TA Capital Management is an investment adviser registered with the United States Securities and Exchange Commission (SEC) and is a limited liability company (LLC) formed under the laws of the State of New York. Introduction The investment advisory services of TA Capital Management are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of TA Capital Management (referred to as a client’s investment adviser representative throughout this brochure). A client’s investment adviser representative typically is not an employee of TA Capital Management; rather, a client’s investment adviser representative typically is an independent contractor of TA Capital Management. A client’s investment adviser representative is limited to providing the services and charging investment advisory fees in accordance with the descriptions detailed in this brochure. However, the exact services you receive and the fees you will be charged will be specified in a client’s advisory services agreement. Description of Advisory Services The following are descriptions of the primary advisory services of TA Capital Management. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and TA Capital Management before we can provide you the services described below. Wealth Management Services – TA Capital Management offers wealth management services which is a combination of asset management services and financial planning services. Asset management services involves TA Capital Management providing you with continuous and ongoing supervision over a client’s specified accounts. You must appoint our firm as a client’s investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under a client’s name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on a client’s financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine a client’s financial situation and investment objectives. You will be responsible for notifying us of any updates regarding a client’s financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however we will contact you at least annually to discuss any changes or updates regarding a client’s financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of a client’s Account. You have the ability to impose reasonable restrictions on the management of a client’s accounts, including the ability to instruct us not to purchase certain securities. TA Capital Management, LLC Page 5 Form ADV Part 2A Disclosure It is important that you understand that we manage investments for other clients and give them advice or take actions for them or for our personal accounts that is different from the advice we

provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for a client’s account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Limits Advice to Certain Types of Investments TA Capital Management provides investment advice on the following types of investments: · Mutual Funds · Exchange Traded Funds (ETFs) · Exchange-listed Securities · Securities Traded Over-the-Counter · Foreign Issues · Corporate Debt Securities · Commercial Paper · Municipal Securities · US Government Securities · Options Contracts on Securities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on a client’s risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients TA Capital Management’s advisory services are always provided based on a client’s individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-one basis through interviews and questionnaires to determine a client’s investment objectives and suitability TA Capital Management, LLC Page 6 Form ADV Part 2A Disclosure information. Our financial planning services are always provided based on a client’s individual needs. When providing financial planning services, we work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by TA Capital Management TA Capital Management has assets of $302,593,737.16under management to report as of the date of this Brochure.