A. Firm Information In July 2020, Fjell Capital, LLC (“Fjell,” the “Firm,” “We,” “Our,” “Us”) was organized as a limited liability company under the laws of the state of Delaware. Subsequently, in August 2023, the Firm’s registration as an investment adviser became effective with the Securities and Exchange Commission1. Mr. Thomas Stadum, the Founder and Chief Executive Officer of Fjell, owns 100% of the Firm. B. Description of Advisory Services Fjell offers investment advisory services to individuals and high-net-worth individuals (collectively, “client” or “clients”). The Firm’s service offerings include Scale and Altitude. Both offerings include a wide range of financial planning services combined with investment management. However, Scale and Altitude’s services are custom-tailored to the needs of different types of clients. The following section provides a complete description of each advisory service. Scale Scale is a custom-tailored wealth solution that combines the components of financial planning and investment management. It is designed to address the specific needs, goals, and concerns of the Millennial Generation2 (“Millennials”). Scale is ideal for clients with annual incomes of $125,000 or more. Millennials typically have complex financial lives, which generally include many competing goals. Through the financial planning process, Scale is designed to address many of Millennials’ competing goals. These goals include, but are not limited to:
• Cash flow and debt management
• Establishing a financial budget
• Creating an emergency fund
• Optimizing an investment portfolio
• Purchase of a home
• Scaling a business
• Addressing insurance needs
• Improving credit scores
• Investment Planning
• Saving for college
• Career management 1 Registration as an investment adviser with the Securities and Exchange Commission is not intended to imply any level of skill or training. 2 Millennials are generally individuals that were born between 1981 and 1996 (between the ages of 27 to 42 years old).
• Selecting and managing employee benefits
• Saving for retirement
• Managing stock options
• Leasing vs. buying a car
• Tax planning strategies Scale’s Investment Management Component Most clients also utilize Scale for ongoing investment management services (these “Services”). These Services are offered exclusively on a discretionary basis and involve consistent communication and collaboration to deliver solutions tailored to the client’s specific needs. The Firm works closely with each client to determine their investment objectives and risk tolerance to construct the optimal asset allocation. Asset allocation consists of allocating client assets amongst various asset classes to seek the optimal return for a given level of risk. Once the optimal asset allocation is agreed upon, the Firm will construct a portfolio comprising equity securities, exchange-traded funds (ETFs), fixed-income securities, and cash equivalents. The types of fixed- income securities purchased will depend on tax status and risk tolerance. Cash equivalents may include money market funds, T- Bills, municipal notes, certificates of deposit, and other fixed-income securities that typically mature in one year or less. However, Fjell also provides advice on a wide range of securities when positions are transferred into a discretionary investment management account managed by Fjell. Recommendations to sell mutual funds and other securities may take into consideration the level of portfolio diversification and tax consequences. The Firm’s investment strategies are primarily long-term focused, but the Firm may buy, sell, or re-allocate positions held for less than one year to meet the client’s objectives or due to market conditions. After constructing a portfolio, Fjell will continuously monitor it to ensure it is on track to meet the goals and objectives based on the client’s agreed-upon risk tolerance. Conflicts of Interest Related to Scale As a component of Scale’s financial planning services, Fjell will generally recommend implementing its strategies through ongoing investment management services for a percentage of assets managed. Additionally, Fjell may recommend purchasing life insurance products for which the Firm’s investment adviser representatives receive insurance commissions in their individual capacities as insurance agents. It is important to note that the receipt of incentive compensation in the form of investment management fees and insurance commissions creates a material conflict of interest. Clients are under no obligation to implement Fjell’s financial planning recommendations by utilizing its investment management services or purchasing term life insurance products. For more detailed information regarding material conflicts of interest, we encourage you to refer to the following sections: “Item 5 – Fees and Compensation”, Item 10 – Other Financial Industry Activities and Affiliations”, and “Item 12 – Brokerage Practices.” These sections provide a comprehensive understanding of our practices and the associated conflicts of interest. Scale’s Investment Management Component – Limited Exceptions for Standalone Investment Management While Scale is primarily designed as a comprehensive wealth management solution for Millennials, integrating financial planning and investment management, there are limited exceptions. Under specific circumstances, Fjell may offer the investment management component of Scale on a standalone basis, without the accompanying financial planning services. Conditions for Exception This exception is made available only to a limited number of clients, based on individual circumstances that align

