ToDo Capital is an independent Registered Investment Advisory Company focused on providing investment management services to high net worth individuals, families, companies and institutions. The firm’s objective is the preservation of capital and the long term growth of the assets under its management. ToDo Capital seeks to achieve this through intelligent solutions focused on the specific needs of each individual client. ToDo Capital provides close consultation and consideration of its clients’ goals and risk tolerance before reaching a mutual decision with the client on how best to seek to build and preserve their wealth. ToDo Capital works to follow a rigorous and disciplined process and seeks to leverage high-quality investment products and providers to create a diversified portfolio aimed at meeting its clients’ objectives. Prior to the rendering of any advisory services, clients are required to enter into one or more written agreements with ToDo Capital, setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). ToDo Capital is wholly owned by Francisco Javier Madariaga. As of December 31st, 2023, ToDo Capital has approximately $119,630,490 of assets under management. $105,379,206 of those assets are managed on a discretionary basis, and $14,251,284 are managed on a non-discretionary basis. While this brochure generally describes the business of ToDo Capital, certain sections also describe the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on ToDo Capital’s behalf and is subject to the Firm’s supervision or control. Investment Management Services Clients can engage ToDo Capital to manage all or a portion of their assets either on a discretionary or non-discretionary basis. ToDo Capital primarily allocates clients’ assets among individual debt and equity securities

and options, mutual funds, exchange-traded funds (“ETFs”), as well as the securities components of variable annuities and variable life insurance contracts, in accordance with the investment objectives of its individual clients. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. As such, ToDo Capital may offer certain business planning, retirement and estate planning, cash flow forecasting and/or risk management services as part of its overall investment and portfolio management. Clients may also engage ToDo Capital to be advised on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, ToDo Capital directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. ToDo Capital tailors its advisory services to meet the individual needs of clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. To do that, ToDo Capital consults with clients initially and on an ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify ToDo Capital if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if ToDo Capital determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.