Description of Firm Fire Capital Management, LLC ("FCM") is a registered investment adviser primarily based in San Francisco, California. We are organized as a limited liability company ("LLC") under the laws of the State of California.
Our mission is to empower our clients to reimagine what is possible to accomplish with their investments, impact goals and legacy. We support High Net Worth (HNW) and Ultra High Net Worth (UHNW) clientele through our tailored Private Wealth Management ("PWM") and customized Multi- Family Office ("MFO") services. We also work with institutional clients, such as private foundations, through our Outsourced Chief Investment Officer ("OCIO") service.
As a fiduciary, we always put our clients' interests first and are relentlessly focused on continuously adding value to every relationship that has entrusted us to serve as their advisor. As an independent investment company, we have the flexibility to leverage our experience to develop custom investment strategies, while providing a higher level of personalized service. As we work to establish our own legacy, we are committed to the highest of ethical standards on how we run our firm and seek out opportunities to create meaningful impact independently, and in partnership with clients. We are proud to lead by example as a Certified B Corp. We have been providing investment advisory services since December 2018. The firm is primarily owned by Michael Firestone.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Fire Capital Management, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
High Net Worth Wealth Management Services* Our comprehensive High Net Worth Wealth Management Platform is purposely designed for the modern wealthy individual or family. Our approach to working with clients is both flexible and highly personalized. We provide customized investment management and advisory solutions to meet your unique needs and investment objectives. To provide personalized service and customized investment strategies, we seek to develop meaningful and enduring long-term relationships with our clients. As part of our onboarding process, we may utilize financial planning software to help develop quantifiable investment goals that may include a combination of retirement saving, investment income targets, college saving goals, tax efficient portfolio management, long-term growth, capital preservation, etc. Once we identify your financial goals and develop a plan of action, we then memorialize the stated objectives in an investment policy statement that will be reviewed annually and revised as needed.
Our role as your family's personal trusted adviser is to be a point of contact that is at the center of your family's financial affairs. As an independent investment firm, we strive to provide our clients with objective advice, that we believe will lead to high quality outcomes. Our client's financial needs and circumstances can at times be quite complex. We work closely with our client's other trusted advisers and may provide recommendations for other professionals (e.g. estate planning attorneys and accountants) to provide support when needed and as requested.
4 We construct investment portfolios based on the needs and preferences of our clients. We work closely with you to identify your investment goals and objectives, as well as risk tolerance and financial circumstances in order to develop your portfolio strategy. We will then construct a tailored portfolio that may be a combination of individual securities such as stocks and bonds, diversified mutual funds, and low-cost Exchange Traded Funds (ETFs). Alternative investments may be appropriate depending on the client's unique situation and investment preference.
*For the HNW Wealth Management Platform, Fire Capital Management requires that you grant the firm and your adviser discretionary investment authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the number of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions in your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. As part of our Wealth Management Services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. Environmental, Social and Governance (ESG) Philosophy Fire Capital Management will also help socially conscious clients invest sustainably and/or align their investment portfolios with their personal values. Our primary responsibility is to help our clients achieve their goals. If sustainability and impact is part of that then we will emphasize it as part of a holistic investment and allocation strategy. We may incorporate Environmental, Social and Governance (ESG) analysis into the security and manager selection process because ESG factors may have a meaningful financial impact on companies that we invest in. A greater focus on ESG analysis may be appropriate for clients who want to focus their portfolio on societal good but may not identify with a specific cause or theme. We will educate our clients around the benefits and potential drawbacks of positive and negative screening associated with investing alongside social causes and beliefs. Our investment approach is flexible and our ability to tailor investment portfolios at the security level allows us to build portfolios that truly represent our client's personal values, while helping them to achieve their financial goals. We may also use ESG, Socially Responsible, and Sustainable ETFs or mutual funds based on client preference and investment rationale.
At Fire Capital Management, we are deliberate in embedding sustainability into our business and investment practices. Our primary responsibility as a fiduciary to our clients is to grow and preserve their wealth. This requires making investments on behalf of our clients. These investments undergo a thorough diligence and research process as part of our investment approach. As part of this process, we must consider any information that may provide deeper insight into potential risks and opportunities of the investments. A critical aspect of these considerations includes being aware of and incorporating sustainability insights and ESG data into the fundamental research process at FCM. Our ability to 5 incorporate sustainability into our process has increased with the broad improvement and availability of sustainability data in recent years. We believe that long-term investing strategies that thoughtfully incorporate sustainability align well with traditional long-term investing principles. As such, sustainable investing is not a separate investment strategy or style at FCM but, instead, is at the core of our investment approach. However, certain clients may work with us with clear objectives to express their personal values or beliefs through their investments. We may utilize ESG data and strategies to tailor investment strategies in support of their goals, while also providing education and perspective if potential risk and return outcomes shift by doing so. We also note our approach makes a clear distinction between sustainable investing and impact investing. For additional information, our Investment Sustainability Policy is available upon request and a copy is provided to all clients. Multi-Family Office Services Fire Capital Management offers multi-family office and financial consulting services designed for UHNW individuals and families to help navigate their family's affairs. We appreciate and understand that

wealthy families may need additional services to support their financial dealings and lifestyle. We serve a distinct role as the family's trusted adviser to professionalize or institutionalize the family's approach to working with their advisers, managing their investments, and dealing with the complexity of family in general.
