Disclosures.

Registration

Stratum Capital Management LLC is registered as an investment adviser with the State of Texas. Registration does not imply a certain level of skill or training.

Our Form ADV filings are available through the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov. Our firm brochure (Form ADV Part 2A) is published on this site and delivered to clients before they sign.

Our services and fees

We provide discretionary investment management through one portfolio, Stratum Capital, held at 30% Core and 70% Alpha. Our only compensation is the asset-based management fee set out in the fee schedule, no commissions, no performance fees, no third-party payments.

The complete fee schedule appears on our fees page, in our brochure, and in the advisory agreement. All three state identical figures.

Risks

Investing involves risk of loss, including loss of principal. Past performance does not guarantee future results. You can lose a large part, or all, of the money you invest. The material risks are described in full in our brochure. They are:

Concentration. Alpha is 70% of the portfolio and has no cap on the size of a position and no set number of positions, so one company can carry much of the account. Core can hold a single company or be entirely in cash.

Lag in strong markets. Core is designed to limit the depth of declines and is expected to lag growth-led markets. The portfolio can trail the broad market for long periods.

The drawdown brake. Core’s brake acts after a decline. It can sell at low prices and miss a recovery.

Judgment and data. Alpha depends on theses, scores and verdicts we produce, and we can be wrong. Both methodologies use third-party data, which can be wrong, late or unavailable.

Turnover and tax. Core is rebuilt each quarter and Alpha is liquidated and rebuilt each January. In a taxable account this realizes gains and losses every year, and short-term gains are generally taxed at ordinary income rates. We do not provide tax advice.

We publish no performance figures on this site. We make no promises about returns.

Conflicts of interest

Our asset-based fee gives us an incentive to encourage larger account balances. We disclose this plainly and manage it by offering the portfolio only where it fits your goals.

Our personnel may invest personally in the same securities we buy for clients. This is a conflict of interest. We manage it through our written Code of Ethics: client trades take priority, and no personal trade may disadvantage a client trade. The Code of Ethics is available on request.

We have no other compensation-related conflicts: no commissions, no affiliated broker-dealer, no proprietary products, no referral payments, no soft dollars.

Suitability

Before an account opens, you answer fit questions and acknowledge the risk statement. A person at the firm reviews every application, records a decision and the reason, and may decline it. The fit questions are not an approval. Each year we ask you to confirm your profile, and we ask you to tell us when your circumstances change.

Custody

Client assets are held at a qualified custodian (Interactive Brokers) in the client’s own name. We never take possession of client funds or securities. Our fee is deducted from the custodial account under your written authorization.

Disciplinary history

Neither the firm nor its professionals have any reportable legal or disciplinary history.

How to verify us and complain

Verify our registration at adviserinfo.sec.gov. If you have a complaint about our services, write to us first, we take complaints seriously and respond promptly. You may also contact the Texas State Securities Board.

Full documents

Firm brochure (Form ADV Part 2A) · Form CRS · Advisory agreement · Privacy policy

Questions: ask@stratumcapitalclub.com. Last updated: October 2026.