Corbett Road Capital Management, LLC ("CRCM", or “the Firm”) is a State-registered investment adviser with its principal place of business located in Virginia. CRCM was registered in April 2024. Listed below are the Firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company):
• Corbett Road Investment Partners, LLC is a corporation and is the owner of CRCM.
• In addition, the following information identifies those parties that indirectly own 25% or more of our firm:  CRCM and Spire Investment Partners, LLC are corporations which together own CR Investment Partners, LLC.  David L. Blisk is the CEO and Managing Member of Spire Investment Partners, LLC  Christopher Scott Airey is the CEO and the owner of CRCM CRCM serves institutionally oriented accounts, which include financial advisory firms, other institutions as well as any client who invests $20 million or more with the Firm. CRCM offers active management of Separately Managed Account portfolios (“SMAs”) via proprietary models that can be accessed at third party investment advisors or dually registered broker-dealer and investment advisor firms, generally via sub-advisory agreements, dual- contract arrangements, or as part of a so-called “wrap” program. Under wrap programs, Sponsor Firms (and the financial advisors at those Sponsor Firms) assist clients with the selection of CRCM to manage the assets in accounts maintained at the Sponsor Firm, collect CRCM’s investment advisory fee on behalf of the client, monitor and evaluate CRCM’s performance, and provide custodial and execution services for the client’s assets. CRCM does not currently participate in any wrap programs. Sub-Advisory Services in Separately Managed Accounts: Our Solution Descriptions Corbett Road Capital Management, LLC provides investment management services to Advisors and Institutions. The firm offers smarttactical™ Strategies with either our proprietary macrocast™ or microcast™ risk overlays, tax-efficient tactical, actively managed, and asset allocation strategies. Our clients can blend these offerings allowing the final solution to be custom-tailored to their or their client’s needs.
• Tactical Solutions - Our smarttactical™ Strategies enable a portfolio to be more adaptive to changing market environments. These strategies can invest in any exchange traded asset class and are not restricted by market cap, sector, or geographic location. They may also hold a substantial fixed income or cash position based upon our macrocast™ or microcast™ risk indicators.
• Active Solutions - Actively managed strategies seeking long-term growth of capital. Designed to remain fully invested throughout the economic cycle, weathering market volatility, and generating alpha through stock selection.
• Hybrid Solutions - Our tax-effective hybrid model combines tactical and passive risk management solutions designed to be used in taxable accounts. The hybrid solution seeks to capture the risk reduction benefits of tactical management in a tax-efficient manner.
• Passive Solutions - Passive by nature, strategic by design—our asset allocation solutions offer a simple way to build a broadly diversified core portfolio. Available in allocation mixes spanning the target risk spectrum, our passive strategies establish a client's long-term base portfolio using low-cost, passive ETF products. While strategic adjustments are made on a year-to-year basis, these portfolios are designed to remain invested throughout the economic cycle and market fluctuations. Providing broad exposure to global equity, fixed income, and real estate markets, our passive solutions can be used as a standalone solution or in conjunction with our other strategies. Corbett Road believes the foundation of long-term investing success is proper risk management that goes beyond the diversification of traditional asset allocation. Through the combination of passive, active, tactical, and hybrid strategies, the Firm delivers a comprehensive solution that strives to be proactive, adaptive, and responsive to changes in the market environment. This blended solution is tailored to fit the client’s risk profile, improving adherence to the Advisor’s guidance, and assisting the client in achieving their financial goals. STRATEGY DESCRIPTIONS TACTICAL SOLUTIONS - MACROCAST™ (MX)
• Opportunity MX Investment Objective The Opportunity MX Strategy is a tactical solution that seeks long-term growth of capital and attempts to mitigate drawdowns during economic downturns by reducing the strategy’s equity exposure. Investment Strategy This strategy targets between 35-40 individual equity positions, though it may invest in ETF’s or other exchange traded assets when needed. It can invest in any exchange traded asset class and is not restricted by market cap, sector, or geographic location. Based upon macrocast™ indicators, this strategy may hold a substantial fixed income or cash position as broader macroeconomic conditions deteriorate and are deemed unfavorable. The Opportunity MX Strategy takes a dual-pronged approach to research and investment. The top-down macro analysis is driven by CRCM's proprietary risk model, macrocast™, which determines the strategy's equity allocation based on prevailing economic conditions. A deeper assessment of the market cycle drives equity positioning, and individual investments are selected using a bottom-up, fundamental approach. Through our dual approach, economic events are recognized for their potential to affect overall market returns while a deeper analysis of individual investments aims to incrementally add to potential returns.
