Form ADV Part 2 - Draft Update 2025

1 Form ADV Part 2A - Draft Update

Invest Vegan LLC DBA Ethical Capital Investment Collaborative

DRAFT FOR REVIEW - NOT FINAL This draft addresses critical inconsistencies identified in the disclosure audit

1.1 CRITICAL UPDATES REQUIRED

1.1.1 1. Item 1 - Cover Page Updates

Current Issues: - Phone number inconsistency: Shows (212) 321-5111 - Entity name clarity needed - Date requires updating

Proposed Changes:

**Registered Investment Adviser**
**CRD #316032**

**Legal Entity Name**: Invest Vegan LLC
**DBA**: Ethical Capital Investment Collaborative
**Address**: 90 N 400 E, Provo, UT 84606
**Phone**: +1 347 625 9000
**Email**: info@ethicic.com
**Website**: ethicic.com

### Form ADV Part 2A - Firm Brochure
**Date**: [UPDATE TO CURRENT DATE - SEPTEMBER 2025]

This brochure provides information about the qualifications and business practices of Invest Vegan LLC DBA Ethical Capital Investment Collaborative. Please contact Sloane Ortel at +1 347 625 9000 or info@ethicic.com if you have any questions about the content of this brochure.

1.1.2 2. Item 2 - Material Changes

Proposed Addition:

# Item 2 - Material Changes

This item describes the material changes we have made to our Form ADV Part 2A since our previous amendment filed [PREVIOUS DATE].

## Key Changes Since Last Filing

**September 2025 Amendment:**
- **Contact Information**: Updated primary phone number to +1 347 625 9000
- **Entity Name Clarification**: Clarified legal structure as "Invest Vegan LLC DBA Ethical Capital Investment Collaborative"
- **Fee Structure Update**: [IF APPLICABLE - Added institutional client fee tier at 0.50% AUM]
- **Regulatory Compliance**: Updated cybersecurity and data breach notification procedures per SEC Regulation S-P
- **Service Provider Updates**: [IF APPLICABLE - Updated custodial relationships and service provider arrangements]

**Previous Changes** (from earlier amendments):
- Removed "short term reserves" from investment strategies list
- Re-titled income and diversification strategies for brand consistency

1.1.3 3. Item 4 - Advisory Business (Critical Update Needed)

Current Issue: AUM and client count requires updating

Proposed Update:

**4.A. Description of Firm**
Invest Vegan LLC is a Utah-domiciled limited liability company formed in July 2021. We operate under the DBA "Ethical Capital Investment Collaborative" and commonly use the abbreviated references "Ethical Capital" and "ECIC."

Sloane Ortel is the firm's Founder, serves as Chief Compliance Officer (supervisor), and maintains majority interest in the firm. Additional information about Ms. Ortel and her professional experience can be found toward the end of this brochure and in her Form ADV Part 2B brochure supplement.

Our firm is not a subsidiary of, nor do we control, another financial services industry entity. However, Ethical Capital has various industry business relationships that are discussed in Items 10 and 12 of this firm brochure.

**Assets Under Management** (as of [CURRENT DATE]):
- Discretionary Assets: $[CURRENT AUM AMOUNT]
- Non-Discretionary Assets: $[AMOUNT IF ANY]
- Total Client Households: [CURRENT COUNT]

*Note: AUM figures to be updated with current data before filing*

1.1.4 4. Item 5 - Fees and Compensation (CRITICAL FEE STRUCTURE UPDATE)

Issue: Current Form ADV shows single 1.00% rate but fee constants suggest institutional tier

OPTION A: If Single Fee Structure (1.00% for all clients)

**Portfolio Management Fees**

Our fee schedule is structured as follows:

| Client Type | Assets Under Management | Annualized Fee Rate |
|-------------|------------------------|-------------------|
| All Clients | $0 - $∞ (infinity) | 1.00% (100 basis points) |

**Fee Calculation**: Fees are calculated quarterly in advance based on the market value of your account on the last business day of the preceding quarter.

