9AT: PASSIVE CAPITAL MANAGEMENT, LLC

PASSIVE CAPITAL MANAGEMENT, LLC

PASSIVE CAPITAL MANAGEMENT, LLC

Adviser Profile

As of Date	01/25/2026
Registration	SEC, Approved, 02/06/2008
Other registrations (1)	Maryland, Terminated, 02/12/2008
ADV Location	SYRACUSE, NY, United States
Contact Info	315 xxxxxxx
Websites

AUM^*	996,942,091 15%
of that, discretionary	986,632,500 15%
Number of Employees	8 33%
of those in investment advisory functions	8 33%
Private Fund GAV^*	0
Avg Account Size	2,329,304 -1%
% High Net Worth	23.60% -20%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pension and profit sharing plans
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management

Reported AUM

987M 846M 705M 564M 423M 282M 141M

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Top Holdings

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker25434V708	Stock NameDIMENSIONAL ETF TRUST	$ Position$53,396,152	% Position17.00%	$ Change-3.00%	# Change-5.00%
Stck Ticker922908553	Stock NameVANGUARD INDEX FDS	$ Position$38,375,594	% Position12.00%	$ Change0.00%	# Change0.00%
Stck Ticker808524862	Stock NameSCHWAB STRATEGIC TR	$ Position$28,422,337	% Position9.00%	$ Change-5.00%	# Change-6.00%
Stck Ticker025072885	Stock NameAMERICAN CENTURY ETF TR	$ Position$21,032,582	% Position7.00%	$ Change1.00%	# Change0.00%
Stck Ticker25434V799	Stock NameDIMENSIONAL ETF TRUST	$ Position$19,313,668	% Position6.00%	$ Change-11.00%	# Change-8.00%
Stck Ticker922907746	Stock NameVANGUARD MUN BD FDS	$ Position$15,987,257	% Position5.00%	$ Change-1.00%	# Change-2.00%
Stck Ticker025072703	Stock NameAMERICAN CENTURY ETF TR	$ Position$15,347,524	% Position5.00%	$ Change-3.00%	# Change0.00%
Stck Ticker808524102	Stock NameSCHWAB STRATEGIC TR	$ Position$13,816,060	% Position4.00%	$ Change4.00%	# Change0.00%
Stck Ticker25434V864	Stock NameDIMENSIONAL ETF TRUST	$ Position$11,148,745	% Position3.00%	$ Change-11.00%	# Change-11.00%
Stck Ticker025072604	Stock NameAMERICAN CENTURY ETF TR	$ Position$9,392,608	% Position3.00%	$ Change-4.00%	# Change0.00%

Brochure Summary

Overview

Passive Capital Management, LLC (“the Adviser”) has been in business since 2007. The principal owners are Scott D. Reinhardt and Jonathan E. Farber. Assets Under Management As of December, 31, 2022, the Adviser managed $796,397,998 in client assets broken down as follows: Discretionary $787,090,237 Non-Discretionary $9,307,761 Investment Management Services The Adviser provides investment management services to its clients on a discretionary and non- discretionary basis. Discretionary Services Discretionary services consist of constructing portfolios to achieve established risk objectives. Portfolios include various funds, primarily passively managed index and asset class funds, designed to achieve competitive returns while attempting to minimize costs and capture the returns provided by the capital markets. The portfolio would generally be rebalanced quarterly to reflect previous

commitments to each market/asset class. When the Adviser manages client assets on a discretionary basis, the Adviser executes securities transactions for clients without having to obtain specific client consent prior to each transaction. Discretionary authority is limited to investments within clients’ managed accounts. Non-discretionary Services Non-discretionary services consist of establishing long-term investment policies, making recommendations regarding portfolio construction and security selection, implementation as directed by the client, and measuring and monitoring results. When the Adviser manages client assets on a non-discretionary basis, the Adviser notifies the client and obtains permission prior to the sale or purchase of each security within the client’s managed account. Clients may decide not to invest in certain securities or types of securities and refuse to approve securities transactions.