OWNERSHIP/ADVISOR HISTORY Luminist Capital, LLC was formed in August 2014. It is owned by Luminist Holdings, LLC. It is a Michigan limited liability company. It was registered as an investment adviser in Michigan in June 2015 and subsequently became registered with the SEC in July 2022. ADVISORY SERVICES OFFERED Prior to the Adviser/Client relationship, the firm may offer a complimentary general consultation to discuss services available and to give a prospective client time to review services desired. Investment advisory services begin only after the client and firm formalize the relationship with a properly executed client agreement. After engaging the firm, the client will be asked to share in a data gathering and discovery process in an effort to determine the client’s stated needs, goals, intentions, time horizons, risk tolerance and investment objectives, based upon information provided by the client and the nature of services requested. The client will then be placed in one or more of the firm’s portfolios. They are: Market Participation and Tactical Market Participation Models The Luminist Capital Market Participation models are designed to provide low-cost passive participation in a diversified blend of liquid ETFs. The allocation between equities and fixed income are based upon each investor’s risk appetite. The models are rebalanced quarterly, and dividends are reinvested according to investor preferences. The Luminist Capital Tactical Market Participation models are intended to provide low-cost participation in diversified combinations of liquid ETFs selected for specific market regimes. The holdings in the models are allocated toward equities, fixed income and alternative assets classes based upon the prevailing and expected market regimes. The models are rebalanced quarterly and as market regime shifts occur. Dividends may be reinvested according to investor preferences. All Weather Models The Luminist Capital All Weather Models aim to provide investors with improved risk-adjusted returns compared to their benchmarks across various economic environments. The models invest in a diversified portfolio of low-cost exchange-traded funds (ETFs) that offer exposure to commodities, fixed income, and equity sectors, including technology, consumer staples, and health care. The models are constructed to be resilient across different market conditions, with a focus on long-term performance. All Weather models are constructed around five core ETFs that are selected based on their ability to provide broad exposure to key asset classes while keeping costs low. The models are rebalanced quarterly to maintain target allocations and adjust to changing market dynamics. Variations of the All Weather model can be tailored to accommodate specific investor preferences, such as a focus on yield or varying degrees of risk appetite. By adjusting the allocation weights within the core ETFs or incorporating additional ETFs with different risk-return profiles, the models can be customized to meet the unique investment objectives and constraints of individual clients. Luminist Capital, LLC Page 5 ADV Part 2A – 3/28/2024 Risk Managed Models The Luminist Capital Risk Managed Models aim to provide investors with protection against negative market movements while maintaining upside potential. The models utilize exchange- traded funds (ETFs) that employ options and option overlays as hedging strategies to mitigate risk and manage volatility. Variations of these models can focus on yield generation, downside protection, or upside participation and can be customized to accommodate varying risk appetites. The models employ a dynamic risk management approach by incorporating ETFs that utilize options and option overlays to hedge against adverse market movements. These strategies are designed to provide downside protection during market downturns while allowing for participation in positive market trends. The models may include ETFs that offer downside buffers or employ defined protection strategies to limit potential losses. The Risk Managed models prioritize risk management by employing ETFs with built-in hedging mechanisms and downside protection strategies. Active monitoring and periodic adjustments ensure that the portfolio remains aligned

with its risk objectives and market conditions. Variations of the Risk Managed models can be tailored to meet specific investor preferences and risk profiles. Customization options may include adjusting the allocation weights within different ETFs, selecting ETFs with varying levels of downside protection or upside participation, or incorporating additional ETFs to enhance yield generation or risk management. Stock Portfolio The firm will create a portfolio consisting mainly of individual stocks. The portfolio will be tailored the client’s investment goals and objectives. For example, a portfolio may be designed for growth or income depending upon the specific goals of the client and size of the account. Financial Planning and Consulting Services The Adviser offers clients financial planning and consulting services to evaluate their financial situation, goals and risk tolerance. Through a series of personal interviews and the use of questionnaires the Adviser will collect pertinent data, identify goals, objectives, financial problems, potential solutions, prepare specific recommendations and implement recommendations. As a result of these actions, the Adviser’s advice may be provided on financial and cash management, risk management, financial issues relating to divorce or marital issues, estate planning, tax issues, stretch IRA planning, Investment Planning/Asset Allocation, retirement planning, educational funding, goal setting, or other needs as identified by the client and Adviser. The Adviser may offer broad-based written planning services, or the client may desire advice on certain planning components that does not include a written plan; the Adviser can tailor services as desired by the client. Selection of Third-Party Investment Advisers After an initial meeting with the client and when deemed appropriate, we may recommend the services of an independent investment adviser (“Third Party Adviser”). The recommendation will depend on the client’s circumstances, goals and objectives, strategy desired, account size, risk tolerance, or other factors. Working with the client we determine which Third Party Adviser may be appropriate. We will review Third Party Advisers prior to making a recommendation to the client. We will Luminist Capital, LLC Page 6 ADV Part 2A – 3/28/2024 consider the following factors during its review: fees, reputation, performance, financial strength, management, price, reporting capabilities, client’s financial situation, client’s goals, client’s needs, and client’s investment objectives. After its review we will present the client with one or more recommendations. If the client wishes to proceed with the recommendation, we will enter into a promoter relationship with the recommended Third-Party Adviser. The promoter relationship means our firm and the Third-Party Adviser will have separate rolls while serving the client. In effect, the client will engage both us and the Third-Party Adviser to serve his/her accounts and we and the Third-Party Adviser will provide separate services to the client. Under this arrangement, the Third-Party Adviser will be responsible for portfolio management, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. While we will maintain our relationship with the client by monitoring the status of the client’s accounts with the Third-Party Adviser, make recommendations about the performance of the Third-Party Adviser, and acting as the client’s primary financial adviser. All questions regarding the Third-Party Adviser’s services and performance shall be directed to us. When using the services of a Third-Party Adviser, clients will be given a copy of its Form ADV Part 2A. Clients are encouraged to read and understand this disclosure document. TAILORED SERVICES The firm’s services are individualized to each client. Portfolio management clients may impose restrictions on investment in certain securities or types of securities. All restrictions must be presented to the Adviser in writing. WRAP PROGRAM The firm does not sponsor or participate in a wrap program. This section is not applicable. CLIENT ASSETS MANAGED As of December 31, 2023, the firm manages $128,575,454 in client assets on a discretionary basis and $0 on a non-discretionary basis.