The Firm Drawbridge Capital, LLC is located in Tulsa, Oklahoma and was originally established in 2017, held under common ownership with Regent Financial Services, Inc by Gary Stanislawski. Investment advisory services were initially offered via Regent Financial Services, Inc from 2015 to 2017, then via Drawbridge Capital staring in 2017 when the firm was established as a state-level registered investment advisor, and finally via Drawbridge Capital as an SEC-registered investment advisory firm since March, 2019. Services provided initially included only personal financial planning, then expanded in 2015 to include asset management, and expanded again in 2018 when Drawbridge Capital became the sole provider of investment advisory services to the membership of TTCU Federal Credit Union, an Oklahoma based NCUA insured credit union. Personal financial planning provided is consistent with a client's financial status, investment objectives, and tax status. An individualized financial plan may include, but is not limited to, information regarding retirement and social security planning, education planning, planning for major purchases and life events, benefits analysis, life insurance, disability insurance, long-term care, final expense needs, estate planning, and inheritance planning. A financial plan may also include generic recommendations as to general types of investment products or securities that may be appropriate for the client to purchase given his/her financial situation and objectives. The client is under no obligation to purchase securities through the investment advisory representative (IAR). However, if the client desires to purchase securities in order to implement his/her financial plan, the IAR may execute such transactions in his/her capacity as a registered representative of LPL Financial LLC (LPL), a separate, legally unaffiliated entity which is an SEC registered broker/dealer and member of the Financial Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation (“SIPC”). Financial plans will not include information with respect to liability risks. Asset management investment advisory services are provided within discretionary (with permission) and non-discretionary fee-based investment advisory services for compensation primarily to individual clients and high-net worth individuals and corporate clients based on the individual goals, objectives, time horizon, and risk tolerance of each client. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring The IARs associated with Drawbridge Capital are appropriately licensed and authorized to provide advisory services and continue to serve as registered representatives of LPL. Any securities transactions executed by IARs of Drawbridge Capital LLC, including those acting for the benefit of TTCU members, acting in their capacity as a registered representative of LPL shall be directed to LPL for execution. However, clients retain the right to execute securities transactions through the broker/dealer of their choice. Any and all material conflicts of interest are disclosed herein. Some of Drawbridge Capital’s IARs may utilize a third-party asset management program (TAMP) to allocate either all or certain segments of their clients’ investments. In most cases where a TAMP is used, Drawbridge Capital has discretion to determine which TAMP and/or which strategy will be used to manage the client’s investment, including discretion to change those selections at any time. As a result, these client accounts are included in the calculation of Drawbridge Capital’s regulatory assets under management. 4 of 31 Management Team Gary M. Stanislawski CFP®, CKA - Owner, President, & Chief Compliance Officer Gary M. Stanislawski CFP® is the sole owner and president of Drawbridge Capital, LLC. He is also a registered principal with LPL, offering securities transactions on a commission basis. He works with individuals and businesses to provide investment, retirement and estate planning services. Gary is a Certified Financial Planner®, Certified Kingdom Advisor, and past President of the Financial Planning Association of Tulsa. Gary was awarded a four-year ROTC scholarship and attended Oregon State University where he received his Bachelor of Science degree in Business Administration. Upon graduation, Gary entered the Air Force and subsequently earned his wings as a pilot in 1984. Gary flew for eight years, flying such planes as the B-52 and the B-1 Bomber, and has approximately 2000 hours of flying time. Gary also holds a Master of Arts degree from Oral Roberts University. In 2008, Gary was elected to the Oklahoma State Senate and served as Caucus Chairman, Chairman of the Education Committee, Vice Chairman of the Appropriations Subcommittee on Education, and also as a member of the following committees: the Business, Commerce and Tourism Committee, Rules Committee, Appropriations Committee, and Appropriations Subcommittee on Finance. In addition, Gary has served his community as past president of Jenks Public School’s Board of Education, member of the Jenks Public School Foundation Board, member of the Planned Giving Committee of the Parent Child Center, member of the board of directors for Glory House (a local women’s shelter), and member of India Missions (a group that reaches out to bring health and wholeness to the people of India). Gary and his wife Dayna have been married for over 40 years and have two children, Shawn and Kristie. He currently attends Victory Church where he has previously served six years as the Sunday School Superintendent. Monty W. Dossman, Chief Investment Officer Monty Dossman is the Chief Investment Officer of Drawbridge Capital, LLC. He brings over 35 years of experience in the investment industry to his portfolio management duties, where he manages numerous equity and hybrid equity/fixed income portfolios. Monty also assists the IARs with client portfolio reviews and servicing investor needs. Monty graduated with a degree in Geology and Geophysics from Yale University where he also participated in football and baseball. Starting his career in 1984, he has gained his investment knowledge and experience through varied market environments including the crash of 1987, Asian financial crisis in 1997, the bull market of the late 1990’s, the Dot-com bubble and ensuing bear market of 2000-2002, the Great Recession and subsequent bear market of 2007-2008, and the results of the Covid Pandemic beginning in 2020. Monty is married and has three daughters. 5 of 31 LPL Financial Sponsored Asset Management Programs and Platforms Drawbridge Capital offers asset management on a discretionary basis. As of December 2023, the firm has $162,316,474 of discretionary assets.