• Dynamic MX Investment Objective The CRCM Dynamic MX Strategy is a tactical solution that seeks long-term growth of capital and attempts to mitigate drawdowns during economic downturns by reducing the strategy’s equity exposure. The strategy invests exclusively in exchange-traded funds (ETFs). Investment Strategy This strategy targets between 17-20 ETF positions and utilizes a core/satellite approach to investing. It can invest in any exchange-traded fund (ETF), and it primarily invests in broad market index ETFs, sector- and industry-specific ETFs, as well as factor and style focused ETFs. Based upon macrocast™ indicators, this strategy may hold a substantial fixed income or cash position as broader macroeconomic conditions deteriorate and are deemed unfavorable. The Dynamic MX Strategy is a flexible ETF strategy that takes a top-down approach to investing. The top- down macro analysis is driven by CRCM's proprietary risk model, macrocast™, which determines the strategy's equity allocation based on prevailing economic conditions. Intra-cycle analysis drives individual investments. Certain styles, factors and industries outperform at different stages of the market cycle, and Dynamic MX seeks to capitalize on these trends by making active sector bets and concentrated satellite investments in factor and industry-focused ETFs.
• Core Demand MX Investment Objective The Core Demand MX Strategy is a tactical solution that seeks long-term growth of capital and attempts to mitigate drawdowns during economic downturns by reducing the strategy’s equity exposure. Investment Strategy This strategy targets between 35-40 individual equity positions. It can invest in any exchange traded asset class and is not restricted by market cap, sector, or geographic location. Based upon macrocast™ indicators, this strategy may hold a substantial fixed income or cash position as broader macroeconomic conditions deteriorate and are deemed unfavorable. The Core Demand MX Strategy takes a dual-pronged approach to research and investment. The top-down macro analysis is driven by CRCM's proprietary risk model, macrocast™, which determines the strategy's equity allocation based on prevailing economic conditions. Individual investments are selected using a bottom-up, fundamental approach that leverages environmental, social, and governance (ESG) data to identify sustainable businesses. By utilizing an ESG filter, the strategy seeks to identify financially-material environmental, social, and governance issues that may impact corporate performance. We subscribe to an independent third-party ESG data firm that provides company ESG ratings for equity securities. In addition to other factors, ESG ratings are incorporated into the strategy’s investment framework as a means of identifying sustainable businesses. ESG ratings affect the investment selection process and the strategy’s sell discipline, but they are not the sole consideration. The ESG ratings used are absolute measures of risk that measure a company's exposure to industry-specific material ESG risks and how well the company is managing those risks. The ESG filter allows the Core Demand MX Strategy to invest in any company with a rating of negligible to medium ESG risk severity, as defined by the data provider. We may buy issuers from a poorly ranking ESG sector, such as oil and gas production, if the issuer's rating falls within the previously defined range of eligible scores. TACTICAL SOLUTIONS - MICROCAST™ (TX)
• Opportunity TX Investment Objective The Opportunity TX Strategy is a tactical solution that seeks moderate long-term growth of capital and attempts to mitigate market drawdowns during periods of elevated volatility and weakening market internals by reducing the strategy’s equity exposure. Investment Strategy This strategy targets between 35-40 individual equity positions, though it may invest in ETF’s or other exchange traded assets when needed. It can invest in any exchange traded asset class and is not restricted by market cap, sector, or geographic location. Based upon microcast™ indicators, this strategy’s allocation to equities will adjust to the prevailing market environment and may hold a substantial fixed income or cash position when underlying market conditions are deemed unfavorable. The Opportunity TX Strategy takes a dual-pronged approach to research and investment. The top-down market analysis is driven by CRCM's proprietary risk model, microcast™, which determines the strategy's equity allocation based on prevailing market conditions. A deeper assessment of the market cycle drives equity positioning, and individual investments are selected using a bottom-up, fundamental approach. Through our dual approach, underlying market conditions are recognized for their potential to impair overall market returns while a deeper analysis of individual investments aims to incrementally add to potential returns.
