State of Delaware and is located in the State of Texas. SineCera Capital was founded in June 2019 and is majority owned and operated by Kevin Kaylakie (Founder, Chief Executive Officer, and Chief Compliance Officer), Adam Packer (Chief Investment Officer), and Connee Sullivan (Managing Director, Head of Family Office Services). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by SineCera Capital. B. Advisory Services Offered SineCera Capital offers investment advisory services to high-net-worth individuals, family offices, trusts, estates, businesses, and private foundations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. SineCera Capital's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services SineCera Capital generally provides customized investment advisory solutions for Clients across its Advisory services. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. SineCera Capital works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation to create a customized portfolio strategy. SineCera Capital will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize alternative investments, individual stocks, bonds, or options contracts to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. SineCera Capital’s investment strategies are primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. SineCera Capital will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. SineCera Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. SineCera Capital may recommend, on occasion, redistributing investment allocations to diversify the portfolio. SineCera Capital may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. SineCera Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 At no time will SineCera Capital accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services SineCera Capital will typically provide a variety of financial planning and consulting services to Clients as part of its family wealth advisory services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass areas of need including but not limited to, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to, the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence- or alter retirement savings, establish education savings, and/or charitable giving programs. SineCera Capital may also refer Clients to an accountant, attorney, or other specialists as appropriate for their unique situation. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor.

If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Separately Managed Account Services The Advisor may choose to offer separately managed account services, which involve investment of client assets in established portfolio strategies of the firm. SineCera Capital’s core portfolio strategy seeks to balance risk contributions between equities, fixed income, and inflation-hedging asset. This “risk balanced” approach seeks to generate superior risk-adjusted returns versus traditional “diversified” strategies that tend to have most of the risk concentrated in equities. Portfolio Monitoring and Consulting Services The Advisor may choose to offer portfolio monitoring and consulting as a stand-alone service. The Advisor will perform ongoing monitoring of the Client portfolio(s), account aggregation, and/or provide investment advice on a non-discretionary basis to the Client. The Advisor shall provide periodic reporting at least quarterly or more frequently based on the Client’s specific needs. The investment advice may be provided regarding asset allocation, investment portfolio construction, investment selection or any other services based on the needs and objectives of the Client. The Advisor may also assist the Client in designing personal financial goals and objectives to help further support the ongoing monitoring and advice rendered to the Client. Family Office Consulting SineCera offers family office consulting services, where the Advisor will assist in the design and implementation of financial goals and objectives through ongoing recommendations. SineCera will coordinate with the Client’s accounting, legal, or investment professionals to provide a holistic approach to the Client’s finances. This service may also include the identification and review of vendors that may help the Client achieve the desired financial outcome. Page 6 Family Office Services The Advisor also offers comprehensive family office services which encompasses financial administration and other services. Financial Administration services include but are not limited to document e-vaulting, personal accounting and budgeting, bill pay, tax organization, payroll administration, and tracking of oil & gas interests and real estate interests. Other Family Office Services would include family education & governance, including education and engagement for next-gen family members, family meeting facilitation, and philanthropy strategy and implementation. Firm Engagement Levels SineCera Capital | Wealth Management SineCera Capital Wealth Management clients are generally high-net-worth families or individuals. This high-touch service offering begins with the Advisor assisting Clients in coordinating a team of professionals to oversee many facets of a Client's financial situation. The Advisor’s services generally include investment management and financial planning in addition to strategic planning. Strategic planning may include but is not limited to: family values identification and alignment, succession planning, estate and tax planning, risk management, and insurance. SineCera Capital Wealth Management services are geared towards Clients with investable assets of $5 million or more and have the desire and/or need for access to and reporting related to alternative investments. SineCera Capital | Family Office SineCera Capital Family Office clients are generally ultra-high-net worth families or individuals. The Advisor’s services generally include all services received by Wealth Management Clients and may also include: Portfolio Monitoring & Consulting, Family Office Services, Family Office Consulting or Separately Managed Account Services. SineCera Capital Family Office services are geared towards Clients with investable assets of $25 million or more and have complex needs associated with elevated levels of wealth. SineCera Capital | Financial SineCera Financial clients are generally affluent families or individuals. Services under SineCera Financial are delivered through a robust digital custodial platform integrated with a modern financial planning platform. This offering couples a modern platform experience with access to ongoing, personal guidance. C. Client Account Management Prior to engaging SineCera Capital to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – SineCera Capital, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – SineCera Capital will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. Page 7
• Portfolio Construction – SineCera Capital will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – SineCera Capital will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs SineCera Capital does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by SineCera Capital. E. Assets Under Management As of December 31st, 2023, SineCera Capital manages $124,555,879 in Client assets, $110,634,841 of which are managed on a discretionary basis and $13,921,038 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. SineCera Capital also advises on $162,878,577 in Client assets on which the Advisor provides ongoing administration, consulting and/or reporting.