Description of Services and Fees ZEGA Investments, LLC is a registered investment adviser with its primary place of business in West Palm Beach, Florida. We are organized as a limited liability company under the laws of the State of Florida. John ("Jay") Pestrichelli is our principal owner. We offer Portfolio Management Services which are personalized to each individual client and Sub-Advisor Services for other registered investment advisors. The following paragraphs describe our services and fees. Please 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 ZEGA Investments, LLC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. 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 for your account) by providing our firm with your restrictions and guidelines in writing. Sub-Advisory Services We offer sub-advisory services to unaffiliated third party money managers (the “Primary Investment Adviser”). As part of these services, we will provide model portfolios, which the Primary Investment Adviser selects for their clients. We will not directly manage the Primary Investment Adviser’s individual client accounts. The Primary Investment Adviser will be responsible for selecting the appropriate model for its clients. Wrap Fee Program(s)

We are a sponsor of a wrap fee program, which is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes administrative fees, management fees, and commissions. If you participate in our wrap fee program, you will pay our firm a single fee, which includes our money management fees, certain transaction costs, and custodial and administrative costs. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. Transactions for your account must be executed by Charles Schwab & Co., Inc. ("Schwab") a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. To compare the cost of the wrap fee program with non- wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by Schwab or other broker-dealers, and the advisory fees charged by investment advisers. For more information concerning the Wrap Fee Program, please see Appendix 1 to this Brochure. Types of Investments We primarily offer advice on broad market and sector ETFs (exchange traded funds), equities, and index futures, in conjunction with options to create hedging strategies. Additionally, we may advise you on any type of investment that we deem appropriate 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. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. We manage wrap and non-wrap fee accounts. Wrap accounts are usually managed using a shorter- term investment strategy. A short-term investment strategy will typically involve purchasing and selling securities within a relatively short period of time based on these securities’ short-term price fluctuations. Wrap accounts consequently involve more frequent trading which would typically incur higher transaction costs if the account was in a non-wrap program. We generally manage non-wrap fee accounts using a long-term investment strategy, although occasionally there may be some short term trades if market circumstances warrant. A long-term investment strategy will typically involve investing in securities that are anticipated to grow in value over a relatively long period of time and it would be expected that there would be lower turnover (i.e., fewer overall trades) than in an account using a shorter-term strategy. If you participate in our wrap fee program, we will provide you with a separate Wrap Fee Program Brochure explaining the program and costs associated with the program. Assets Under Management ZEGA will manage all assets on a discretionary basis in accordance with the terms and conditions of the Fund’s Governing Documents. ZEGA is relying on the 120-day exemption to establish regulatory assets under management to permit it to register as an investment adviser with the SEC. ZEGA will update this information upon meeting the eligibility requirements for registration.