Comprehensive Capital Management, Inc. is an investment adviser firm registered with the U.S. Securities and Exchange Commission (“SEC”) with its principal place of business located in Rockaway, New Jersey. Comprehensive Capital Management, Inc. began conducting business in 2002. For clarity, we refer to Comprehensive Capital Management, Inc. throughout this brochure as “CCM”, the “firm”, “our” or “we”. Timothy Liam Smith, President is the firm's principal shareholder (i.e., those individuals and/or entities controlling 25% or more of this company). Our firm offers services through our network of investment advisor representatives (“Advisor Representatives” or “IARs”). IARs may have their own legal business entities or doing business as (dba) names whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Client should understand that the businesses may be legal entities of the IAR and not of our firm CCM. The IARs are under the supervision of our firm CCM, and the advisory services of the IAR are provided through our firm, CCM. Our firm CCM has the arrangement described above with the following Advisor Representatives:
• Harper & Hodge David Hodge, Daniel Hodge, Raymond Harper, Lori Hodge, Zachary Davidson
• Senior Resources Jeffery Fox
• AmeriWealth Management Dov Fobar
• Oberlander Dorfman Mark Dorfman
• East main Street Advisors Thomas McEvoy
• Alan Weingarten
• Scott Daly We offer various advisory services to our clients. However, it is important to understand that our firm enables its financial advisors, who are sometimes referred to as investment adviser representatives (“IARs”), to provide customized advice to their clients. These IARs are permitted great latitude in selecting investments, investment strategies and delivering investment advice to our clients, which remains subject to the supervision of our compliance department. Each of the advisory programs that our IARs may use in servicing their clients is described in greater detail below. Unless otherwise agreed to by us, APW Capital, Inc., a registered broker-dealer and our affiliate, provides brokerage services as the introducing broker-dealer on transactions in the underlying brokerage account of the client’s account, and Pershing, LLC acts as custodian and provides execution and clearing services. We also allow clients to hold assets with variable annuity issuers and directly with mutual fund sponsors. Please refer to Item 12 for additional information about these arrangements. INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides ongoing advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and generally will include advice regarding the following securities:
• Exchange-listed securities
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual funds and exchange-traded funds
• United States governmental securities
• Options contracts on securities
• Structured Products and Structured Notes
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests Because some types of investments involve certain additional degrees of risk, they only will be implemented or recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. MODEL PORTFOLIO SERVICES Our firm provides both continuous and periodic portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. Below is more information about the style of the model portfolios that we offer. (1) Strategic Asset Allocation: allocation of client assets to be selected from among a broad universe of mutual funds/ETFs, asset classes and style categories in accordance with a client's investment objectives; (2) Tactical Asset Allocation: allocation of client assets among mutual fund/ETF classes with an overlay of technical analysis, i.e. asset management charting software; (3) Vanguard ETF Strategic Model Portfolios: The Vanguard model portfolios seek to provide broad exposure to U.S. and international equities and global investment-grade taxable bonds in an asset allocation framework. They are designed to manage risk through asset allocation and broad diversification and do not contemplate active management. The portfolios are designed using Vanguard ETFs and potentially mutual funds and money market funds. The portfolios are created by Vanguard’s Investment Strategy Group, but we retain the responsibility for portfolio trading and rebalancing and may ultimately override decisions made by Vanguard. (4) In addition, through one or more of our IARs, a technical analysis signal program may be offered to and subscribed to by other unaffiliated investment advisers for a fee. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. The timing of reviews and rebalancing activity is driven by your discussions with your IAR and what you agree is appropriate for your investment objectives. We may rebalance the portfolio on an annual, semi-annual or quarterly basis. Alternatively, we may rebalance your account on a more frequent basis based on market conditions or based on the stated percentage of drift in your account from the model. Through personal discussions with the client in which the client's goals and objectives are established, we determine if the model portfolio is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Because some types of investments involve certain additional degrees of risk, they only will be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. send periodic written reminders to each Model Portfolio Management Services client requesting any updated information regarding changes in the client's financial situation and investment objectives; 2. at least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 3. be reasonably available to consult with the client; and 4. maintain client suitability information in each client's file. INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides asset management of client funds based on the individual needs of the client on a periodic basis too. Through personal discussions in which goals and objectives based on the client's particular circumstances are established, we develop the client's personal investment policy. We create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Once the client's portfolio has been established, we review the portfolio at a time agreed upon between the IAR and the client. At that time, a client’s IAR will review the portfolio and make any investment recommendations or decisions that he or she determines are appropriate. Our investment recommendations