• Strategic Wealth Management (SWM) Drawbridge Capital, through its IARs, provides ongoing investment advice and management on assets held within clients’ custodial Strategic Wealth Management (SWM) accounts held at LPL Financial, which support investment advisory services provided to clients by Drawbridge Capital. In a SWM account certain transactions / ticket charges may be passed on to the client. Drawbridge Capital may negotiate a higher fee for a SWM account due to the use of individual securities and the potential for higher trading activity. Each client’s trading frequency will be evaluated as part of their initial and annual review to determine the most cost-effective program. The combined total fee will not exceed 2.0%. More specific account information and acknowledgements are further detailed in the account opening documents. IARs provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, real estate investment trusts (“REITs”), equities, and various fixed income securities. The initial advice is tailored to the individual needs of the client to help them to meet their financial goals, and accounts are reviewed on a regular basis and rebalanced as necessary, all based on each client’s investment objective and profile. Generally, there is no minimum account balance required for a SWM account. In certain instances, Drawbridge Capital may require a minimum account size.
• Optimum Market Portfolios (OMP) The Optimum Market Portfolios (OMP) program is a professionally managed mutual fund asset allocation program that provides ongoing investment advice and management via LPL and the IAR. Various multi-manager model portfolios available are consistent with several investment objectives and distributed by Delaware Distributors, LP. Portfolios include up to six Optimum Funds representing the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. Each fund uses at least two institutional subadvisors for diversification and provides customization benefits through the combination of subadvisors. Drawbridge Capital’s IARs obtain financial data from each client, assist the client in determining the suitability of the OMP program, and help to select an appropriate fund portfolio program. LPL Research consults with Macquarie Investment Management in the creation of the funds, ongoing monitoring, and in determining whether to engage, maintain, or terminate managers as necessary, managing the underlying Optimum Funds on a discretionary basis consistent with the portfolio program objectives. LPL Financial does not directly manage fund assets on behalf of any particular client. LPL follows an asset allocation investment style in constructing portfolios for the program. Asset allocation methodology is implemented by combining investments representing various asset classes that react differently to varying market conditions. Thus, if one asset class reacts negatively to certain market events, the potential exists for another asset class to react positively. As with any investment strategy, there is no guarantee that the use of an asset allocation strategy will produce favorable results. Drawbridge Capital IARs are responsible for educating the client about this investment style in advance of opening the account by explaining the various asset classes (e.g., large cap growth, large cap value, etc.) being used within the selected portfolio. This educational process continues throughout the time that the client maintains the account. 6 of 31 OMP is one of several portfolio platforms centrally managed by LPL Financial. OMP enables advisors of Drawbridge Capital to manage client assets with diversified asset allocation models, professional money management, and automatic rebalancing. A minimum account value of $1,000 is required for OMP, but systematic contributions are required for account sizes below $10,000.
• Model Wealth Portfolios (MWP) The Model Wealth Portfolios (MWP) program is a unified managed account program that provides ongoing investment advice and management via mutual fund and/or exchange-traded product manager models, separately managed account (SMA) strategies, and advisor-created models. Drawbridge Capital’s IARs obtain financial data from each client, assist the client in determining the suitability of the MWP program, and help to select an appropriate investment objective. The IAR will have discretion to select one or multiple (up to twenty) model portfolio(s) consistent with the client’s stated investment objective that are designed by a portfolio strategist: LPL’s Research Department, a third-party investment strategist, or the IAR. IARs have discretion to choose among the available models designed by LPL or outside strategists or create their own models. The portfolio strategist is responsible for selecting and making changes to the investment vehicles within a model portfolio. Portfolios can include mutual funds, exchange-traded funds, exchange-traded notes, closed-end funds, equities, or fixed-income securities. The client will authorize LPL to act on a discretionary basis to purchase and sell various securities consistent with the stated investment objective and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP is one of several portfolio platforms centrally managed by LPL Financial. MWP enables advisors of Drawbridge Capital to manage client assets with outsourced asset allocation, manager selection, portfolio monitoring, trading, and automatic rebalancing. The minimum account value for an MWP portfolio is $25,000, however the minimum is as low as $10,000 for select strategies.
