This disclosure document is being offered to you by Trilogy Capital, Inc. (“Trilogy”) in connection with the investment advisory services we provide. It discloses information about the services that we provide and the manner in which those services are made available to you, the client. We are an investment management firm with locations in Arizona, California, Colorado, and Massachusetts. Our main headquarters is in Irvine, CA. We specialize in investment advisory services for high-net-worth individuals, families, trusts, estates, and profit-sharing plans. The firm was established by Jeff Motskein 2015. As of March 4, 2024, the Firm is owned directly by Trilogy Capital Holdings, Inc. More detail on the Firm’s breakdown of ownership is listed on Schedule A/B of the Firm’s Part 1 ADV. Our firm offers its services under the business name of Trilogy Financial. Our IARs will use this name and logo for marketing purposes and Trilogy Financial may appear on marketing materials or client statements. The Client should understand that Trilogy Financial is an affiliated entity of Trilogy Capital. The Investment Advisor Representatives (“IARs”) are under the supervision of Trilogy Capital and the advisory services of the IARs are provided through Trilogy Capital. We are committed to helping clients build, manage, and preserve their wealth, and to providing assistance that helps clients to achieve their stated financial goals. We may offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and Trilogy execute an engagement letter or client agreement. Investment Management and Supervision Services We offer discretionary and non-discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. The discretionary investment management services include investment analysis, allocation of investments, quarterly portfolio statements, financial commentaries, and ongoing monitoring of client portfolios. We determine your portfolio composition based on your needs, your portfolio restrictions, if any, your financial goals and your risk tolerances. We will work with you to obtain necessary information regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This information enables us to determine the portfolio best suited for your investment objective and needs. In performing our services, we shall not be required to verify any information received from you or from other professionals. We may recommend and/or engage the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives. For discretionary accounts, we will trade these portfolios and rebalance them on a discretionary basis based on our market views and on your investment objectives, using our investment philosophy and process as outlined in Item 8 in this Brochure. We tailor our advisory services to meet the needs of our clients and seek to ensure that client portfolios are managed in a manner consistent with those financial needs and investment objectives. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate authorization by you on our Discretionary Investment Management Agreement and the Custodian paperwork. 5 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect an account’s performance. This could result in capital losses in your account. There may be times a non-discretionary account relationship exists with our firm. In these circumstances, the client may call in to facilitate a trade on their account. Our Advisors will assist in facilitating the transaction on behalf of the client but we do not have continuous or supervisory oversight on such accounts and do not bill advisory fees for such relationships. The custodian charges additional fees such as transaction costs, custodial fees, redemption fees, retirement plan and administrative fees or commissions. Coach – “Financial Coaching” As an additional service to our investment management services described above, Trilogy provides financial consulting services (“Coaching & Advanced Planning”) based on the information provided by you regarding your individual financial objectives, needs and circumstances. The specific services to be provided are disclosed in the Coach Agreement but includes financial guidance for you with a focus on budgeting, tax strategies, education, and retirement planning. Services may include preparation of a comprehensive financial plan document and analysis with specific investment and/or planning recommendations, and an annual financial plan update. Our recommendations are based on the information you provide us; therefore, the completeness and accuracy of the information provided to us is essential. You agree to discuss with us your current financial resources and projected needs, and to provide copies of any financial documents that we may reasonably request as necessary to evaluate your financial circumstances and provide consulting services. You may choose to have us review and update the consulting recommendations annually or more frequently to adjust for changes in your financial situation or investment objectives. The recommendations should be reviewed and updated as necessary. If agreed to by the Client under our Advanced Planning services, our Firm will provide a comprehensive financial plan. We will address any or all of the six areas of financial planning established by the National Endowment for Financial Education and endorsed by the Certified Financial Planner Board of Standards, depending on your specific needs. These may include: financial position, protection planning, investment planning, income tax planning, retirement planning, and estate planning. Our specific services in preparing your Advanced Planning Written Plan may include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management and estate planning.
• Creation of a unique plan for each goal you have including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession and other personal goals.
• Development of a goal-oriented investment plan around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable and trust accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death.
