North Capital was established in October 2008 to provide financial planning and investment advisory solutions to individuals, families and institutions. Advisory services are offered on both a discretionary and non-discretionary basis. As of March 31, 2023, The Firm has $260,946,342 of assets under management or regular supervision. $241,104,115 is managed on a discretionary basis and $19,842,227 is managed on a non-discretionary basis. In addition, the Firm provides a broad range of hourly advisory and consulting services related to illiquid assets (real estate, hedge funds, private companies) with a value of approximately $325 million. The Firm develops comprehensive financial plans for clients based upon their needs, goals, income and expenses, assets and liabilities, and other relevant factors. Information is collected through questionnaires and personal interviews and analyzed using quantitative and qualitative methods with proprietary models and third party analytical software. Investment advisor representatives produce written plans that are reviewed with clients in person or by phone. The Firm utilizes an open architecture approach to provide discretionary investment management to clients. By accessing a wide array of asset classes, investment styles and strategies through mutual funds, ETFs, ETNs, and separately managed accounts, the Firm attempts to offer broad diversification, tax efficiency and cost-effective portfolio management. The Firm may be asked to provide or may offer advice and consulting services related to investments in private investment partnerships or other private investments such as hedge funds, private equity funds, or venture capital funds, to qualified clients for whom such investments are deemed to be suitable. The Firm also operates as a sub-advisor for other investment advisory firms, providing asset allocation, manager selection, implementation consulting, trading, and portfolio reporting services. These services are offered on a fixed fee, asset-based fee, or combined basis. Sub-advisory relationships are documented by a sub-advisory agreement between the Firm and the client advisory firm. The Firm also operates as a co-advisor with other investment advisory firms in certain instances with respect to certain customers, providing asset allocation, manager selection, implementation consulting, trading, and portfolio reporting services. In such instances, the Firm executes an individual advisory agreement with the subject client, or a joint advisory agreement which stipulates the scope of services to be provided, and the responsibilities of the Firm vis a vis the other investment advisory firm. The Firm is manager of an open-end, registered mutual fund through the North Capital Funds Trust, a U.S. Government Money Market Fund. The Prospectus may be accessed here: http://funds.northcapital.com and the Statement of Additional Information may be accessed here. The North Capital Government Money Market Fund (NCGXX) seeks to maximize current income to the extent consistent with the preservation of capital and the maintenance of liquidity. In pursuing its investment objective, the Fund will operate as a “government money market fund,” as such term is defined in or interpreted under Rule 2a-7 under the Investment Company Act of 1940, as amended (the “1940 Act”). Government money market funds are required to invest at least 99.5% of their total assets in: (i) cash; (ii) securities issued or guaranteed by the United States or certain U.S. government agencies or instrumentalities; and/or (iii) repurchase agreements that are fully collateralized (i.e., backed by cash or government securities). Government money market funds are exempt from requirements to impose liquidity fees and/or temporary redemption gates, however, government money market funds may elect to impose these fees. The Fund has elected to not impose liquidity fees or redemption gates at this time. As a government money market fund, the Fund values its securities using the amortized cost method. The Fund seeks to maintain a stable net asset value (“NAV”) of $1.00 per share. In conjunction with its investment management programs, the Firm may provide written commentary, newsletters, financial models and other information developed by the Firm or its partners, which are designed to provide advice and support to clients. Such supporting materials may be provided with or without additional charge to clients and prospective clients of the Firm. The Firm does not participate in any wrap fee programs. In addition to customized investment management for individuals and institutional investors, the Firm provides specialized, non-discretionary investment and financial consulting services such as valuation, management, and hedging of illiquid assets, endowment formation and management, strategic liability management, and retirement plan formation. The Firm operates a branded platform service, evisor.com, to address a market segment that we believe to be underserved by financial advisors. evisor.com is a DBA of North Capital and was created to provide low-cost, fee-only financial planning and investment management services through an online advisory platform. The platform has been designed to address the most common planning needs and issues faced by individuals and families, utilizing the approaches and methodologies developed by the Firm. The evisor.com service is marketed direct to retail investors and as a business-to-business offering on a wholesale basis to serve such businesses’ retail customers. Compassvest and Compass Family Offices are DBAs