with Fjell’s investment strategies and philosophy. This limited exception does not constitute separate services and is aligned with the Firm’s focus on comprehensive wealth management solutions. Fee Structure for Exceptions The fee structure for clients receiving only the discretionary investment management component will align with the existing Scale fees for this component. Any variations or specific terms will be discussed and agreed upon in writing with the eligible client. Altitude Altitude is our traditional wealth management solution. This solution combines components of financial planning, specifically cash flow planning and lifestyle maintenance, and investment management, referred to as “efficient capital allocation,” and is specifically geared to pre-retirees3 with $500,000 or more in assets. At this stage of life, goals of pre- retirees include, but are not limited to:
• Retirement cash flow
• Selling a business
• Tax-efficient investing
• Asset protection
• Legacy and estate planning
• Large real estate transactions
• Liquidating stock options
• Tax planning strategies Altitude’s Proprietary Wealth Mapping System Altitude’s proprietary Wealth Mapping System is focused on three critical areas which we believe have the most significant impact on the lives of our clients. These areas include:
• Efficient capital allocation (investment management component)
• Cash flow planning
• Lifestyle maintenance Efficient Capital Allocation is at the heart of our investment philosophy and represents both the discretionary and non- discretionary investment management component of Altitude. We diligently assess and allocate client capital to maximize returns for a given or assumed level of risk. Through rigorous research and analysis, we identify opportunities that align with 3 Generally, we define pre-retirees in the age range of 55 – 65 with plans of retiring in two to ten years. objectives and construct well-diversified portfolios based on modern portfolio theory and asset allocation principles. Continual monitoring and adjustment ensure intelligent deployment, enhancing long-term financial outcomes. The products utilized to meet client objectives include exchange-traded funds (ETFs), no-load mutual funds, equities, fixed- income securities, and cash equivalents. Cash equivalents may include money market funds, T-Bills, municipal notes, and certificates of deposit. However, the Firm also provides advice on a wide range of securities when positions are transferred into an investment management that we are managing. Recommendations to sell mutual funds and other securities may take into consideration the level of portfolio diversification and tax consequences. Cash flow planning is integral to our advisory services. We work closely with clients to understand their income, expenses, and saving goals. By analyzing current and projected cash flows, we develop tailored strategies for optimized liquidity, responsible spending, and debt management. We aim to provide clients with a clear roadmap to make informed decisions and achieve their goals. Lifestyle maintenance is a core part of our services. We understand clients’ unique lifestyle choices and goals. By assessing financial resources, we create customized strategies to sustain desired lifestyles. We provide guidance on budgeting, investments, and risk management to ensure long-term security and peace of mind. Conflicts of Interest Related to Altitude As a component of Altitude’s financial planning services, Fjell may recommend purchasing fixed annuity products for which the Firm’s investment adviser representatives receive insurance commissions in their individual capacities as insurance agents. It is important to note that the receipt of incentive compensation in the form of insurance commissions creates a material conflict of interest. Clients are under no obligation to implement Fjell’s financial planning recommendations by purchasing fixed annuity products. For more detailed information regarding material conflicts of interest, we encourage you to refer to the following sections: “Item 5 – Fees and Compensation”, Item 10 – Other Financial Industry Activities and Affiliations”, and “Item 12 – Brokerage Practices.” These sections provide a comprehensive understanding of our practices and the associated conflicts of interest. C. Tailored Advisory Services Both of Fjell’s offerings (e.g., Scale, Altitude) are tailored to each client’s individual needs. Clients are permitted to place reasonable restrictions on purchasing certain securities or the types of securities purchased. Services Tailored to the Individual Needs of Each Client and Imposition of Reasonable Restrictions By its very nature, the financial planning services component of both Scale and Altitude are custom- tailored to each client’s individual needs. The investment management services component allows tailored solutions and reasonable restrictions. Based on a client’s risk tolerance and goals, Fjell will develop a custom-tailored solution to help clients meet their individual needs. Reasonable restrictions may include concentration risk limits (e.g., asset class exposure, industry exposure, single stock exposure), liquidity requirements (maintenance of sufficient liquidity), socially responsible investing (incorporating specific environmental, social, or governance considerations when purchasing equities, ETFs, or mutual funds). D. Wrap Fee Programs Fjell does not participate in or offer wrap fee programs. E. Assets Under Management The amount of client assets managed by Fjell totaled $129,656,341 as of March 20, 2024. $119,268,454 of client assets are managed on a discretionary basis, and $10,387,887 are managed on a non-discretionary basis.