A. Description of the Advisory Firm XPS Capital LLC (hereinafter “Cope Corrales”) is a limited liability company organized in the District of Columbia. The firm was formed in May 2019 and was registered as an investment advisor in November 2020, and the principal owners are Luis Corrales and Joseph Cope. B. Types of Advisory Services Portfolio Management Services Cope Corrales offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Cope Corrales creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Cope Corrales evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Cope Corrales will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Cope Corrales seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Cope Corrales’s economic, investment or other financial interests. To meet its fiduciary obligations, Cope Corrales attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Cope Corrales’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 Cope Corrales’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. Pension Consulting Services Cope Corrales offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Investment planning involves working with clients to make sure their investments match their respective risk tolerance and goals. Tax concerns are addressed by working with the client to determine and compare effective tax rates for income, capital gains and other earnings or investments, then attempting to allocate the client’s resources accordingly. Life insurance planning entails reviewing the life insurance and/or disability insurance needs of the client, together with any applicable dependents, spouse or other relatives, and assessing appropriate coverage for these individuals. College planning entails helping clients save for higher education, whether for the client or his/her children or other dependents, in the ideal manner to suit the client’s overall financial goals and means. Financial

planning to address retirement entails making sure clients are financially equipped for retirement in light of the client’s anticipated income and expenses, investments, and other assets. Debt/credit planning consists of breaking down client budgets and aiding clients in decision-making as to current debt, anticipated significant expenses and potential debt, and avoiding excessive debt. Pontera Services We provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily = Employer Sponsored Retirement Plans that we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. This fee will be assessed and billed monthly. These directly managed accounts are held away, such as 401(k)’s. As it is impossible to directly debit the fees from these accounts, those fees will be debited from the client’s taxable account on a pro-rata basis. If the client does not have a taxable account, those fees will be billed directly to the client. Private Placement Consulting Services Cope Corrales also provides advice about certain privately placed securities to clients (“Private Placement Consulting”). The Private Placement Consulting includes:
• advice on the source of funds for the private placement, in respect to their entire financial picture.
• determine individual client suitability of private placement investment and continue to monitor during holding period.
• Conduct due diligence on the Private placement opportunity including reviewing the operators, financials and deal structure.
• Maintain continual communication with fund, fielding questions from clients and providing an intermediary between the fund and client.
• Advice on follow-on funds and coordinate with their unique and specific financial circumstances.
• Capital Call Management. Subscription Services Cope Corrales provides a newsletter only to clients using Cope Corrales’s other advisory services and for free; it does not entail an additional fee. It will offer recommendations on purchasing and selling specific securities, sectors, asset classes, or other specific groupings of securities at a stated time, but clients are not obligated to act on the recommendations mentioned in the newsletter. These recommendations are separate and apart from the advisory services of the firm and do not overlap. Services Limited to Specific Types of Investments Cope Corrales generally limits its investment advice to mutual funds, fixed income securities, real estate funds, insurance products including annuities, equities and ETFs. Cope Corrales may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Cope Corrales offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Cope Corrales does not participate in any wrap fee programs. E. Assets Under Management Cope Corrales has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $153,322,757 $124,486 December 2023