of the Firm. Compassvest was created to differentiate the Firm’s multi-family office financial planning and wealth advisory services from other business of the Firm and its affiliates. Compass Family Offices is focused on providing holistic wealth advisory and family office services for individuals and families with at least $25 million of investment assets. Compass Family Offices is managed by Paul Bowers, a senior investment advisor representative of the Firm. The Firm has granted a license of certain intellectual property to AdvisorEngine Inc. (formerly Vanare Inc.), a financial technology company that provides services to registered investment advisory firms, including the Firm. In turn, the Firm has obtained a license of certain intellectual property, software and services from AdvisorEngine to support the Firm. The Firm also provides technology and business process consulting services

to investment management firms and broker-dealers, related to the management and operation of their businesses. Technology and related services are offered through its affiliate under common control, North Capital Investment Technology Corp. The Firm is a fee-only investment advisory company. The Firm does not charge and will not accept brokerage fees or commissions related to any business transacted by or on behalf of its clients. Retirement Plan Rollover Recommendations - When the Firm provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that the Firm is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way North Capital Inc makes money creates conflicts with your interests, so the Firm operates under a special rule that requires the Firm to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, the Firm must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of the Firm ahead of yours when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that the Firm gives advice that is in your best interest;
• Charge no more than is reasonable for the services of the Firm; and
• Give Clients basic information about conflicts of interest. To the extent the Firm recommends that you roll over your account from a current retirement plan account to an individual retirement account managed by the Firm, please know that the Firm and our investment adviser representatives generally have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by the Firm. We will earn less fees if you do not roll over the funds in the retirement plan to an IRA managed by the Firm. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA, which is a conflict of interest because our recommendation could be based on our economic incentive and not based exclusively on whether moving the IRA to our management program is in your overall best interest. Some clients of the Firm are charged an advisory fee based on aggregate assets advised by the Firm, including assets “held away” in retirement plans. While the economic incentive described in the foregoing paragraph may not exist with regard to such clients, the conduct standard described herein nevertheless applies. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in the Firm receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by the Firm and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of the Firm or our affiliated personnel. The Firm is a wholly-owned subsidiary of North Capital Investment Technology, Inc., whose principal beneficial owner is James P. Dowd, CFA, who also serves as the Firm’s CEO and Chief Investment Officer. Additional Conflicts of Interest The Firm may provide financial planning to clients to whom investment management services are also offered or provided. A conflict of interest may exist inasmuch as a financial plan may include recommendations such as saving more money for retirement, establishing a 529 plan account, establishing a retirement account, and/or changing the asset allocation or the investments in the client’s portfolio. The Firm offers discretionary and non-discretionary investment management services that would include the implementation of such recommendations for an additional fee. Financial planning and other non-discretionary advisory clients are under no obligation to act upon any recommendations made by the Firm, or to retain the Firm for discretionary or additional non- discretionary advisory services beyond the scope of the financial plan or other non-discretionary engagement. If a client decides to act upon a recommendation made during the planning process, it is under no obligation to implement the recommendation or to effect any transaction through the Firm. An additional conflict of interest exists in that the Firm has an incentive to recommend its proprietary fund --- the North Capital Government Money Market mutual fund --- to discretionary clients of the Firm, especially if the Firm stands to earn more in advisory fees from proprietary products than from other products that are recommended. The Firm mitigates this risk in two ways. First, any such financial incentive is eliminated through an offset against advisory fees; the management fees earned by the Firm on any proprietary product are credited dollar for dollar against advisory fees on accounts that are allocated primarily to third party funds. Whether an investor’s portfolio is allocated to ETFs or proprietary funds or REITs, the Firm earns the same aggregate fees. Second, the Firm’s Risk Committee has established guidelines regarding the maximum allocation to proprietary funds. At present, the limit for each product is 5%. The limits and offsets described above do not apply to non-discretionary advisory clients.