A. General Description of Advisory Firm AZA Capital Management (“Adviser” or “AZA” or “we”) is an independent, fee-only investment advisory firm, specializing in managed strategies designed to adjust for changing market conditions. We strive to help long-term investors avoid pitfalls and take advantage of opportunities as markets cycle up and down. Established in 1997, AZA is a private corporation that is owned and operated by its employees. Christopher Recker, Jeffrey Keen, and Michael LaFontaine each own more than 25% of the outstanding common stock of the firm. AZA’s principal place of business is Chicago, Illinois. B. Description of Advisory Services Offered We combine quantitative analysis and qualitative research to help our clients target their investment objectives while navigating the long-term changes in market conditions. Our services are tailored to the needs of each client and include, but are not limited to, the following: Wealth Management For Individuals and Families
• Risk “comfort zone” identification
• Asset allocation guidance and management
• Investment selection and management
• Financial planning related to savings, retirement, and income
• Performance reporting, market commentary, and education Asset Management For Financial Advisors and Their Clients
• Portfolio allocation guidance and management
• Separately managed account strategies
• Strategies provided on third-party TAMP platform
• Market analysis Employer-Sponsored Retirement Plans For Businesses and Organizations
• Identify, develop, and implement plan design concepts that best achieve the goals of recruiting and retention, cost efficiency, and participant retirement readiness.
• Develop/implement policies and procedures to ensure plans meet fiduciary

compliance requirements and adhere to fiduciary best practices. Filed 4/1/2024 5 of 19
• Screen, select, and monitor investment options In some situations, we implement investment advice on behalf of clients in certain held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). The order management system that we use for held-away accounts is provided by Pontera Solutions, Inc. We review, monitor, and manage these held-away accounts in an integrated way with client accounts held at our primary custodians. Further information about this service is available in Item 5. C. Availability of Tailored Services for Individual Clients We have the ability to tailor our services and will provide investment advice and management based on each client’s specific objectives. When practical we will accommodate reasonable client restrictions with respect to certain investments, security types, tax considerations, or account features. Certain investment strategies and portfolios may be more accommodating of restrictions than others. As a result, the performance of an account within a particular investment objective may differ from other accounts within that same investment objective. Differences in portfolio composition may be attributable to a variety of factors, including but not limited to, the type of account, specific investment restrictions and guidelines, and the size and frequency of client contributions and withdrawals. D. Wrap Fee Programs AZA currently does not participate in any wrap fee programs. E. Assets Under Management Calculated as of December 31, 2023 Discretionary Basis: $ 305,544,335 Non-Discretionary Basis: $ 8,242,465 Total Assets Under Management: $ 313,786,800