ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... ii ITEM 6 - SUPERVISION .............................................................................................................................. ii ITEM 7 - REQUIREMENTS FOR STATE-REGISTERED ADVISERS ................................................................ iii David Hutchison ................................................................................................................................ iv ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... iv Triad Investment Management Brochure Revised June 22, 2023 6 Professional Designations ................................................................................................................... iv ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iv ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iv ITEM 6 - SUPERVISION .............................................................................................................................. v ITEM 7 - REQUIREMENTS FOR STATE-REGISTERED ADVISERS ................................................................. v Client Privacy Notice ......................................................................................................................... A Triad Investment Management Brochure Revised June 22, 2023 7 Description of Advisory Firm Triad Investment Management, LLC (“Triad,” “we,” “our,” or “us”) is a privately owned limited liability company headquartered in Newport Beach, CA. John Heldman, Partner, founded Triad in 2008. The Heldman Family Trust and Hutchison Family Trust are the principal owners of the firm. Fiduciary Duty Registered investment advisers are considered fiduciaries under state and federal law. Our fiduciary duty carries with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and confidence. It encompasses a duty of care and a duty of loyalty. Duty of Care The duty of care includes, among other things, 1. the duty to provide advice that is in the best interest of the client; 2. the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades; and 3. the duty to provide advice and monitoring over the course of the relationship. The duty to provide advice suitable to each client based on a reasonable understanding of the client’s objectives is a critical component of the duty of care. Providing suitable advice includes making a reasonable inquiry into the client’s financial situation, investment experience, and financial goals and then updating this information as necessary throughout the course of the relationship to reflect the client’s changing objectives over time and adjusting the advice we provide to reflect any changed circumstances. When Triad has the responsibility to select broker-dealers to execute client trades in discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s services and so the determinative factor is not necessarily the lowest possible commission cost but whether the transaction represents the best qualitative execution. Moreover, we periodically and systematically evaluate the execution we receive on behalf of our clients. Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the best interest of the client, taking into account the scope of the agreed relationship. This scope is indicated by the duration and nature of the services as outlined in each client’s advisory arrangement and extends to all personalized advice provided to clients. Duty of Loyalty Triad adheres to a duty of loyalty where we seek to serve the best interests of our clients and never subordinate the interests of our clients to our own. Simply put, Triad cannot place its own interests ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at least expose through full and fair disclosure all conflicts of interest which might incline Triad, consciously or unconsciously, to render advice that is not disinterested. We believe that in order for disclosure to be Triad Investment Management Brochure Revised June 22, 2023 8 full and fair, it should be sufficiently specific so that each client is able to understand the material fact or conflict of interest and make an informed decision whether to provide consent. Consequently, we provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they can use the information within to decide whether or not to enter into an advisory relationship. Advisory Services Offered Triad offers the following services to advisory clients: Investment Management Services Triad provides continuous and regular investment supervisory services on a discretionary basis. John Heldman and Dave Hutchison work with clients and have the ongoing responsibility to select and/or make recommendations, based upon the objectives of the client, as to specific securities or other investments that Triad purchases or sells in client accounts. Triad’s recommendations for new investments will primarily include: 1. Equity securities 2. Warrants 3. Fixed income securities, including corporate bonds, government bonds and, municipal bonds, 4. Real estate investment trusts (REIT) 5. Publicly Traded Partnerships (PTPs) Additionally, Triad’s recommendations,

depending on the individual investment objectives and needs of the client may include: 1. Foreign securities listed on US exchanges (ADRs) 2. ETFs 3. Closed-end mutual funds Triad also occasionally offers advice regarding additional types of investments if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. Triad may offer investment advice on any investment held by the client at the start of the advisory relationship. We describe the material investment risks for many of the securities that we recommend under the heading Specific Security Risks in Item 8 below. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. We describe the Fees charged for investment management services below under Item 5 - Fees and Compensation. Our Fiduciary Duties to Clients with Retirement Plans When we provide investment advice to you regarding any retirement plan or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Triad Investment Management Brochure Revised June 22, 2023 9 Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Participant Account Management Triad utilizes a third-party platform to facilitate discretionary management of the accounts of retirement plan participants, including but not limited to 401(k) and defined contribution plan participant accounts (collectively, “held-away accounts”). These held-away accounts are not maintained with the custodian(s) we recommend but rather custodied at an institution selected by the client and/or their employer. We are not affiliated with the platform in any way and receive no compensation from them for using their platform; however, Triad pays a fee to the third-party platform provider for use of the service. A link will be provided to the client allowing them to connect the held-away account(s) to the platform. Once accounts are connected to the platform, Triad will regularly review the available investment options in these accounts, monitor them, and rebalance them, though using different tools, as necessary. Financial Planning Services Triad does not generally provide comprehensive financial planning services, but we may offer financial planning related services as part of our overall advisory services. These services generally involve providing advice to clients regarding the investment/management of financial resources based upon an analysis of their individual needs. A written plan is generally provided. However, we do not include preparation of any income tax, gift, or estate tax returns, or preparation of any legal documents. Triad does not receive separate compensation for financial planning related services. In accordance with the California Code of Regulations section 260.235.2: a. Neither the adviser nor any affiliate or associated person of Adviser will receive commissions from the sale of insurance or real estate, or fees or other compensation from the sale of securities or other products or services recommended in the financial plan, or otherwise has a conflict of interest. b. Client is under no obligation to act on Adviser's or its associated persons’ recommendations. c. If Client elects to act on any Adviser's or its associated persons’ recommendations, Client is under no obligation to effect the transaction through Adviser or its associated persons when such person is employed as an agent with a licensed broker-dealer or is licensed as a broker- dealer or through any associate or affiliate of such person. Triad Investment Management Brochure Revised June 22, 2023 10 Limitations on Investments Limitation by Client Triad may limit advice based on certain client-imposed restrictions. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. Tailored Services and Client Imposed Restrictions Triad manages client accounts based on the investment strategy, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Triad applies the strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our recommendations may be limited if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep Triad informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want Triad to buy or sell certain specific securities or security types in the account. Triad reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Wrap Fee Programs Triad does not manage accounts as part of a wrap or bundled fee program. Assets Under Management Triad manages client assets in discretionary accounts on a continuous and regular basis. As of December 31, 2022, the total amount of assets under our management was $76,948,899. We did not manage any accounts on a non-discretionary basis.