• Personal Wealth Portfolios (PWP) The Personal Wealth Portfolios (PWP) is a unified managed account program that provides ongoing investment advice and management through LPL and the IAR. The program utilizes asset allocation portfolios designed by LPL’s Research Department including a combination of mutual funds, exchange- traded funds (ETFs), as well as investment models provided by third party money managers, which typically consist of equity and fixed income securities but may include investment company securities. LPL’s Research Department selects the mutual funds, ETFs and investment models to be made available in a portfolio. Drawbridge Capital’s IARs obtain the financial data from each client, assist the client in determining the suitability of the PWP program, and help to select an appropriate investment objective. The IAR, or client with the assistance of the IAR, selects a portfolio based on the client’s investment objective and then selects among the mutual funds, ETFs and/or models available in the portfolio. If a client authorizes the IAR to have discretion to make such selections on client’s behalf, the discretionary authority will be set out in the account agreement and application signed by the client. Neither LPL nor a third-party money manager directly provides advisory services to the clients of Drawbridge Capital, with the exception of the Muni Model/Sleeve. If the Muni Model is selected, the PWP advisor does provide individualized discretionary advisory services with respect to that sleeve. Otherwise, the third-party money managers selected by LPL Financial for a particular program manage 7 of 31 the portfolio without regard for any particular client of Drawbridge Capital. Drawbridge Capital is solely responsible for the advisory services provided and selecting the proper portfolio of third-party money managers. Drawbridge Capital is not acting as a cash solicitor for LPL Financial or other third-party money managers. A minimum account value of $250,000 is required for PWP.
• Guided Wealth Portfolios (GWP) The Guided Wealth Portfolios (GWP) program is a digital, centrally managed investment platform made available to users and clients through a web-based interactive account management portal (“Account View”). Investment recommendations are generated based upon the client profile provided which is relied upon to select an appropriate investment allocation track and model portfolio. Model portfolios are designed and maintained by LPL Research. Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through Account View), although Drawbridge Capital’s IARs can be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the program (the “Proposal Tool”) is generally provided for a limited period to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL and Drawbridge Capital by enrolling in the advisory service (the “Advisory Service”). The Proposal Tool is intended to be used for educational and informational purposes only. Users of the Proposal Tool are not considered to be advisory clients of LPL or Drawbridge Capital, do not enter into an advisory agreement with LPL or Drawbridge Capital, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. Additional details about the Proposal Tool as well as the Advisory Service can be found in the GWP program brochure provided by LPL Financial. A minimum account value of $5,000 is required to enroll in GWP.

• Manager Access Select (MAS) The Manager Access Select (MAS) wrap program provides access to the investment advisory services and/or model portfolios of third-party professional portfolio management firms for the individual management of client accounts. Two alternative platforms are available: the Separately Managed Account (SMA) platform and the Model Portfolio (MP) platform. LPL acts as the investment advisor; Drawbridge Capital’s IARs obtain the financial data from each client to assist in determining the suitability of the MAS program, an appropriate investment objective, and risk/return preferences. In addition, the IAR will identify any restrictions on the management of the account and select an investment strategy and portfolio manager (within the SMA platform) or select a model portfolio provided by LPL’s Research Department or third-party investment advisors (within the MP platform). The IAR will provide initial and ongoing advice and monitoring regarding the portfolio manager services within both platforms. The portfolio manager manages client’s assets on a discretionary basis. A minimum account value of $50,000 is required for MAS, however, minimum varies by strategy and can be as high as $250,000 in certain instances. 8 of 31
• Manager Access Network (MAN) The Manager Access Network is a dual contract platform in which clients, typically high-net-worth investors, have access to a variety of third-party institutional portfolio managers at significantly lower account minimums. By using separate account managers, clients can access a higher level of specialization and service through the ownership of individual securities. A broad range of portfolio managers and multiple investment styles are available, including equity, fixed income, asset classes, mutual funds, ETFs, and specialty strategies. Clients contract directly with portfolio managers, granting them discretionary authority with respect to the account and activity conducted therein, and contract with Drawbridge Capital separately to provide advisory services. LPL provides only brokerage, custodial, and administrative services to the account. Due diligence and portfolio monitoring is not provided by LPL’s Research Department. Minimum account balances vary by portfolio manager, but typically start between $100,000 and $250,000. Financial Planning Services Drawbridge Capital, through its IARs, may provide personal financial planning tailored to the individual needs of each client for their retirement and/or