A. Description of the Advisory Firm Catalina Capital Group LLC (hereinafter “CatalinaCap”) is a Limited Liability Company organized in the State of California. The firm was formed in July 2014, and the principal owners are Chris Frantz and Philippe Oertle. B. Types of Advisory Services Portfolio Management Services CatalinaCap offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CatalinaCap creates an Investment Objective Sheet for each client, which outlines the client’s current investment objectives and risk tolerance. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring CatalinaCap evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CatalinaCap will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Objective Sheet, which is given to each client. CatalinaCap seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CatalinaCap’s economic, investment or other financial interests. To meet its fiduciary obligations, CatalinaCap attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CatalinaCap’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CatalinaCap’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. CatalinaCap has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, CatalinaCap will always ensure those other advisers are properly licensed or registered as an investment adviser. CatalinaCap conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. CatalinaCap then makes investments with a third-party investment adviser by investing with the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third-party adviser on behalf of CatalinaCap's client. CatalinaCap may also allocate among one or more private equity funds, private equity fund advisers, REITs, Real Estate Investment Funds or Hedge Funds. CatalinaCap will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Pension Consulting Services CatalinaCap offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• Identifying investment objectives and restrictions
• Providing guidance on various asset classes and investment options
• Recommending money managers to manage plan assets in ways designed to achieve objectives
•

Monitoring performance of money managers and investment options and making recommendations for changes
• Recommending other service providers, such as custodians, administrators and broker-dealers
• Creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Smart Harvest Solutions Smart Harvest Solutions builds personalized direct index SMA solutions with an emphasis on tax loss harvesting and custom beta/index exposure. Smart Harvest creates disciplined rules-based equity strategies for third party investment advisors.
• Provide tax loss harvesting with tax lot consideration, and daily portfolio management to seek index outperformance returns on an after-tax basis
• Customized domestic and international index exposure with individual security selection
• Assist in creating custom exposure to target factors, socially responsible investing and more
• Provide detailed reporting, custom reports, transition reports and performance reports to advisors Services Limited to Specific Types of Investments CatalinaCap generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. CatalinaCap may use other securities as well to help diversify a portfolio when applicable. Selection of Other Advisors Services CatalinaCap may direct clients to third-party investment advisers. CatalinaCap will be compensated via a fee share from the advisers to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that CatalinaCap has an incentive to direct clients to the third-party investment advisers that provide CatalinaCap with a larger fee split. CatalinaCap will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. CatalinaCap will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where CatalinaCap is recommending the adviser to clients. C. Client Tailored Services and Client Imposed Restrictions CatalinaCap offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CatalinaCap from properly servicing the client account, or if the restrictions would require CatalinaCap to deviate from its standard suite of services, CatalinaCap reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. CatalinaCap does not participate in any wrap fee programs. E. Assets Under Management CatalinaCap has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 445,732,632.00 $ 183,856,748.00 December 2023