• Dynamic TX Investment Objective The Dynamic TX Strategy is a tactical solution that seeks moderate long-term growth of capital and attempts to mitigate market drawdowns during periods of elevated volatility and weakening market internals by reducing the strategy’s equity exposure. The strategy invests exclusively

in exchange-traded funds (ETFs). Investment Strategy This strategy targets between 17-20 ETF positions and utilizes a core/satellite approach to investing. It can invest in any exchange-traded fund (ETF), and it primarily invests in broad market index ETFs, sector- and industry-specific ETFs, as well as factor and style focused ETFs. Based upon microcast™ indicators, this strategy’s allocation to equities will adjust to the prevailing market environment and may hold a substantial fixed income or cash position when underlying market conditions are deemed unfavorable. The Dynamic TX Strategy is a flexible ETF strategy that takes a top-down approach to investing. The top- down market analysis is driven by CRCM’s proprietary risk model, microcast™, which determines the strategy’s equity allocation based on prevailing market conditions. Intra-cycle analysis drives individual investments. Certain styles, factors and industries outperform at different stages of the market cycle, and Dynamic TX seeks to capitalize on these trends by making active sector bets and concentrated satellite investments in factor and industry-focused ETFs.
• Core Demand TX Investment Objective The Core Demand TX Strategy is a tactical solution that seeks moderate long-term growth of capital and attempts to mitigate market drawdowns during periods of elevated volatility and weakening market internals by reducing the strategy’s equity exposure. Investment Strategy This strategy targets between 35-40 individual equity positions. It can invest in any exchange traded asset class and is not restricted by market cap, sector, or geographic location. Based upon microcast™ indicators, this strategy’s allocation to equities will adjust to the prevailing market environment and may hold a substantial fixed income or cash position when underlying market conditions are deemed unfavorable. The Core Demand TX Strategy takes a dual-pronged approach to research and investment. The top-down market analysis is driven by CRCM’s proprietary risk model, microcast™, which determines the strategy’s equity allocation based on prevailing market conditions. Individual investments are selected using a bottom-up, fundamental approach that leverages ESG data to identify sustainable businesses. By utilizing an ESG filter, the strategy seeks to identify financially-material environmental, social, and governance issues that may impact corporate performance. We subscribe to an independent third-party ESG data firm that provides company ESG ratings for equity securities. In addition to other factors, ESG ratings are incorporated into the strategy’s investment framework as a means of identifying sustainable businesses. ESG ratings affect the investment selection process and the strategy’s sell discipline, but they are not the sole consideration. The ESG ratings used are absolute measures of risk that measure a company’s exposure to industry-specific material ESG risks and how well the company is managing those risks. The ESG filter allows the Core Demand TX Strategy to invest in any company with a rating of negligible to medium ESG risk severity, as defined by the data provider. We may buy issuers from a poorly ranking ESG sector, such as oil and gas production, if the issuer’s rating falls within the previously defined range of eligible scores. ACTIVE SOLUTIONS
• Core Demand Investment Objective The Core Demand Strategy is an active solution that seeks long-term growth of capital. Investment Strategy This strategy targets between 35-40 individual equity positions. It can invest in any exchange traded asset class and is not restricted by market cap, sector, or geographic location. This actively managed strategy is designed to remain fully invested through market volatility and economic cycles. Individual investments are selected using a bottom-up, fundamental approach that leverages environmental, social, and governance (ESG) data to identify sustainable businesses. By utilizing an ESG filter, the strategy seeks to identify financially-material environmental, social, and governance issues that may impact corporate performance. We subscribe to an independent third-party ESG data firm that provides company ESG ratings for equity securities. In addition to other factors, ESG ratings are incorporated into the strategy’s investment framework as a means of identifying sustainable businesses. ESG ratings affect the investment selection process and the strategy’s sell discipline, but they are not the sole consideration. The ESG ratings used are absolute measures of risk that measure a company's exposure to industry-specific material ESG risks and how well the company is managing those risks. The ESG filter allows the Core Demand Strategy to invest in any company with a rating of negligible to medium ESG risk severity, as defined by the data provider. We may buy issuers from a poorly ranking ESG sector, such as oil and gas production, if the issuer's rating falls within the previously defined range of eligible scores.
• Select Q Investment Objective The Select Q Strategy is an active solution that seeks long-term aggressive growth of capital. Investment Strategy This strategy targets 25 individual equity positions. This actively managed strategy is designed to remain fully invested through market volatility and economic cycles. The Select Q Strategy is a concentrated, growth equity strategy seeking long-term capital appreciation through investments in innovative, large-cap growth stocks. The strategy selects 25 stocks from the Nasdaq-100 Index® using a multi-factor model to identify high-quality, high-growth businesses exhibiting positive earnings momentum.
