North Capital

Business, clients and compensation, as filed

Advisory activities

financial planning, portfolio management for individuals and small businesses, portfolio management for investment companies, portfolio management for businesses and institutional clients and other advisory activities

Compensated by

a percentage of assets under management, hourly charges and fixed fees

Client types

individuals (other than high net worth) (119); high net worth individuals (51); banking or thrift institutions (1); investment companies (1); business development companies (0); pooled investment vehicles (0); pension and profit sharing plans (3); charitable organizations (3); state or municipal government entities (0); other investment advisers (0); insurance companies (0); sovereign wealth funds and foreign official institutions (0); corporations or other businesses (4); other (0)

Also engaged as

commodity pool operator or commodity trading advisor

Related persons include

a broker-dealer and an insurance company or agency

Affiliates

2 broker-dealers

Form ADV Item 11 disclosures

No yes answers on Item 11 as of the latest Form ADV (May 5, 2026). Item 11 covers the firm and its advisory affiliates.

Brochure Item 9, as stated by the firm: The brochure states: 'North Capital has no Firm disclosures applicable to this provision, but certain investment adviser representatives have reportable financial disclosures.'

Registered funds this firm advises, from Form N-CEN

1 fundregistered under the Investment Company Act name this firm as investment adviser on the latest Form N-CEN. Net assets and the share of holdings at Level 3 or carried at NAV ("marks") are from the newest Form N-PORT; the flow series is on each fund's page in Terminal Pro. Fee and expense ratios are as the fund reported them on N-CEN.

Fees and minimums, as stated in the firm's brochure

Advisory fees are established in a written agreement with each client and are negotiable based on scope, complexity, duration of relationship, and market rates; the Firm may waive fees at its discretion. Investment advisory fees are generally payable quarterly in arrears based on the average value of the account, while hourly consulting fees are invoiced upon completion of services and due upon receipt.

• Salt Lake Asset-based Advisory Fee: .95% per annum of the first $250 thousand
• Salt Lake Asset-based Advisory Fee: .75% per annum for $250k - $1 million
• Salt Lake Asset-based Advisory Fee: .50% per annum for $1 - $5 million
• Salt Lake Asset-based Advisory Fee: .25% per annum for assets over $5 million
• Sea Island Asset-based Advisory Fee: 1.25% per annum for all assets
• Non-Discretionary Reporting Fee: .15% per annum
• Hourly Consulting Fees: $750 / hour – Senior Advisor
• Hourly Consulting Fees: $250 / hour – Junior Advisor

Performance fees: The Firm does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the client's assets).

Minimums: The Firm does not require any minimum account balance to begin a relationship. The independent custodian may impose minimums for certain types of accounts, and certain investment products (such as mutual funds) may have their own minimum balance requirements. Compass Family Offices is focused on individuals and families with at least $25 million of investment assets.

Ownership, affiliations and conflicts the firm discloses

Ownership: The Firm is a wholly-owned subsidiary of North Capital Investment Technology, Inc., whose beneficial owners with an interest greater than 25% are James P. Dowd and Franklin Resources, Inc.

Named in the brochure: James P. Dowd, Principal executive officer of North Capital, Inc. and North Capital Private Securities Corporation; CFA charter holder; Paul Bowers, Senior investment advisor representative; manages Compass Family Offices

Affiliations: North Capital Private Securities Corporation (NCPS), a registered broker-dealer affiliate under common control, acting as an agency broker for private funds and other private debt/equity securities; Mobility Securities, LLC, a registered broker-dealer under common control with the Advisor; North Capital Investment Technology, Inc. (NCIT), the parent company of the Firm and owner of NCPS, which also provides technology and business process consulting services; AdvisorEngine Inc. (formerly Vanare Inc.), a financial technology company with a mutual intellectual property/software licensing arrangement with the Firm, which may also refer wholesale relationships; North Capital Funds Trust, through which the Firm manages the North Capital Government Money Market Fund (NCGXX)

Conflicts of interest the brochure identifies, as stated:

• The Firm has an incentive to recommend its proprietary North Capital Government Money Market Fund (NCGXX) because it could earn more in advisory fees from proprietary products, mitigated by fee offsets and a 5% allocation limit per product.
• Investment adviser representatives have an economic incentive to recommend rollovers of retirement plan assets to IRAs managed by the Firm because doing so can increase advisory fees.
• Financial planning clients who are also offered investment management services may receive recommendations (e.g., asset allocation changes) that the Firm can then implement for an additional fee.
• Because Mr. Dowd is principal of both the Firm and NCPS, the attention and service clients of each receive depends on how he allocates his time, creating a financial incentive to favor more profitable activities.
• Mr. Dowd has a financial incentive to direct prospective customers to NCPS (a broker-dealer) rather than the Firm because agency brokerage commissions may be more lucrative than advisory fees.
• Mr. Dowd's close identification with both the Firm (fiduciary advisor) and NCPS (non-fiduciary broker-dealer) could cause customers to mistakenly believe brokerage services are subject to a fiduciary standard.
• Employees may trade in the same securities recommended to or purchased for clients, creating a possibility that employees benefit from client market activity.
• Some clients are charged advisory fees based on aggregate assets including 'held away' retirement plan assets, which the brochure notes still requires adherence to the conduct standard even though the rollover economic incentive may not apply.

Relying advisers and state notice filings (IAPD)

Notice filings: California, Georgia, New York, Texas, Utah