Fire Capital Management will work closely with the family client to identify how best to support their needs. The individual services for each client will vary as they are tailored for each family. These services may include, but are not limited to, ongoing portfolio and investment manager oversight, holistic portfolio investment strategy, manager due diligence, family bookkeeping, coordination of family meetings, philanthropic planning, and foundation administration. Our financial consulting services may also involve advising clients on a variety of financial-related topics such as risk assessment/management, strategic investment planning, financial organization, or financial decision making/negotiation. These services are very customizable to the specialized needs of our clients and we aim to streamline complex financial matters efficiently and effectively.
Financial Planning Services Fire Capital Management may utilize financial planning expertise, advice, and technology to best serve clients. The financial planning process will often be used as a foundational tool to understand clients' needs and develop clear financial goals. Financial planning may also be used to help identify appropriate investment strategies. The firm's financial planning service is meant to compliment other investment-related services and is mainly intended for prospective and existing clients. We maintain a one-time financial planning fee that is waived for individuals that are or become clients of the firm. We may, at times, provide independent financial planning services to individuals in an effort to support the community and help people in financial distress who may benefit from our professional advice. In those circumstances, any fee that is collected would be accounted for and donated prior to the end of the year to charity. The donation may benefit Fire Capital Management in the form of a tax deduction, community goodwill, and potentially other beneficial unforeseen circumstances could arise. The charity or charities that will receive a donation will be chosen by Fire Capital Management. As part of our financial planning service, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will either discuss the results of our analysis or deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
6 Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Pursuant to California Code of Regulations, 10 CCR Section 260.235.2, Fire Capital Management hereby makes the following statement: in the context of providing financial planning services, a conflict exists between the interest of Fire Capital Management and the interests of the client. This conflict exists because as part of its financial plan, a client can be advised to engage us for portfolio management services which will provide additional income to our firm. Further, the client is under no obligation to act upon Fire Capital Management's recommendations, and if the client elects to act on any of the recommendations, the client is under no obligation to effect the transactions through Fire Capital Management and always has the right to implement any investment advice at any financial institution of their choosing.
All material conflicts of interest under CCR Section 260.238 (k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice.
Outsourced Chief Investment Officer ("OCIO") Program Fire Capital Management also offers customized portfolio solutions to charitable organizations and private foundations through its OCIO Program. OCIO recommended strategies may entail active or passive management strategies in addition to third-party manager oversight and reporting to help the Client achieve the goals and objectives as outlined by the foundation board and/or authorized decision makers. The nature of any OCIO engagement may be non-discretionary, discretionary, or a combination depending on the details set forth by the executed agreement. Portfolios are constructed, implemented, and monitored through our due diligence program. For each manager recommended by Fire Capital, we will typically perform all or some of the following:
•perform regular on-site and digital visits;
•meet with senior personnel to assess organizational and management stability;
•review due diligence protocols;
•review quarterly work product; and
•discuss specific sub-manager activity. Fire Capital reviews many factors, in addition to performance, of a portfolio sub-manager before approval including but not limited to:
•Operational functionality
•Safety of client assets
•Investment Review
•Track Record
•Compliance Once the appropriate areas have been reviewed, Fire Capital makes the determination whether to recommend the sub-manager or not. 7 Wrap Fee Programs We do not participate in any wrap fee program.
Types of Investments We recommend all types of securities and we do not necessarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Some of the security types we offer advice on include equity securities, corporate debt securities (other than commercial paper), municipal debt securities, mutual fund shares, United States government securities, options contracts on securities, money market funds, real estate investment trusts ("REITs"), derivatives, exchange traded funds ("ETFs"), private equity, and venture capital.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management & Assets Under Advisement As of January 1, 2024, we manage $248,607,532 in client assets on a discretionary basis, and $176,545,085 in client assets on a non-discretionary basis. We also manage $699,804,175 in client assets on a non-continuous basis (also referred to as "oversight assets").