• Generation of a benefits plan, risk management plan and succession plan for your business, if applicable. 6 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 The fees and services for investment management and Coaching services are separate and distinct of each other. When engaging in Investment Management and Coaching services, clients enter into separate Agreements outlining each of the services and advisory/consulting fees. When both investment management or plan implementation and Coaching services are offered, there is a conflict of interest since there is an incentive for us to recommend products or services for which Trilogy Capital receives compensation. However, Trilogy Capital will make all recommendations independent of such considerations and based solely on our obligations to consider your investment objectives and financial needs. As a Coach client, you have the right not to act upon any of our recommendations and not effect the transaction(s) through us if you decide to follow the investment recommendations. General Consulting Services We also provide general consulting services to clients which provide investment advice on a more- limited basis on one-or-more isolated areas of concern such as estate planning, retirement planning, or any other specific topic. Additionally, we may provide consulting on non-securities matters in connection with the rendering of estate planning, insurance, and/or annuity contracts. In these cases, you may be required to select your own investment managers, broker-dealer and/or insurance companies for the implementation of consulting recommendations. If your needs include brokerage and/or other financial services, we may recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals ("Firms"). You must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm you choose. You are under no obligation to follow the consulting advice that we provide. Types of Retirement Plan Services Our Firm offers (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment Advisory Services and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement plans and their participants. Depending on the type of Plan and the specific arrangement with the Sponsor, we may provide one or more of these services. Prior to being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2A along with a copy of our Privacy Policy and Plan Sponsor Investment Management Agreement ("Agreement") that contains the information required under Sec. 408(b)(2) of the Employee Retirement Income Security Act ("ERISA") as applicable. The Agreement authorizes our Investment Advisor Representatives ("IARs") to deliver one or more of the following services: Discretionary Investment Management Services These services are designed to allow the Plan fiduciary to delegate responsibility for managing, acquiring and disposing of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974 ("ERISA"). We will perform these investment management services through our IARs and charge fees as described in this Form ADV and the Agreement. If the Plan is subject to ERISA, we will perform these services as an “investment manager” as defined under ERISA Section 3(38) and as a “fiduciary” to the Plan as defined under ERISA Section 3(21). Specifically, the Sponsor may determine that we perform the following services: SELECTION, MONITORING & REPLACEMENT OF DESIGNATED INVESTMENT ALTERNATIVES ("DIAs") Our Firm will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor an IPS that contains criteria from which we will select, monitor and replace the Plan's DIAs. Once approved by Sponsor, our Firm will review the investment options available to the Plan and will select the Plan's DIAs in accordance with the criteria set forth in 7 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 the IPS. On a periodic basis, we will monitor and evaluate the DIAs and replace any DIA(s) that no longer meet the IPS criteria. SELECTION, MONITORING & REPLACEMENT OF QUALIFIED DEFAULT INVESTMENT ALTERNATIVES ("QDIA(s)") Based upon the options available to the Plan, our Firm will select, monitor and replace the Plan's QDIA(s) in accordance with the IPS. MANAGEMENT OF TRUST FUND We will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor an IPS that contains criteria from which our Firm will select, monitor and replace the Plan's investments. Once approved by Sponsor, we will review the investment options available to the Plan and will select the Plan's investments in accordance with the criteria set forth in the IPS. On a periodic basis, our Firm will monitor and evaluate the investments and replace any investment(s) that no longer meet the IPS criteria. Non-Discretionary Investment Management Services These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan. We will solely be making recommendations to the Sponsor. We will perform these Non-Discretionary investment advisory services through our IARs and charge fees as described in this Form ADV and the Agreement. If the Plan is covered by ERISA, we will perform these investment advisory services to the Plan as a "fiduciary" defined under ERISA Section 3(21). The Sponsor may engage us to perform one or more of the following Non-Discretionary investment advisory services: INVESTMENT POLICY STATEMENT ("IPS") Our Firm will review with Sponsor the investment objectives, risk tolerance and goals of the Plan. If the Plan does not have an IPS, we will provide recommendations to Sponsor to assist with establishing an IPS. If the Plan has an existing IPS, our Firm will review it for consistency with the Plan's objectives. If the IPS does not represent the objectives of the Plan, we will recommend to Sponsor revisions to align the IPS with the Plan's objectives. ADVICE REGARDING DESIGNATED INVESTMENT ALTERNATIVES ("DIAs") Based on the Plan's IPS or other guidelines established by the Plan, our Firm will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting DIAs to be offered to Plan participants. Once Sponsor selects the DIAs, we will, on a periodic basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the DIAs. If a DIA is required to be removed, our Firm will provide recommendations to assist Sponsor with replacing the DIA. ADVICE REGARDING QUALIFIED