***Formula***: ((quarter-end market value) x (applicable number of basis points)) ÷ 4

**Example**: A portfolio maintaining $1,000,000 as of the last market day of the prior quarter will be assessed $2,500 quarterly fee.
Formula: ($1,000,000 x 100 bps) = $10,000 ÷ 4 = $2,500

OPTION B: If Tiered Fee Structure (Individual vs Institutional)

**Portfolio Management Fees**

Our fee schedule is structured as follows:

| Client Type | Assets Under Management | Annualized Fee Rate |
|-------------|------------------------|-------------------|
| Individual/Family Clients | $0 - $∞ | 1.00% (100 basis points) |
| Institutional Clients | $0 - $∞ | 0.50% (50 basis points) |

**Client Type Definitions**:
- **Individual/Family Clients**: Personal investment accounts for individuals and families
- **Institutional Clients**: Corporate accounts, pension funds, endowments, foundations, and other institutional entities

**Fee Calculation**: [Same formula as above with appropriate rate applied based on client type]

1.1.5 5. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss

Proposed Update to Include Current Strategies:

**Investment Strategies**

We offer three primary investment strategies:

**Growth Strategy**
- **Objective**: Long-term capital appreciation through growth-oriented equity investments
- **Target Return**: 8-12% annually over full market cycles (not guaranteed)
- **Time Horizon**: 5+ years recommended
- **Holdings**: Concentrated portfolio of companies meeting our ethical screening criteria

**Income Strategy**
- **Objective**: Current income generation with capital preservation
- **Focus**: Dividend-paying stocks and income-producing securities
- **Screening**: All holdings subject to our comprehensive ethical exclusion process

**Diversification Strategy**
- **Objective**: Balanced market exposure through complementary holdings
- **Implementation**: May utilize external managers or index funds for broader exposure
- **Integration**: Designed to complement our concentrated ethical positions

**Ethical Screening Process**
Our proprietary investment process involves filtering from approximately 10,000 publicly traded companies down to fewer than 40 qualifying holdings based on our comprehensive exclusion criteria, including but not limited to:
- Animal agriculture and testing
- Weapons and defense contractors
- Fossil fuel extraction and related industries
- Tobacco, alcohol, and gambling
- Companies with significant labor or human rights violations

1.1.6 6. Item 11 - Code of Ethics Updates

Proposed Enhancement:

**Code of Ethics, Participation or Interest in Client Transactions and Personal Trading**

Our firm has adopted a Code of Ethics that sets forth high ethical standards of business conduct for our Associated Persons. The Code includes provisions relating to:

- Fiduciary duty to clients
- Personal securities trading policies and procedures
- Insider trading prohibition
- Conflicts of interest management
- Confidentiality requirements
- Regulatory compliance obligations

**Personal Trading Policy**
Our Associated Persons may invest in the same securities recommended to clients. However, we maintain policies to ensure that:
- Client interests are placed before personal interests
- Personal trades do not disadvantage client accounts
- All personal trades are pre-cleared and reported
- Associated Persons cannot trade ahead of client transactions

A copy of our Code of Ethics is available upon request.

1.1.7 7. Item 18 - Financial Information

Current Utah Registration Update:

**Financial Information**

As a Utah-registered investment adviser, we are not required to provide audited financial statements unless we maintain custody of client funds or securities, or require prepayment of fees in excess of $1,200 per client and six months in advance.

We do not maintain custody of client funds or securities, and we do not require substantial prepayment of advisory fees.

**Custody Arrangements**
All client assets are maintained with qualified custodians including:
- Altruist Financial LLC (Member FINRA/SIPC)
- Apex Clearing Corporation (Member FINRA/SIPC)
- Charles Schwab & Co., Inc. (Member FINRA/SIPC)

Client assets held at these qualified custodians are protected by SIPC insurance up to applicable limits.

1.3 QUESTIONS REQUIRING RESOLUTION

1.3.1 1. Fee Structure Confirmation

Current Practice: Do you charge different rates for institutional vs. individual clients?
If Yes: What defines “institutional client” vs. “individual client”?
Documentation: Are current client agreements consistent with chosen fee structure?

1.3.2 2. Entity Name and DBA Usage

Legal Structure: Confirm current legal entity name and DBA registration
State Filings: Are DBA filings current in Utah and any other operating states?
Consistency: Ensure all regulatory filings use consistent entity naming

1.3.3 3. Current Assets Under Management

As of Date: What is current AUM for discretionary and non-discretionary accounts?
Client Count: Current number of client households?
Growth Trajectory: Are you approaching $100M AUM threshold for SEC registration?

1.3.4 4. Service Provider Relationships

Current Custodians: Are Altruist, Apex, and Schwab still primary custodians?
New Relationships: Any new material service provider relationships to disclose?
Conflicts: Any new potential conflicts of interest to address?

Next Steps: 1. Resolve outstanding questions above 2. Complete data updates with current figures 3. Legal review of DBA requirements (see separate research handoff) 4. File amendment with Utah Division of Securities 5. Update all related compliance documentation