View Capital RIA is an investment adviser registered with the Securities and Exchange Commission. View Capital RIA, formerly known as Bluffview RIA, LP, was formed in Dallas, Texas in 2004. The Firm is principally owned by View Capital Advisors, LLC, a Texas Limited Liability Company. Historically, View Capital RIA characterized certain of its investment programs as wrap fee programs; however, the Firm has reevaluated this stance and determined that it no longer serves as the sponsor of, or manager under, a wrap fee program. View Capital’s primary business involves managing client assets in one of two investment management programs, each with its own respective agreement. The first program is the View Capital Advisory Program (“VCAP”) which includes advisory and financial planning services. The second program is the View Capital Consulting Program (“VCCP”) which includes investment consulting and financial planning services. In order for clients to access specialized investments, View Capital RIA occasionally forms pooled investment vehicles (“Pooled Investment Vehicles”) in order to aggregate client access and avail them access to certain opportunities to which they may not otherwise have access. These Pooled Investment Vehicles may consist of a single asset or multiple portfolio investments, such as direct private equity and debt investments, and energy exploration and development opportunities. These Pooled Investment Vehicles may be structured as a limited partnership, limited liability companies or other corporate structures. The Pooled Investment Vehicles are generally controlled by an affiliate of the Firm, which serves as the General Partner or comparable managing entity in other corporate structures. View Capital Advisory Program The VCAP offers clients the ease and efficiency of a traditional registered investment adviser program with primary client contact maintained by View Capital RIA. Other benefits may include a single client contract with a one-page services selection and fee arrangement, access to multiple asset classes and asset managers. VCAP offers clients the choice of two independent custodians, Pershing Advisor Solutions, an affiliate of Pershing, LLC (“Pershing”) and Charles Schwab Institutional (“Schwab”), for execution of securities transactions, trade execution and clearing needs. Portfolios managed under VCAP generally consist of allocations to separate account managers, mutual funds and alternative asset managers such as hedge funds, fund of funds and private equity funds (“Asset Managers”). The VCAP offers four options: 1. A Discretionary Advisory Account offers investment management to the client who prefers View Capital RIA to have discretionary trading authority over the account. 2. A Nondiscretionary Advisory Account offers investment management to the client who prefers to retain all trading authority over the account, and to approve all transactions prior to execution. 3. An Investment Manager Advisory Account offers selection, retention, and subsequent periodic evaluation of non-affiliated Asset Managers selected to participate in the Investment Manager Advisor (“IMA”) program (the “Independent Managers”, see Item #3 below for additional information); and 4. Financial Planning Services offer the client services such as financial and estate planning, business succession planning, structured transaction design, review and analysis, and/or charitable giving planning. VCAP accounts may contain the following securities (including but not limited to): listed and over-the-counter equity securities, mutual funds (open and closed-end funds), exchange traded funds, hedge funds, fund-of-funds, private equity investments, offshore mutual funds, options contracts on equity securities, corporate debt, commercial paper, municipal securities, U.S. government securities, and money market fund shares. 1. Discretionary Advisory Account View Capital RIA Investment Professionals (the “Client Advisors”) provide discretionary account management to discretionary advisory account clients. Client Advisors draw upon their professional insights and experience to provide account management services to the client. Client Advisors may utilize other View Capital RIA employees to provide portfolio management expertise and oversight of the client’s investment assets. Each account is managed on an individual basis according to the client’s investment objectives. The Client Advisor may employ fundamental and technical approaches to security analysis and portfolio management, separately or simultaneously. The fundamental approach entails an examination of the operating, financial, and industry conditions affecting each company. The technical approach entails examining price changes for a specific security, industry group or asset class. Each account is reviewed with the client at least semi-annually and is reviewed continually by the Client Advisor for the impact of changing market conditions, significant events, and client needs and objectives. 2. Nondiscretionary Advisory Account View Capital RIA helps clients formulate a personalized investment strategy consistent with the client’s particular financial goals, time horizon, and risk tolerance. Then, the Client Advisor and the client structure a portfolio of investments consistent with the formulated investment strategy. Portfolios are based upon asset allocation principles intended to achieve an efficient blend of investment asset classes. 3. Investment Manager Advisory Account View Capital RIA advises clients about the selection, retention and subsequent, periodic evaluation of non-affiliated Independent Managers selected to participate in its Investment Managers Advisory services. Independent Managers may be traditional Asset Managers investing in equity and/or fixed income investments, or they may be non- traditional Asset Managers targeting alternative investments including hedge funds, fund of funds and other