non-retirement account(s). The services consider information collected from the client such as financial status, investment objectives and tax status, among other data. Fees for such services are negotiable and detailed in the client agreement. The financial plan may include generic recommendations as to general types of investment products or specific securities which may be appropriate for the client to purchase given his/her financial situation and objectives. The client is under no obligation to act upon the investment advisor’s recommendation or purchase such securities. However, if the client desires to purchase securities to implement his/her financial plan, IARs of Drawbridge Capital may make a variety of products available in their capacity as registered representatives of LPL Financial. This may result in the payment of normal and customary commissions, advisory fees or other types of compensation to Drawbridge Capital and the IAR. A conflict exists between the interests of the investment advisor and the interests of the client. Depending on the type of account/investments that could be used to implement a financial plan, such compensation includes (but is not limited to): advisory fees, commissions, mark-ups and mark-downs, transaction charges, confirmation charges, small account fees, mutual fund 12b-1 fees, mutual fund sub- transfer agency fees, hedge fund, managed futures, and variable annuity investor servicing fees, retirement plan fees, fees in connection with an insured deposit account program, marketing support payments from mutual fund, annuity and insurance sponsors, administrative servicing fees for trust accounts, referral fees, compensation for directing order flow, and bonuses, awards or other things of value offered by Drawbridge Capital to the IAR. To the extent that an IAR recommends that client invest in products and services that will result in compensation being paid to Drawbridge Capital and the IAR, this presents a conflict of interest. This compensation to the IAR and Drawbridge Capital may vary depending on the product or service that IAR recommends. Therefore, the IAR may have a financial incentive to recommend that a financial plan be implemented using a certain product or service over another product or service.
• A conflict exists between the interests of the investment advisor and the interests of the client.
• A client is under no obligation to act upon the investment advisor's recommendation.
• If the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through the investment advisor. 9 of 31 Such conflicts are mitigated by an IAR’s fiduciary duty to act in the best interest of their client. Financial planning is made available to all clients as either a comprehensive service or separately that may or may not result in a written plan. The amount of time required per plan can vary greatly depending on the scope and complexity of an individual engagement. A particular client’s financial plan will include the relevant types of planning specific to their needs and objectives such as:
• Retirement – planning an investment strategy with the objective of providing inflation-adjusted income for life.
• College / Education – planning to pay the future college / education expenses of a child or grandchild.
• Major Purchase – evaluation of the pros and cons of home ownership versus renting as well as buying or leasing a car, for example.
• Divorce – planning for the financial impact of divorce such as change in income, retirement benefits and tax considerations.
• Insurance Needs – planning for the financial needs of survivors to satisfy such financial obligations as housing, dependent child care and spousal arrangements as well as education.
• Final Expenses – planning to leave assets to cover final expenses such as funeral, debts and potential business continuity.
• Estate Planning – planning that focuses on the most efficient and tax friendly option to pass on an estate to a spouse, other family members or a charity.
• Cash Flow/ Debt Reduction – planning to manage expenses against current and projected income.
• Wealth Accumulation – planning to build wealth within a portfolio that takes into consideration risk tolerance and time horizon.
• Tax Planning – planning a tax efficient investment portfolio to maximize deductions and off- setting losses.
• Investment Planning – planning an investment strategy consistent with a particular objective, time horizon and risk tolerance.
• Inheritance Planning – planning for a tax efficient method to pass wealth to the next generation.
• Employee and Government Benefits Analysis – analysis of the cost and premiums as well as the pre-and post-retirement coverage options.
• Social Security Planning – analysis of expected benefits at retirement, disability or death as well as qualification criteria and age-based considerations. 10 of 31 Hourly Consulting Services Drawbridge Capital, through its IARs, may provide consulting services on an hourly basis. These services may include analyses of the above topics or any other specified topic, as selected by the client in the consulting agreement. The services consider information collected from the client such as financial status, investment objectives and tax status, among other data. The IARs may or may not deliver to the client a written analysis or report as part of the services. The IARs tailor the hourly consulting services to the individual needs of the client. The engagement terminates upon final consultation with the client. Retirement Plan Consulting IARs of Drawbridge Capital may assist clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory services. IARs may perform one or more of the following services, as selected by the client in the client agreement:
• Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan based upon consultation with client to ascertain Plan’s investment objectives and constraints.