DEFAULT INVESTMENT ALTERNATIVE ("QDIA(s)") Based on the Plan's IPS or other guidelines established by the Plan, our Firm will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting or replacing the Plan's QDIA(s). PARTICIPANT INVESTMENT ADVICE Our Firm will meet with Plan participants, upon reasonable request, to collect information necessary to identify the Plan participant's investment objectives, risk tolerance, time horizon, etc. We will provide written recommendations to assist the Plan participant with creating a portfolio using the Plan's DIAs or Models, if available. The Plan participant retains sole discretion over the investment of his/her account. ADVICE REGARDING INVESTMENT OF TRUST FUND 8 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 Based on the Plan's IPS, our Firm will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting investments that meet the IPS criteria. Once Sponsor selects the investment(s), we will, on a periodic basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the investment(s). If the IPS criteria require any investment(s) to be replaced, our Firm will provide recommendations to assist Sponsor with replacing the investment(s). Retirement Plan Consulting Services Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in meeting his/her fiduciary duties to administer the Plan in the best interests of Plan participants and their beneficiaries. Retirement Plan Consulting Services are performed so that they would not be considered “investment advice” under ERISA. The Sponsor may elect for our IARs to assist with any of the following services: ADMINISTRATIVE SUPPORT ✓ Assist Sponsor in reviewing objectives and options available through the Plan ✓ Review Plan committee structure and administrative policies/procedures ✓ Recommend Plan participant education and communication policies under ERISA 404(c) ✓ Assist with development/maintenance of fiduciary audit file and document retention policies ✓ Deliver fiduciary training and/or education periodically or upon reasonable request ✓ Recommend procedures for responding to Plan participant requests SERVICE PROVIDER SUPPORT ✓ Assist fiduciaries with a process to select, monitor and replace service providers ✓ Assist fiduciaries with review of Covered Service Providers ("CSP") and fee benchmarking ✓ Provide reports and/or information designed to assist fiduciaries with monitoring CSPs ✓ Coordinate and assist with CSP replacement and conversion INVESTMENT MONITORING SUPPORT ✓ Periodic review of investment policy in the context of Plan objectives ✓ Assist the Plan committee with monitoring investment performance ✓ Educate Plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s) PARTICIPANT SERVICES ✓ Facilitate group enrollment meetings and coordinate investment education ✓ Assist Plan participants with financial wellness education, retirement planning and/or gap analysis Potential Additional Retirement Services Provided Outside of the Agreement We and our IARs, in the course of providing Retirement Plan Services or otherwise, may establish a client relationship with one or more plan participants or beneficiaries. Such client relationships develop in various ways, including, without limitation:
• as a result of a decision by the plan participant or beneficiary to purchase services from us not involving the use of plan assets;
• as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relating to assets held outside of a plan; or
• through a rollover of an Individual Retirement Account ("IRA Rollover"). 9 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 In providing these optional services, we may offer employers and employees information on other financial and retirement products or services offered by us and our IARs. If we are providing

Retirement Plan Services to a plan, IARs may, when requested by a participant or beneficiary, arrange to provide services to that participant or beneficiary through a separate agreement. When a participant requests assistance with an IRA Rollover from his/her plan to an account advised or managed by us, we will have a conflict of interest if our fees are reasonably expected to be higher than those we would otherwise receive in connection with the Retirement Plan Services. For participants invested in plans which we do not advise, we also have a conflict of interest given that we may not earn any compensation if they remain invested in their current plan. We will disclose relevant information about the applicable fees charged by us prior to opening an IRA account. Any decision to affect the rollover or about what to do with the rollover assets remain that of the plan participant or beneficiary alone. Use of Sub-Advisors Factors we will consider in recommending a particular sub-advisor include, but are not limited to, the client’s stated investment objectives, management style, independence, stature of the custodian utilized by the sub-advisor, performance, philosophy, financial strength, continuation of management, client service, reporting, commitment to a particular investment mandate, fees, trading efficiency, and research. We provide investment advice, recommendations and utilize the investment strategies of Outside Investment Managers (“Managers”) through a sub-adviser relationship. Selected Managers are evaluated by us for use in a client’s account. Managers selected by us may offer multiple strategies. Some of these strategies include the use of ESG criteria to build investment offerings. There are inherent risks involved in ESG investing. Please see Item 8 for details. Please inquire for additional information if interested in investing in these types of strategies. Our Firm will monitor Managers to ensure that it adheres to the philosophy and investment style for which it was selected and to ensure that its performance, portfolio strategies, and management remain aligned with the client’s overall investment goals and objectives. We will retain discretionary authority to hire and fire the Manager. Our ongoing review includes, but is not limited to, assessment of the Manager’s disclosure brochure, performance information, materials, personnel turnover, and regulatory events. When we engage a Manager to invest a