9AT: CIOVACCO CAPITAL MANAGEMENT

Adviser Profile

As of Date	07/16/2026
Registration	SEC, Approved, 04/13/2021
Other registrations (9)	New York, Terminated, 11/16/2021 Colorado, Approved, 04/03/2020 North Carolina, Approved, 05/06/2019 Massachusetts, Approved, 05/18/2016 Florida, Approved, 09/01/2012 Texas, Approved, 06/27/2012 California, Approved, 06/05/2012 Georgia, Approved, 05/23/2012 Nevada, Terminated, 11/20/2009
Contact Info	678 xxxxxxx
Websites

AUM^*	217,305,940 40%
of that, discretionary	215,601,539 40%
Number of Employees	2
of those in investment advisory functions	1
Private Fund GAV^*	0
Avg Account Size	626,242 18%
% High Net Worth	66.22% 6%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Corporations or other businesses not listed above

Advisory Activities

- Portfolio management for individuals and/or small businesses

Compensation Arrangments

- A percentage of assets under your management

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser SCHOLTZ & COMPANY, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM340.5m	#Funds-
Adviser REBALANCE LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund101.9m	Other Fund-	Total Private Fund GAV203.8m	AUM1.9b	#Funds7
Adviser BIRCHBROOK	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM296.5m	#Funds-
Adviser PLANNING CAPITAL MANAGEMENT CORP.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM313.3m	#Funds-
Adviser FULLEN FINANCIAL GROUP, INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM282.0m	#Funds-
Adviser ELEVATION WEALTH PARTNERS, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM670.7m	#Funds-
Adviser OARSMAN CAPITAL, INC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM1.2b	#Funds-
Adviser GEMMER ASSET MANAGEMENT LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM2.4b	#Funds-
Adviser HOXTON PLANNING & MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM591.5m	#Funds-
Adviser KRAEMATON INVESTMENT ADVISORS, INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM201.5m	#Funds-

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker922908363	Stock NameVANGUARD INDEX FDS	$ Position$68,638,874	% Position40.00%	$ Change-8.00%	# Change-3.00%
Stck Ticker78464A409	Stock NameSPDR SERIES TRUST	$ Position$21,163,203	% Position12.00%	$ Change-9.00%	# Change-1.00%
Stck Ticker78462F103	Stock NameSTATE STR SPDR S&P 500 ETF T	$ Position$18,660,315	% Position11.00%	$ Change-31.00%	# Change-28.00%
Stck Ticker46090E103	Stock NameINVESCO QQQ TR	$ Position$12,196,876	% Position7.00%	$ Change-11.00%	# Change-6.00%
Stck Ticker81369Y852	Stock NameSELECT SECTOR SPDR TR	$ Position$6,324,392	% Position4.00%	$ Change-8.00%	# Change-2.00%
Stck Ticker464287721	Stock NameISHARES TR	$ Position$4,659,039	% Position3.00%	$ Change-44.00%	# Change-38.00%
Stck Ticker922908736	Stock NameVANGUARD INDEX FDS	$ Position$5,203,327	% Position3.00%	$ Change-11.00%	# Change-1.00%
Stck Ticker78463V107	Stock NameSPDR GOLD TR	$ Position$5,789,982	% Position3.00%	$ Change38.00%	# Change27.00%
Stck Ticker316092808	Stock NameFIDELITY COVINGTON TRUST	$ Position$2,744,250	% Position2.00%	$ Change-8.00%	# Change-1.00%
Stck Ticker92189F676	Stock NameVANECK ETF TRUST	$ Position$3,668,642	% Position2.00%	$ Change9.00%	# Change2.00%

Brochure Summary

Overview

CCM offers discretionary portfolio management services for individuals, high net worth individuals, corporations, or other business entities. CCM has been in business since November 1999. CCM works with clients on a fee-only, fiduciary basis. This means we work for our clients and are compensated directly by the client. We do not accept any commissions or referral fees. Christopher Ciovacco, President and Chief Executive Officer is the principal owner. CCM uses a proprietary model, the CCM Market Model (model or market model), to manage separate accounts held by a third-party custodian. The thoroughly researched and backtested market model recommends a prudent allocation between growth-oriented exchange-traded funds (ETFs) and lower volatility ETFs. Growth-oriented ETFs include, but are not limited to, those with exposure to U.S. stocks, market sectors, small caps, mid caps, large caps, foreign stocks, regions of the globe, individual countries, commodities, and precious metals. Lower volatility ETFs include, but are not limited to, those with exposure to bonds, preferred stocks, and currencies. The model under very specific and limited circumstances can allocate to inverse-stock ETFs. CCM offers advice primarily on exchange-traded funds. ETFs selected by CCM’s

proprietary market model may be comprised of or have exposure to equity securities (U.S. and foreign), corporate debt securities, municipal securities, United States government securities, currencies, interests in partnerships investing in real estate and oil & gas interests, commodities, and precious metals. CCM reserves the right to advise clients on any other type of investment it deems appropriate based on the client’s stated goals and objectives. CCM may also provide advice about any type of investment held in a client’s portfolio at the inception of the advisory relationship. All accounts are managed on a discretionary basis. Client allocations are based on current market conditions and model readings. Under certain circumstances and market conditions, very limited tailoring occurs based on the client’s individual needs and risk tolerance. Limited tailoring can take the form of higher cash levels, excluding some higher volatility ETFs from an allocation, or adjusting allocations. Clients may not impose restrictions on the ETFs selected for investment, nor the mix of ETFs in the client’s portfolio. On a discretionary basis, CCM manages $154,061,856 in assets as of March 12, 2024. On a non- discretionary basis, CCM manages $1,179,157 in assets as of March 12, 2024.

CIOVACCO CAPITAL MANAGEMENT

CIOVACCO CAPITAL MANAGEMENT

CIOVACCO, CHRISTOPHER GEORGE

CIOVACCO CAPITAL MANAGEMENT, LLC

CIOVACCO CAPITAL MANAGEMENT LLC

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Top Holdings

Brochure Summary

Overview

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CIOVACCO CAPITAL MANAGEMENT CIOVACCO CAPITAL MANAGEMENT CIOVACCO, CHRISTOPHER GEORGE CIOVACCO CAPITAL MANAGEMENT, LLC CIOVACCO CAPITAL MANAGEMENT LLC

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Top Holdings

Brochure Summary

Overview

CIOVACCO CAPITAL MANAGEMENT

CIOVACCO CAPITAL MANAGEMENT

CIOVACCO, CHRISTOPHER GEORGE

CIOVACCO CAPITAL MANAGEMENT, LLC

CIOVACCO CAPITAL MANAGEMENT LLC