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| Trilogy Capital Inc
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| CRD # | 281597 |
| SEC # | 801-106922 |
| CIK # | 0001722512, 0001817259, 0001907929 |
| AUM | 3,210.0 M (2026-06-09) |
| Employees | 74 (100% Investors, 51% Brokers) |
| Fees | |
| Minimum | |
| Phone | 949-221-8105 |
| Address | 2601 Main Street Irvine, CA 92614 |
| Source | [IAPD] [EDGAR] [Website] [Twitter] [LinkedIn] [Facebook] |
| Total AUM ($B) |
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| Fees and Compensation — Form ADV Part 2A (7/23/2026) [Brochure] |
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ITEM 5 - FEES AND COMPENSATION Investment Management Fees and Compensation Trilogy charges a fee as compensation for providing Investment Management services on your account. These services include advisory and consulting services, sub-advisory, trade entry, investment supervision, and other account-maintenance activities. Our custodian may charge transaction costs, custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for additional details. In addition, some mutual fund assets deposited in your accounts may have been subject to other mutual fund annual management and administrative fees as described in the funds’ prospectuses. These fees are independent of our fees and should be disclosed by the custodian or contained in each fund’s prospectus. You should also note that fees for comparable services vary and lower fees for comparable services may be available from other sources. The Advisory Fees will be calculated and paid to our firm each calendar month in arrears based on the average daily value of the Portfolio during the previous calendar month (calculated based on the Portfolio’s value at the end of each day). Under the average daily balance method, each day’s balance for the month is summed then divided by the number of days in the month, to compute the average daily balance. The average daily balance is then multiplied by the monthly portion of the annual fee to determine the monthly fee due. Fees are assessed on all assets under management, including securities, cash, and money market balances. Margin balances are included as part of assets under management for purposes of calculating Trilogy Capital’s advisory fee. In the event of termination, any paid but unearned fees will be promptly refunded to the Client based on the number of days that the Portfolio was managed, and any fees due to Trilogy Capital will be deducted from the Client’s account prior to termination. For purposes of this fee calculation, “value of the Portfolio” means the sum of the fair market value of all of the holdings in the Portfolio. Equity securities listed or traded on a national securities exchange or quoted on the over-the-counter market are valued at the last sales price on the day of valuation or, if no sale price is reported, at the last bid price. Trilogy Capital’s maximum investment advisory fee is 2.00%. The specific advisory fees are set forth in your Investment Advisory Agreement. Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account or other reasons agreed upon by us and you as the client. In certain circumstances, our fees and the timing of the fee payments may be negotiated. At our discretion, we will aggregate asset amounts in accounts from your same household together to determine the advisory fee for all your accounts. We may do this, for example, where we also service accounts on behalf of your minor children, individual and joint accounts for a spouse, and/or other types of related accounts. This consolidation practice is designed to allow you the benefit of an increased asset total, which could potentially cause your account(s) to be assessed a lower advisory fee based on the asset levels available in our fee schedule. The Generational Wealth Program allows related client households to be linked solely for purposes of determining advisory fee breakpoints. Advisory services are provided at the individual household level. 