separately managed account (“SMA”), the SMA will be traded by either the Manager (externally-traded) or by our Firm (internally-traded). In both cases, all research, investment selections and portfolio decisions are the responsibility of the Manager, not by our Firm. Performance reporting may be the provided by the Manager. Our Firm has entered into agreements with various independent Managers. Under these agreements, we offer clients various types of programs sponsored by these Managers. All third-party Managers to whom we will refer or engage for clients will be licensed as registered investment advisors by their resident state and any applicable jurisdictions or registered investment advisors with the U.S. Securities and Exchange Commission (“SEC”). Through our Discretionary Investment Management Agreement, the Client grants Trilogy Capital authority to utilize a sub-advisor. Trilogy Capital receives no compensation or additional benefits from the Manager related to this arrangement. Our Firm, in conjunction with the Manager, will continue to provide advisory services to the Client for the ongoing monitoring, review, and reporting of the overall account performance. 10 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 Third-party managed programs generally have account minimum requirements that will vary from investment advisor to investment advisor. A complete description of the Manager’s services, fee schedules and account minimums will be disclosed in the Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at the time an agreement for services is executed and account is established. LPL Financial Sponsored Advisory Programs We may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory program available to our Firm. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. Our Firm will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. We will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Wrap Fee Program Trilogy Capital is the sponsor and manager of the Trilogy Capital Wrap Program (the “Program”), a wrap fee program (i.e., an arrangement where brokerage commissions and transaction costs are absorbed by the Firm). The fee covers transaction costs or commissions resulting from the management of your accounts, however, most investments trade without transaction fees today, so our payment of these and other incidental custodial related expenses should not be considered a significant factor in determining the relative value of our wrap program. Participants in the Program may pay a higher aggregate fee than if brokerage services are purchased separately. Additional information about the Program is available in Trilogy Capital’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV. We adhere to our fiduciary duty when trading in your accounts. Trades are made only on the basis of the account’s stated investment objectives, and without concern to the firm’s trading costs and firm’s expenses that trading the accounts will create. In order to mitigate this conflict of interest, we will fulfill our fiduciary duty by acting in the client’s best interest. All advisory accounts at LPL Financial are in our Wrap Fee Program. Clients will receive investment advisory services, the execution of securities brokerage transactions, custody, and reporting services for a single specified fee. The terms and conditions of a wrap program engagement are more fully discussed in LPL’s Disclosure Brochure provided to prior to opening your account. The “wrap” fee program at LPL may be more or less than the fees and commissions charged by other advisory firms, third-party managers, and brokerage firms if the services were acquired separately. The factors that 11 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 bear upon the cost of services are the size of the account, type of transaction and whether trades are placed through a brokerage firm other than the custodian resulting in per trade commissions being charged. IRA Rollover Considerations If you have an employer-sponsored retirement plan, you have several choices as to what to do with your assets when you retire or separate from employment. As part of our consulting and advisory services, we may offer you recommendations or education only concerning your employer retirement plan or other qualified retirement account. Our recommendations may include you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset- based fee as described in our Firm’s ADV Part 2A Brochure and Form CRS. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should, among other factors, consider impacts relating to costs and fees, available investments, services provided, simplicity and convenience, required minimum distributions, and early distribution penalties. An employee will typically have four options: 1. Leave the funds in your existing employer plan. 2. Move the funds to a new employer plan. 3. Take a lump-sum distribution. 4. Roll the funds over to an IRA account. You should carefully weigh the advantages and disadvantages of each option, including any applicable fees and all features of each option before making your decision. You should also consult your tax and/or legal advisor to determine any applicable tax consequences. Your financial advisor can provide you with information you need to consult with your tax and/or legal advisor and make the appropriate decisions to meet your specific needs, but it is ultimately your decision as to which option is best for you. The following are general factors that you should consider when making your decision. 1. If you keep your assets in certain types of employer-sponsored plans [e.g., 401(a) or 401(k)], consider:
• Tax Deferral. Your money can continue to grow tax deferred within the plan.
• Additional Withdrawal Allowances. There is no federal tax penalty for withdrawals if you are age 59 ½ or separated from employment during or after the calendar year in which you reach age 55.
• Low-Cost Investment Options/Investment Strategy. You may have access to lower priced mutual funds or special products that are not available in an IRA, such as company stock, fixed annuity contracts or stable value options. Your current plan may offer model portfolio options at no additional cost.