illiquid investments. View Capital RIA maintains access to databases of information provided by various Independent Managers and to other data compiled from reliable internal and third-party sources. View Capital RIA does not conduct an independent review to verify the Asset Manager’s performance information, the appropriateness of the Asset Manager’s methodology in calculating performance results, or the information’s accuracy. Instead, the Firm conducts a due diligence review of each Independent Manager who submits Form ADV and provides operating information to View Capital RIA including: administrative information, model portfolios, and performance records. The Client Advisor conducts a client profile analysis to determine which Independent Managers are best suited to the clients’ investment objectives. View Capital RIA then recommends Independent Managers to clients. The Firm will also determine if non- affiliated Independent Managers are properly registered in those states where investment advice or securities are provided. After the client selects an Independent Manager(s), the client executes an investment management agreement granting the Independent Manager discretionary trading authority over the client’s account. Afterward, View Capital RIA provides performance measurement services to the client, and the chosen Independent Manager receives client profile information and periodic updates as requested. View Capital RIA may recommend termination of an Independent Manager if due diligence activities indicate an Independent Manager is no longer suitable for a client or if a client’s financial situation or investment objectives are no longer compatible with the Independent Manager’s investment philosophy. Other reasons for such a recommendation include changes affecting the Independent Manager like ownership changes, departure of key personnel, market or performance fluctuations, or altered investment approach. If the client accepts View Capital RIA’s recommendation to change managers, the Firm terminates the Independent Manager for the client. 4. Financial Planning Services While View Capital RIA representatives do not practice law or offer accounting or tax services, certain employees are licensed attorneys, certified public accountants, and certified financial planners. If the client engages View Capital RIA for financial planning services, it may include the review, analysis, and provision of advice regarding any or all of the following areas: financial and estate planning, business succession planning, structured transaction design, review or analysis, and/or charitable giving planning. View Capital RIA and the client mutually agree to the specific scope of services and fees charged as reflected in the client agreement. View Capital Consulting Program VCCP offers clients access to the advice and experience of View Capital RIA’s investment professionals in a range of areas mentioned below. VCCP also offers access to Asset Managers who require a direct client relationship via a tri-party agreement amongst the client, the Asset Manager, and View Capital RIA. VCCP has been traditionally used by ultra- high-net-worth families or institutions. Some of the types of securities included in VCCP portfolios include (but are not limited to): listed and over-the-counter equity securities, mutual funds, closed-end investment companies, hedge funds, fund-of-funds, private equity investments, options contracts on equity securities, corporate debt, American depository receipts, exchange-traded funds, commercial paper, municipal securities, U.S. government securities, and money market funds. The View Capital Consulting Program offers two options: 1. Investment Consulting includes: selection, retention, and subsequent periodic evaluation of non-affiliated Asset Managers; performance reporting; and 2. Financial Planning offers the client services such as financial and estate planning, business succession planning, structured transaction design, review or analysis, and/or charitable giving planning. 1. Investment Consulting View Capital RIA provides a broad range of consulting services including, without limitation:
• Review, evaluation, and inventory of existing investments, strategy, and goals.
• Preparation or revision of investment policy statement.
• Asset allocation, modeling, and recommendation for portfolio construction.
• Analysis of structured and complex transactions.
• Advice regarding institutional debt structuring and/or restructuring.
• Independent Manager research, manager search due diligence, and ongoing performance monitoring.
• Performance reporting only.
• Custodian evaluation and selection.
• Review and evaluation of costs and expenses. If a client selects an Independent Manager not offered or reviewed by View Capital RIA, the client acknowledges that View Capital RIA conducted no due diligence review of the Independent Manager, and the client separately contracts with such Independent Manager. 2. Financial Planning Services While View Capital RIA representatives do not practice law or offer accounting or tax services, certain employees are licensed attorneys, certified public accountants, and certified financial planners. If the client engages View Capital RIA for financial planning services, it may include the review, analysis, and provision of advice regarding any or all of the following areas: financial and estate planning, business succession planning, structured transaction design, review or analysis, and/or charitable giving planning. View Capital RIA and the client mutually agree to the specific scope of services and fees charged as reflected in the client agreement. Assets Under Management As of December 31, 2018, View Capital RIA has a total of $1,017,602,891 assets under management, $108,595,840 in discretionary accounts and $909,007,051 in non- discretionary accounts.