• Acting as a liaison between the Plan and service providers, product sponsors or vendors.
• Ongoing monitoring of investment manager(s) or investments in relation to the criteria specified in the Plan’s IPS or other written guidelines provided by the client to IAR.
• Preparation of reports describing the performance of Plan investment manager(s) or investments, as well as comparing the performance to benchmarks.
• Ongoing recommendations, for consideration and selection by client, about specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan.
• Education or training for the members of the Plan investment committee regarding various matters, including plan features, retirement readiness, service on the committee, and fiduciary responsibilities.
• Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, IARs may provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan. If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, IARs do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan may invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or may obtain participant loans, IARs do not provide any individualized advice or recommendations to the participants regarding these decisions. In addition, if the client elects to engage an IAR to perform ongoing investment monitoring and ongoing investment recommendation services to a Plan subject to ERISA in the client agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Therefore, the IARs will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with 11 of 31 those services. Clients should understand that to the extent the IAR is engaged to perform services other than ongoing investment monitoring and recommendations, those services are not “investment advice” under ERISA and therefore, the IAR will not be a “fiduciary” under ERISA with respect to those other services. From time to time the IAR may make the Plan or Plan participants aware of and may offer services available from IAR that are separate and apart from the services provided under Retirement Plan Consulting. Such other services may be services to the Plan, to a client with respect to client's responsibilities to the Plan and/or to one or more Plan participants. In offering any such services, the IAR is not acting as a fiduciary under ERISA with respect to such offering of services. If any such separate services are offered to a client, the client will make an independent assessment of such services without reliance on the advice or judgment of the IAR. Such service may include:
• Assistance with investment education seminars and meetings for Plan participants. Such meetings may be on a group or individual basis and may include information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine investment time horizons and assess risk tolerance. Such meetings do not include specific investment advice about investment options under the Plan as being appropriate for a particular participant.
• Assistance in making changes to investment options under the Plan at the client’s direction.
• As part of the ongoing investment recommendation service set out above, assistance in identifying investment options in connection with the “broad range” requirement of Section 404(c) of the Employee Retirement Income Security Act of 1974 (“ERISA”).
• As part of the ongoing investment recommendation service set out above, assistance in identifying an investment fund product or model portfolio in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA.
• Assistance with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support in connection with vendor analysis and service provider support.
• Preparation of comparisons of Plan data (e.g., regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans.
• Assistance in identifying the fees and other costs borne by the Plan for, as specified by client, investment management, recordkeeping, participant education, participant communication and/or other services provided with respect to the Plan. Institutional Equity Strategies Drawbridge Capital manages several concentrated US equity strategies designed for institutional clients. The minimum account size for these strategies is $1 million, which has been waived for clients of Drawbridge IARs. Typically holding fewer than 35 positions with wide latitude on cash and sector weights, these strategies may at times be considered “non-diversified.” They should be expected to demonstrate significant tracking error against their benchmarks. The investment objectives of each strategy are to consistently generate positive risk-adjusted returns (alpha) and lower correlation to the broad US equity market in comparison with its benchmark. 12 of 31 Other Considerations Neither the firm nor any IAR are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the foregoing. Advisory agreements may not be assigned or transferred in any manner by any party without the written consent of all parties receiving or rendering services hereunder, however the IAR may assign an agreement upon consent of the client. An advisory agreement may be terminated by any party effective upon receipt of written notice to the other parties. The client will be entitled to a prorated refund of any pre-paid quarterly account fee based upon the number of days remaining in the quarter after the termination date. Clients need to understand that in the event of death or incapacity during the term of an advisory agreement, the authority of Drawbridge Capital under an advisory agreement shall remain in full force and effect until such time as Drawbridge Capital is notified otherwise in writing by the authorized representative of a client or a client’s estate. Termination of an advisory agreement will not affect the liabilities or obligations of the parties from transactions initiated prior to termination. Economic commentaries and research provided by LPL are provided at no cost and not contingent upon the amount of business processed through LPL. The IAR may receive additional cash or non-cash compensation from advisory product sponsors or TAMPs. Such compensation may not be tied to the sales of any products. Compensation may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings or marketing or advertising initiatives.