• Opportunity Investment Objective The Opportunity Strategy is an active strategy that seeks long-term growth of capital. Investment Strategy This strategy targets between 35-40 individual equity positions, though it may invest in ETF’s or other exchange traded assets when needed. It can invest in any exchange traded asset class and is not restricted by market cap, sector, or geographic location. This actively managed strategy is designed to remain fully invested through market volatility and economic cycles. The Opportunity Strategy takes a dual-pronged approach to research and investment. Top-down macroeconomic analysis is utilized to assess the current market environment and drives portfolio-level positioning within the equity universe. Individual investments are selected using a bottom-up, fundamental approach. In combining top-down macroeconomic research with individual stock selection, economic events are recognized for their potential to affect overall market returns while a deeper analysis of individual investments aims to incrementally add to potential returns.
• Dynamic Investment Objective The Dynamic Strategy is an active solution that seeks long-term growth of capital. The strategy invests exclusively in exchange-traded funds (ETFs). Investment Strategy This strategy targets between 17-20 ETF positions and utilizes a core/satellite approach to investing. It can invest in any exchange-traded fund (ETF), and it primarily invests in broad market index ETFs, sector- and industry-specific ETFs, as well as factor and style focused ETFs. This actively managed strategy is designed to remain fully invested through market volatility and economic cycles. The Dynamic ETF Strategy is a flexible ETF strategy that takes a top-down approach to investing. Individual investments are selected based off the firm’s research and analysis of the market cycle. Certain styles, factors, and industries outperform at different stages of the market cycle, and Dynamic ETF seeks to capitalize on these trends by making active sector bets and concentrated satellite investments in factor and industry-focused ETFs. HYBRID SOLUTIONS
• HELIX Series Investment Objective The HELIX Series is a hybrid solution. The strategy’s growth and risk objectives vary depending on the targeted allocation to equities and fixed income investments. Investment Strategy The foundation of HELIX is the strategy's investment in actively managed exchange-traded funds (ETFs) that take a tactical approach to investing. The core allocation to tactical ETFs is complemented by 8-15 broadly diversified ETFs with target allocations determined by the risk tolerance of the individual investor. The HELIX Strategy combines strategic asset allocation with tactical risk management to create a diversified client solution. Specifically designed for taxable accounts, the HELIX series seeks to capture the risk reduction benefits of tactical management in a tax-efficient manner.
• Buffered Outcome Strategies Buffered Outcome Strategies are constructed using a combination of multiple Buffered Exchange Traded Funds (ETFs). These strategies are designed to offer a different approach to risk management by enabling investors to participate in the growth potential of equity markets up to a stated cap, with a specific downside buffer. Buffered ETFs are constructed with an actively managed basket of FLEX Options. FLEX Options allow for customized strike prices, underlying reference assets, and expiration dates. Having strike prices that expire on a designated date forms an outcome period. The combination of these options coming together results in the reference asset (or index) exposure, the buffer, and the cap of a Buffered ETF. PASSIVE SOLUTIONS
• MyPath Asset Allocation PortfoliosTM (MAAP) Investment Strategy myPath Asset Allocation PortfoliosTM (MAAP) are passive, strategic asset allocation solutions focused on risk diversification. By investing in broad-based, passively managed exchange traded funds (ETFs), these portfolios aim to balance risk across major asset classes to reduce variability in returns. Each portfolio’s level of risk is embedded in the corresponding targeted allocation. Allocation percentages, strategic adjustments, and rebalances of the portfolios are guided by the firm’s market outlook and the variance of individual positions from their targeted allocations. CRCM offers three MAAP strategies for clients to choose from: o MAAP Traditional - provides a well-diversified asset allocation that can be used in any type of account. o MAAP Dividend - provides a well-diversified asset allocation solution that focuses on income producing equity ETFs. o MAAP Tax-Aware - provides a well-diversified asset allocation solution that utilizes municipal bond ETFs in an effort to produce a more tax-aware result. Clients may impose restrictions on investing in certain securities or types of securities so long as the restrictions do not fundamentally alter the overall strategy. CRCM in its sole discretion can determine whether to accept any client specific restrictions. Amount of Managed Assets As of December 31, 2023, the Firm had approximately $ 45,885,638 in sub-advisory assets under management.