A. Description of the Advisory Firm Revolution Capital, LLC (hereinafter “RevCap”) is a Limited Liability Company organized in the State of Nebraska. The firm was formed in January 2019, and the principal owner is Revolution Group, LLC. B. Types of Advisory Services Portfolio Management Services RevCap offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RevCap creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. 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 RevCap evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. RevCap 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. For certain alternative investments, discretionary trading is not possible. In these cases, the client will be consulted prior to the execution of the investment recommendation. RevCap seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RevCap’s economic, investment or other financial interests. To meet its fiduciary obligations, RevCap attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, RevCap’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 RevCap’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services RevCap 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. Written Acknowledgement of Fiduciary Status 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. Services Limited to Specific Types of Investments RevCap generally limits its investment advice to mutual funds, fixed income securities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. RevCap may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions RevCap will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by RevCap on behalf of the client. RevCap may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent RevCap from properly servicing the client account, or if the restrictions would require RevCap to deviate from its standard suite of services, RevCap reserves the right to end the relationship. D. Wrap Fee Programs RevCap acts as portfolio manager and sponsor for a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. However, this brochure describes RevCap’s non-wrap fee advisory services; clients utilizing RevCap’s wrap fee portfolio management should see RevCap’s separate Wrap Fee Program Brochure. RevCap manages the investments in the wrap fee program. RevCap receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5 and Item 12 of this brochure. E. Assets Under Management RevCap has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 134,352,477.00 $ 6,398,865.00 December 2023 As of December 2021, RevCap has $ 2,592,062.00 in assets under advisement.