A. Firm Information Regatta Capital Group, LLC (“Regatta” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”), which is organized as a Limited Liability Company (“LLC”) under the laws of the State of California. Regatta was founded in November 2007 and is owned and operated by Russell Mohberg (Co- founder, Partner, and Chief Compliance Officer) and Spencer Kelly (Co-founder, Partner, and Head of Advisory Services). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Regatta. B. Advisory Services Offered Regatta offers investment advisory services to individuals, high net worth individuals, pension and profit-sharing plans, corporations, charitable organizations, and institutional investors (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. Regatta’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Regatta provides Clients with wealth management services, which generally include a broad range of comprehensive financial planning and consulting strategies as well as discretionary and non-discretionary management of investment portfolios. Investment Management Services – Regatta provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and consulting services. Regatta works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Regatta will then construct a portfolio consisting of low-cost, diversified mutual funds and/or exchange- traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, and options, as appropriate, to meet the needs of its Clients. Regatta selects, recommends, and/or retains mutual funds on a fund by fund basis and seeks to use non-retail or institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax consideration, and/or systematic investment plans, Regatta may select, recommend, and/or retain a mutual fund share class that has a higher expense ratio than an equivalent share class. Regatta will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and state investment guidelines. Regatta’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Regatta will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Regatta evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Regatta may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Regatta may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Regatta may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, changes in the risk tolerance of the Client, generating cash to meet Clients’ needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor 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. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction, including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client Page 6 investment advisory agreement; please see Item 12 – Brokerage Practices. Private Fund Advisor Services – Regatta may also recommend that certain Clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, and a “qualified purchaser” as that term is defined in Section 2(a)(51)(A) of the Investment Company Act of 1940, invest in affiliated pooled investment vehicles (each a “Fund” and collectively the “Funds”). Investing in affiliated Funds presents a conflict of interest as management persons benefit financially from additional revenue. Additionally, the Advisor will charge its wealth management fee described in Item 5 below for assets invested in the Funds. Clients are under no obligation to invest in affiliated Funds. The Advisor serves as the investment manager of the Funds, whereas an affiliated entity serves as the General Partner. If a Client determines to invest in the Funds, the amount of assets invested in the Funds shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee per Item 5 below. The management of the Funds is described in the relevant Fund’s Offering Documents. The Advisor’s Clients are under no obligation to consider or make an investment in the Funds. The Advisor does not receive a separate advisory fee or other forms of compensation for its investment advisory services to a Funds. Rather, the Advisor’s only compensation is the advisory fee that it receives from any value included as a part of its assets under management. Please

see Item 10 for additional details. The Advisor manages each Fund based on the investment objectives, policies, and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in a Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. In general, investors in the Funds are not permitted to impose restrictions or limitations. However, the Advisor may enter into side letter agreements with one or more investors that may alter, modify, or change the terms of interest held by investors. Certain types of side letters create a conflict of interest between the Advisor and the investors in the Fund and/or between investors themselves. For more detailed information on investment objectives, policies and guidelines, please refer to the respective Fund’s Offering Documents. Financial Planning and Consulting Services – Regatta will typically provide a variety of financial planning services to individuals and families as part of its wealth management services or pursuant to a written financial planning or consulting agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Regatta may also refer Clients to an accountant, attorney, or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Regatta provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to Page 7 the needs of the Plan and Plan Sponsor. Services generally include:
• Fee Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight (ERISA 3(21))
• Investment Management (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services Communication and Education - Regatta provides Communication and Education to the Plan and the Plan Participants, pursuant to the terms of the Advisor’s agreement with each Plan Sponsor:
• Investment education
• Periodic on-site advisor visits with staff for account updates and reviews
• Periodic Plan Participant group education These services are provided by Regatta, serving in the capacity of a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Regatta’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. Transformational Coaching Services Regatta’s financial advisor, Lisa Margulies, may offer to Clients of Regatta, as well as the general public, transformational coaching services. These services consist of a highly developed series of coaching sessions focused on identifying barriers to personal fulfillment and breakthroughs to transforming one’s life. C. Client Account Management Prior to engaging Regatta to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include:
• Client Suitability – Regatta will document the Client profile with financial statements or financial plans. Regatta develops a statement that summarizes the Client’s investment goals and objectives along with the broad management strategy to be employed to meet the Client’s objectives and ensure decisions made are suitable for the Client.
• Asset Allocation – Regatta will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – Regatta will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Regatta will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Regatta does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Regatta. E. Assets Under Management As of December 31, 2023, Regatta manages $1,162,612,228 in Client assets, $982,171,034 of which are managed on a discretionary basis and $180,441,194 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.