14 | P a g e Trilogy Capital ADV Part 2A Brochure July 2026 Asset aggregation is used exclusively to determine the applicable fee tier and does not impact account ownership, management, or control. Participation is not automatic and must be requested by the client or advisor and approved the Firm’s Compliance Department. The independent qualified custodian holding your funds and securities will debit your account directly for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be paid directly from your account held by the qualified custodian. Further, the qualified custodian agrees to deliver an account statement at least quarterly directly to you indicating all the amounts deducted from the account including our advisory fees. See Item 15 for details. At our discretion, you may pay the advisory fees by check. You are encouraged to review your account statements for accuracy. There may be a possibility for price or account value discrepancies due to month-end transactions in an account. Dividends or trade date settlements may occur, and our third-party billing software may report a slight difference in account valuation at month end compared to what is reported on your Statement from the Custodian. Either Trilogy or you may terminate the management agreement immediately upon written notice to the other party. The management fee will be pro-rated to the date of termination, for the month in which the cancellation notice was given and any earned fees will be billed to your account. Upon termination, you are responsible for monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those assets. Fees for Sub-Advisory relationships As discussed in Item 4 above, there are occasions where Manager acts in a sub-advisor capacity to our Firm. Under this arrangement, the Manager invests the assets based upon the parameters provided by our Firm. Depending on the agreement with the Manager, the total advisory fee will be collected by the custodian and the portion of the advisory fee is sent to the Manager and our Firm. This total fee includes our Firm’s portion of the investment advisory fee as well as the Manager’s fee. The fee billed is defined in the relevant Discretionary Investment Management Agreement as well as in the individual Form ADV Filing of the respective Manager. ... |
| Account Minimums and Types of Clients — Form ADV Part 2A (7/23/2026) [Brochure] |
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ITEM 7 - TYPES OF CLIENTS We provide investment advice to individuals, high-net-worth individuals, families, small businesses, pensions, foundations, trusts and estates. Our minimum initial account value is $5,500; however, we may accept accounts for less than the minimum. Our Retirement Plan Services are available to clients that are sponsors or other fiduciaries to plans, including 401(k), 457(b), 403(b) and 401(a) plans. Plans include participant-directed defined contribution plans and defined benefit plans. Plans may or may not be subject to ERISA. |
| CIK | Period |
|---|---|
| 0001722512 0001817259 0001907929 |
| Sector | Form 13F Holdings | Value ($B) | |
|---|---|---|---|
| SPDR Gold Trust | 0.0 | ||
| Prev | Page 1 | Next | |||
| AUM Breakdown | Accounts | AUM ($B) |
|---|---|---|
| By Client Type | ||
| (a) Individuals (other than high net worth individuals) | 7,512 | 1.6 |
| (b) Individuals (high net worth individuals) | 546 | 1.0 |
| (c) Banking or thrift institutions | 0 | 0.0 |
| (d) Investment companies | 0 | 0.0 |
| (e) Business development companies | 0 | 0.0 |
| (f) Pooled investment vehicles | 0 | 0.0 |
| (g) Pension and profit sharing plans | 305 | 0.6 |
| (h) Charitable organizations | 3 | 0.0 |
| (i) State or municipal government entities | 0 | 0.0 |
| (j) Other investment advisers | 0 | 0.0 |
| (k) Insurance companies | 0 | 0.0 |
| (l) Sovereign wealth funds and foreign official institutions | 0 | 0.0 |
| (m) Corporations or other businesses not listed above | 22 | 0.0 |
| (n) Other | 0 | 0.0 |
| Total | 18,988 | 3.2 |
| By Discretionary | ||
| Discretionary | 18,837 | 2.9 |
| Non-Discretionary | 151 | 0.3 |
| Total | 18,988 | 3.2 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.0 | |
| United States Persons | 3.2 | |
| Total | 18,988 | 3.2 |
| EDGAR Form | CIK | 2011 - 2026 |
|---|---|---|
| 13F-HR | [0001722512] | |
| 4 | [0001817259] | |
| 3 | [0001907929] | |
| 4 | [0001907929] | |
| SC 13D | [0001907929] |
| Form 13D/13G Filer | Form 13D/13G Subject | Filed |
|---|---|---|
| Trilogy Capital Group LLC | Smart for Life Inc | [2022-03-21] |
| Firm Profile (Form ADV) | |
|---|---|
| Clients | 60 |
| Serves | Institutional, Retail |
| Form 3/4/5 Subject | 2011 - 2026 |
|---|---|
| Smart for Life Inc | |
| Trilogy Capital Group LLC | |
| Pham Judy | |
| Alchemy Capital LLC | |
| Mountain High Acquisitions Corp | |
| Trilogy Capital LLC |
| Insider Transaction (Form 3/4/5) | Date | Action | Shares | Price | Value ($) |
|---|---|---|---|---|---|
|
Smart for Life Inc SMFL
Common Stock
|
2022-12-16 | Sell | 1,161,000 | $0.26 | 301,860 |
|
Mountain High Acquisitions Corp MYHI
Common Stock
|
2020-05-13 | Other | 196,000,000 | ||
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Mountain High Acquisitions Corp MYHI
Common Stock
|
2020-04-23 | Buy | 11,750,000 | $0.01 | 117,500 |
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