are not limited to any specific product or service offered by any particular broker-dealer or insurance company. The individual portfolio management service is typical for advice that we provide to a client’s variable annuity or life insurance contract or retirement plan where the client might not require ongoing investment advice. Because some types of investments involve certain additional degrees of risk, they will be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability, and best interest. RETIREMENT PLAN CONSULTING SERVICES We also provide several advisory services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Consulting Services are comprised of four distinct services. Clients may choose to use any or all of these services. Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We will meet with the client (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We will then review various mutual funds (both index and managed) and/or ETFs to determine which investments are appropriate to implement the client's IPS. The number of investments to be recommended will be determined by the client, based on the IPS. Monitoring of Investment Performance: We monitor client investments continually, based on the procedures and timing intervals delineated in the Investment Policy Statement. Although our firm is not involved in any way in the purchase or sale of these investments, we supervise the client's portfolio and will make recommendations to the client as market factors and the client's needs dictate. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we may also provide periodic educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. SELECTION AND MONITORING OF THIRD-PARTY MONEY MANAGERS We also offer advisory management services to our clients through our Selection and monitoring of Third- Party Money Managers programs. Third-Party Money Managers currently used include, but are not limited to, SEI Investment Company ("SEI"), AssetMark, Brinker Capital and Morningstar. From time to time, we may offer another manager without updating this list. Our firm provides the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Personal Investment Policy Statement ("PIPS"). Based on the client's individual circumstances and needs (as exhibited in the client's PIPS) your IAR will then select a third party manager from an approved list of managers. Your IAR may consider various factors in selecting a third party manager, including their preference for a third party manager, your account size, risk tolerance, the opinion of each client and the investment philosophy of third party manager. Clients should refer to the selected registered investment adviser's Firm Brochure or other disclosure document for a full description of the services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. Once we select a third-party manager for the client, we provide the selected adviser with the client's PIPS or the client otherwise provides their PIPS to the adviser. The adviser then creates and manages the client's portfolio based on the client's individual needs as exhibited in the PIPS. We monitor the performance of the selected investment adviser. If we determine that a particular selected adviser is no longer appropriate, or is not managing the client's portfolio in a manner consistent with the client's PIPS, we may suggest that the client contract with a different investment adviser or program sponsor or we may use our discretion to select a new investment adviser. Whether we maintain discretion to select a new investment adviser is outlined in our investment advisory agreement. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We may review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We may analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client’s current income tax and future tax liability.
• INVESTMENTS: We may analyze investment alternatives and their effect on the client’s portfolio.
• INSURANCE: We may review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile.
• RETIREMENT: We may analyze current strategies and investment plans to help the client achieve his or her retirement goals. DEATH & DISABILITY: We may review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We may assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. All recommendations are of a generic nature. ACTIVE MANAGEMENT SERVICES Comprehensive Capital Management, Inc. provides the management of individual clients' portfolios, rendering advice as to the advisability of moving from one or more mutual funds or ETFs into either a more conservative fund or money market fund (and vice versa) in an attempt to capture gains during rising markets and to preserve the client's capital during falling market periods. Our active management service is of a continuous nature, evaluating holdings and market positions on an ongoing basis. In order to effectively manage client funds, we generally require that each client provide the firm with discretion. It is also noted that certain mutual funds allow for telephone switching services. This is perhaps the quickest way in which to effect a transaction on the client’s behalf. As such, our firm will offer this service to a client, if the particular mutual fund under active management consideration has provisions for telephone switching privileges. If market conditions were to change rapidly, we are able to assist our clients in achieving the fastest possible response, given the individual circumstances. Our primary objective is to preserve and increase the aggregate capital funds of any client, although we can make no guarantees of reaching this objective. Clients and prospective clients should review the risk factor in Item 8 under the heading “Market Timing”. AMOUNT OF MANAGED ASSETS As of December 31, 2023 we were actively managing $48,291,805.10 of clients' assets on a discretionary basis plus $0.00 of clients' assets on a non-discretionary basis.