Our Advisory Business Swan Capital is a Florida domiciled investment adviser, currently registered with the States of Florida and Alabama. The Adviser was founded in 2012 by its principal owner, Andrew McNair, and registered in 2019. Services Swan Capital offers asset management, financial planning, private placement consulting, and consulting services, with an emphasis on building portfolios designed to meet the needs of our clients. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Active Asset Management Model Portfolios We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and will recommend one or more of our model portfolios. Please note that due to our investment strategies in our models, you shall not have the ability to impose restrictions on the management of your account. Refer to Item 8 below for a description of each model and the risks associated with the analysis methods and products involved with the models. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. Additionally, trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Periodically, your account will need to be rebalanced or reallocated in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur as dictated by the model. You will be responsible for all tax consequences resulting from the sale of any security, rebalancing or reallocation of the account. You are responsible for any taxable events in these instances. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction Swan Capital ADV Part 2A March 26, 2024 Page 5 of 22 activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. Your custodian will provide you with quarterly performance statements. These statements give you additional feedback regarding performance, educate you about our long-term investment philosophy, and describe any changes in current strategy and allocation along with the reasons for making these changes. Tailored Portfolio Services As part of the active asset management process, we do not offer tailored portfolios. Financial Planning and Consulting Financial Planning Swan Capital also offers comprehensive and modular financial planning. Comprehensive and modular financial planning may cover one or all of the following: a. Retirement Income Planning; b. Legacy Planning with beneficiary review; c. Tax Planning in regard to investment decisions; d. Review of their insurance needs (life insurance and long-term care); e. Review of client’s investment allocations and diversification among asset classes. Fee based financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or

other professionals. If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. Swan Capital ADV Part 2A March 26, 2024 Page 6 of 22 We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision. Consulting We can also work with you in a project based or ongoing consulting capacity. Based upon your needs, we may also provide consultations throughout the year to advise and counsel you about other financial issues. Financial consulting services can include any or a combination of the following:
• Review of current portfolio
• Income tax planning
• Life and disability insurance needs
• Budgeting
• Retirement needs
• Estate planning needs Project based consulting may include but is not limited to the purchase of a new home, household budgeting, business transition, etc. Ongoing consulting may include but is not restricted to ongoing reviews of portfolio held away from Swan Capital, ongoing reviews of household budgeting and spending, educational savings, etc. Consulting services will be provided on an ongoing basis for a period of time determined between Swan Capital and the client. Some consulting services will result in a written report while others will be handled through ongoing consultations between the Adviser and Client. Educational Seminars We offer no charge educational seminars which go over the importance of preparing for the financial future. Our seminars focus on common retirement topics, including how to prepare for unexpected medical expenses and ways to create income to help support your desired lifestyle. Recommendations If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. While Swan Capital endeavors at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving additional compensation based on the recommendations made creates a conflict of interest and may affect Swan Capital’s judgment when making recommendations. We require that all investment adviser representatives disclose this conflict of interest when such recommendations Swan Capital ADV Part 2A March 26, 2024 Page 7 of 22 are made, and that the client is not obligated to implement the recommendations made within the plan through Swan Capital. Private Equity Real Estate Fund Management Swan Capital is the general partner and investment adviser for Cygnet Fund, LP, a limited partnership formed as a private fund (“Cygnet”). Cygnet operates as a private equity real estate fund in accordance with the investment objective and investment strategy described in the fund’s offering documents. Cygnet currently relies on an exemption from registration under the Investment Company Act of 1940, as amended. Swan Capital does not receive any compensation (outside of its management and performance fee as set forth in Item 5) if a client invests in Cygnet. While Cygnet is generally Swan Capital’s client, the term “client(s)” sometimes refers to the investors in Cygnet. Participation as an investor in the Cygnet Fund is restricted to investors who are “qualified clients” pursuant to Rule 205-3 under the Advisers Act, as well as those who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, and “qualified purchasers” as defined under the Investment Company Act of 1940, as amended. To the extent certain of Swan Capital’s individual wealth management clients qualify, they will be eligible to participate as limited partners of Cygnet. Investment in Cygnet as a limited partner involves a significant degree of risk. Investors should review relevant information, terms and conditions relative to Cygnet, including but not limited to suitability, limited rights of redemption, risk factors and potential conflicts of interest, which are set forth in the confidential private placement memorandum, Partnership Agreement, and Subscription Agreement (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in Cygnet. For additional information regarding the Cygnet Fund, please refer to the Offering Documents. Wrap Fee The Adviser does not sponsor or participate in a third-party sponsored wrap fee program. Assets Under Management As of December 31, 2023, we have $190,671,290 in discretionary assets under management.