Wolf Group Capital Advisors (“WGCA,” the “Firm,” “we,” “us,” or “our”) is an investment adviser and provides investment advisory and financial planning services to individuals, high net worth individuals and trusts. WGCA was founded in 1996 and is owned by Robert D. Len, Leonard S. Wolf, and Charles K. Verruggio. Investment Advisory Services We provide investment advice and implement investment strategies for clients based on their individual circumstances. We manage accounts on a discretionary (which means selection of investments will be made for the client without obtaining consent from the client prior to making a purchase or sale for the account) or non-discretionary basis, depending on the client’s preference. Through personal discussions, we develop portfolios based upon a client’s goals, objectives, investment time horizon and risk tolerance, as well as their core financial-related values. We develop a brief written investment policy statement, including a detailed asset allocation, describing the investment goals and investment strategy. We use asset allocations or spreading investments among a number of asset classes and sectors (domestic stocks vs. foreign stocks; value vs. growth; large-cap stocks vs. small-cap stocks; corporate bonds vs. government securities) for client accounts. The types of securities purchased for client portfolios may include stocks, bonds, exchange traded funds and mutual funds. We may also use alternative investments where applicable, based upon a client’s investment strategy. After reviewing the asset allocation with the client, the investment strategy will be implemented. Investment strategies generally include long-term and short-term purchases depending upon the individual needs of the client. Financial Planning We offer financial planning to clients, which includes an initial meeting with the prospective client to determine the scope of the service desired. Subsequently, a proposal is developed summarizing the issues to be addressed, the analysis to be performed and the fee for the financial planning engagement. The proposal also includes a list of information and items that we require to complete the financial plan. Financial planning may be provided as part of our investment advisory services, or as a standalone service for a fixed fee, or as a monthly subscription service. Financial planning may include a review of all aspects of a client’s current financial situation, including, but not limited to the following components: cash management, insurance planning, education planning, charitable giving, retirement planning, estate tax planning, and capital needs. Financial plan recommendations are not limited to any specific product or service offered by a broker/ dealer or insurance company. With respect to estate planning, we work closely with attorneys qualified to assist clients in the development of wills and trusts. For insurance plans, we work closely with qualified internal and external insurance professionals. Third-Party Asset Management Programs In addition to managing client accounts directly, in certain circumstances, we will recommend that a client engage (for all or a portion of its portfolio) a Third-Party Asset Management Program to provide additional services or expertise that we believe will be beneficial to the client. These services will be outlined in a separately executed discretionary asset management agreement with the Third-Party Asset Manager and will be provided for a fee that is separate and distinct from fees we charge you. Our Investment Advisor Representatives (IARs) will provide personal advisory services to clients in the selection of a particular Third-Party Asset Manager. Factors considered in the selection of a Third-Party Asset Managers include but may not be limited to i) each individual IAR's preference for a particular Third-Party Asset Manager; ii) the client's risk tolerance, goals, and objectives, as well as investment experience; and iii) the size of the client's assets available for investment. In order to assist in the selection of a Third-Party Asset Manager, the IAR will typically gather information from the client about the client's financial situation, investment objectives, and reasonable restrictions the client wants imposed on the management of the account. Our IARs will periodically review reports provided to the client. An IAR will contact the client periodically,

as agreed upon with each client, to review the client's financial situation and objectives, communicate information to the Third-Party Asset Manager managing the account as warranted, and to assist the client in understanding and evaluating the services provided by the Third-Party Asset Manager. Clients will be expected to notify their IAR of any changes in their financial situation, investment objectives, or account restrictions. We will communicate any changes to your investment objectives to the Third-Party Asset Manager managing your account(s). We will provide you with a complete description of the programs and services (including fees to be charged and other contractual information) provided by the Third-Party Asset Manager, as well as the Third-Party Asset Manager’s Form ADV, investment advisory contracts, and account opening documents. Tailored Relationships We tailor investment advisory services to the individual needs of the client. The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objectives. Our clients are allowed to impose restrictions on the investments in their account. We may accept any reasonable limitation or restriction to discretionary authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to us in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs We act as a portfolio manager to two wrap-fee programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. Portfolio Manager for Wrap Fee Programs We offer portfolio management services through two Wrap Fee Programs sponsored by broker/dealers. We make investment selections and create portfolio models for these programs. Clients should refer to the broker/dealer’s Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1) for more detailed information about the services offered in the program. Client Assets As of June 30, 2023, we managed $445,914,061 in assets on a discretionary basis.