Firm Description Hoxton Capital Management USA LLC, (HCM-USA, the Adviser/Firm) was founded in 2019. The Firm is a registered investment advisor with the Securities Exchange Commission (SEC). The Firm home office is located in Austin, Texas. HCM-USA also maintains a branch office in Jersey City, New Jersey. The Principle Place of Business of the firm is Dubai, United Arab Emirates. The Adviser is a fee-only investment management and financial planning firm. The Firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Firm ownership is affiliated with entities that recommend financial products or securities. The Adviser does not act as a custodian of client assets and the client always maintains asset control. The Adviser does not have discretion regarding client accounts and seeks client approval prior to placing a trade on behalf of the client. The Adviser does have discretion over which brokerage firms to trade with but does not determine the resulting commissions to be paid, where the account is held in custody and/or the resulting expenses related to that custodianship. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be engaged directly by the client on an as-needed basis and not through the Firm. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owner: HCM Trading Holdings, Ltd. Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services; retirement account portfolio advisory service; manages investment advisory accounts not involving investment supervisory services; furnishes investment advice through consultations; and issues, charts, graphs, formulas, or other devices which clients may use to evaluate securities. On more than an occasional basis, the Adviser furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services that often include estate planning.  As of December 31, 2023, the Adviser manages $ 326,345,642 on a non-discretionary basis. Types of Pension Advisory Services The Adviser focuses on assisting United Kingdom (UK) citizens currently residing in the identified states of registration (expatriates/Ex-Pats) with the management of their private UK pension scheme transfers. The private UK transfer arrangements allow all or part of a personal pension scheme, to be directed by the pension recipient (in this case the Ex-Pat) the power to direct how some or all of the Ex-Pat’s contributions are invested. The transfer process creates a Self Invested Personal Pension (SIPP). The SIPP is commonly referred to as a scheme. A scheme is the investment vehicle the Adviser may recommend for the client to purchase and/or invest. SIPP investment vehicles are strategies within the offering adviser portfolio. The portfolio is financed from many individual investor assets. The assets are aggregated for the purposes of investment. This is also referred to as pooled funds. Mutual funds, exchange traded funds, pension plan and unit investment trusts are all examples of professionally managed pooled funds. The Adviser currently engages the services of several investment companies including pension trustees, on behalf of clients, electing to implement a self-directed pension plan. Trustees include but are not limited to International Financial Group Limited (RL360, Ardan and The IFG Pensions Limited), Capital International Group, Novia Global Limited/Novia Financial plc. (Novia) and IFG Pension Services (UK) Limited (IFGL SIPP). RL360 is an Insurance Manager regulated by the Isle of Man Financial Services Authority. Novia is a qualified custodian registered with the Financial Conduct Authority (United Kingdom) pursuant to Board Rules 116.17(a)(8) and International Financial Group, Capital International Group, Novia Financial plc. and IFGL Pension Services (UK) Limited are the investment platform trustees for the SIPP separate accounts managed on behalf of clients. Investment funds are held in an assigned custodian account. The custodian is a third party and is not affiliated with the Adviser. Holdings are pooled and not immediately identifiable by separate certificate/name. For additional information regarding the custodial relationship refer to the SIPP Application Form. IRA Rollover Considerations and Recommendations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account (IRA) that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with the Firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by the Firm. HCM-USA complies with the Department of Labor (DOL) Prohibited Transaction Exemption 2020-02 (PTE 2020-02) where applicable. The Firm is providing the following additional acknowledgment: When the Adviser provides investment advice to individuals regarding a retirement plan account or individual retirement account, the firm is deemed a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way the Adviser makes money creates potential conflicts with a client’s interest. Therefore, the Adviser operates under a special rule which requires the firm to act in a client’s best interest and not put the Adviser’s interest ahead of the client. Under this special rule’s provisions, the Adviser must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put the Adviser’s financial interests ahead of a client when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees and investments;  Follow policies and procedures designed to ensure advice given is in the client’s best interest;  Charge no more than is reasonable for services; and  Provide basic information about conflicts of interest. The Adviser benefits financially from

the rollover of a client’s assets from a retirement account to an account managed by the firm. This is a primary conflict of interest because when the Adviser provides investment advice, the assets increase the firm’s assets under management and, in turn, its advisory fees. To meet the fiduciary responsibility the Adviser only recommends a rollover when it is deemed in the client’s best interest. The Adviser currently engages the custodial services of Interactive Brokers and Kingdom Trust Company for investments not held in a SIPP. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Assignment of Investment Management Agreements Agreements are assigned according to client’s address of record (domicile). Types of Agreements The following agreements define the typical client relationships. Investment Management Agreement As part of the investment management service, all aspects of the client’s financial affairs are reviewed, and realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the client, which often includes an annual meeting with the client. The Adviser makes use of portfolio rebalancing software to maintain client allocations according to the Investment Policy Statement in effect. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time. Asset Management Investments may also include equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually through brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. The Adviser does not receive any compensation, in any form, from fund companies. Initial public offerings (IPOs) are not available through the Adviser. Insurance Services The Firm’s Investment Adviser Representatives (IARs) offer insurance products. Products are offered though a third party relationship and not directly through the Firm. Applicable IARs are appropriately licensed to sell insurance products to clients, in the applicable jurisdiction(s), and are allowed to earn commissions on these insurance products in addition to any fees earned from financial planning, investment management or other services offered. The commissions are based on the standard commission schedule of the provider of the insurance products and are generally not negotiable. There is an inherent conflict of interest in providing these products as financial plans or investment management services as the IAR will earn additional fees for recommending the purchase of insurance products. The Adviser does not make any representation that these products are available at the lowest cost and similar products are available from other providers. The client is under no obligation to purchase insurance products through the IARs. When applicable, the Adviser shall mitigate this conflict by reviewing the financial plan or investment policy statement of the client. Wrap Fee Programs HCM-USA does not currently sponsor nor provide management services to any wrap fee program (an advisory program under which a specified fee is charged for investment advisory services and execution of transactions). However, the Firm may recommend that its clients participate in a wrap-fee program, based on the client's specific financial needs and investment objectives. Other Services Clients may also engage us to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, we direct or recommend the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product's provider. In addition, the Firm provides Qualified Account Record keeping services through an affiliated administrator. Termination of Agreements A Client may terminate any of the aforementioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, the Adviser will refund any unearned portion of the advance payment. Adviser will refund any pre-paid, unearned fees based on the number of days remaining in the quarter after the effective date of termination. Refunds will be made within thirty (30) calendar days of the effective date of termination. Adviser reserves the right to charge up to $100 to close an Account. The Adviser reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded within thirty (30) calendar days of the effective date of termination. The Adviser’s Privacy Policy and the Adviser’s Disclosure Statement(s) shall be provided to potential client(s) less than 48 hours prior to, but not later than, the date of execution of the Wealth Management Agreement. Clients shall have the option to terminate the Agreement without penalty within five business days after the date of execution.