• No Asset Management Services. It is likely you will not be charged a management fee and will not receive ongoing asset management services or advice unless you elect to have such services. In the event your plan offers asset management or model portfolio 12 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024 management, there may be a fee associated with the service that is more or less than our asset management fee.
• Protection from Creditors. Assets in a retirement savings plan such as a 401(k) or 403(b) are generally protected from creditors and legal judgments, while assets in IRAs receive more limited protections from creditors.
• Deferral of Required Minimum Distributions (RMD's). Your employer-sponsored retirement plan may offer this feature if you are currently working for the sponsoring employer and are over age 72.
• Availability of Company Stock as an Investment Option. If you hold company stock in your former employer's plan, you should consider the impact of net unrealized appreciation.
• Outstanding Loan Balances. If you leave your employment, you may be able to continue repaying any outstanding loan. Alternatively, you may be required to repay the loan in full or have it become taxable. (Consult with the Plan's Administrator to determine the consequences of any outstanding plan loan.)
• Subject to Plan Limitations. Accounts of inactive or retired participants may have limitations, such as restrictions on plan loans. The employer might change plans or plan provisions in the future. You can no longer make contributions to the plan.
• Plan Advice and Service. Your Plan may allow you to hire us as the manager and keep the assets titled in the plan and/or your current plan may offer financial advice or guidance at no additional costs. 2. If you rollover assets into another employer-sponsored plan, consider:
• Tax Deferral / Additional Withdrawal Allowances / Low-Cost Investment Options / Protection from Creditors / RMD Deferrals. Like keeping your assets in your existing employer-sponsored plan, if you move your assets into new employer's retirement plan, you may likely receive similar benefits such as these, as noted above.
• Consolidation of Retirement Accounts. It may be easier to track your assets and manage your retirement plan accounts with all your money in one place.
• Plan Limitation on Accepting Rollover Assets. You must check with the receiving employer- sponsored plan to confirm that it is willing to accept rollovers.
• Possible Limitations on Access to Funds Rolled into Plan. Check with the receiving employer-sponsored plan to confirm that the plan does not impose any restrictions on your ability to access or withdraw funds rolled into the plan. 3. If you take a lump-sum distribution, consider:
• Withdrawals May be Subject to Withholding, Taxes, Penalties and Other Charges. If you are under the age 59½, the withdrawal will be subject to mandatory tax withholding as well as applicable tax penalties for early withdrawal. Note, there are limited exceptions to the penalty tax (e.g., payments made to you after you separate from service if you are age 55 or over in the year in which you separate). Note also that the penalty tax does not apply to distributions from a governmental 457(b) plan. You may also be subject to surrender charges or penalties assessed under the terms of the applicable investment. 4. If you rollover assets into an IRA from an employer-sponsored plan, consider:
• Tax Deferral. Your money can continue to grow tax deferred. No taxes or penalties are applicable for direct rollovers of pre-tax contributions to traditional IRAs or direct rollovers of Roth contributions to Roth IRAs.
• More Investment Options. IRAs generally allow for a broader range of investment options, which include mutual funds, exchange-traded funds, stocks and bonds.
• Asset Management and Additional Services. You should understand the asset management programs and various services we offer and you might take advantage of and the cost of those services. 13 | P a g e Trilogy Capital ADV Part 2A Brochure March 2024
• Consolidation of Retirement Accounts. Combining all retirement plan accounts into a single IRA makes it easier to track your assets and manage required minimum distributions required under federal tax laws.
• Inability to Take Plan Loans/Limited Access to Monies Prior to age 59 ½. You will not have the ability to take penalty-free withdrawals as a plan loan. In addition, your access to IRA assets prior to age 59 ½ will be limited to certain specific circumstances, such as first-time homebuyers and higher education expenses.
• Conflicts of Interest. Your financial advisor has a financial incentive to recommend an IRA rollover because of the compensation that he/she receives for our management services.
• Loss of Plan Options. You may lose certain options offered by your former plan, which often include, but are not limited to, guaranteed interest rates, death benefits and protection from creditors (under certain plan types).
• Charges for Rollovers. Surrender charges could be imposed by the former provider if the account included an annuity. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding if you have questions contact your financial advisor. Participant Account Management (Discretionary) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Advisor will review the current account allocations. When deemed necessary, Advisor will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. Assets As of December 31, 2023, we manage a total 1,886,949,860 in regulatory assets under management. All assets under our management are discretionary assets.