MATERIAL CHANGES
Since our last annual updating amendment, dated March 26, 2024, Sierra updated its Form ADV Part 2A Disclosure Brochure on October 1, 2024. Please see the material updates related to that change noted below.
In this March 31, 2025 Annual Amendment Update, Sierra is updating its Firm Brochure in relation to the following material items:
ITEM 5: Revised the Standard Advisory Fee Schedule to note the lower breakpoint of 1% on assets over $1 Million effective 4/1/2025.
ITEM 8: Added additional investment Programs that Sierra makes available, including applicable descriptions of each.
Added or updated additional risk disclosures, in particular: 1) Market and Geopolitical Risks, 2) Commodity-Linked Derivative Risks, 3) Emerging Markets Risk, 4) Equity Risks, 5) Fixed-Income Risk, 6) High Yield Risk, 7) Small and Mid-Capitalization Risk , 8) Treasury Securities Risk, 9) Tax Risk, and 10) Underlying Fund Risk.
October 1, 2024 Other Than Annual Amendment Updates – Summary of Material Changes:
On October 1, 2024, Sierra Investment Management, LLC succeeded to the business of a registered investment adviser as a result of a change of Sierra’s legal structure and form of organization. Prior to October 1, 2024, Sierra operated under the incorporated entity Sierra Investment Management, Inc.
Moreover, on October 1, 2024, Sierra’s affiliates Ocean Park Asset Management, LLC and Ocean Park Asset Management, Inc., consolidated their operations and advisory services under the single registered entity of Ocean Park Asset Management, LLC. In coordination with this change, Ocean Park Asset Management, LLC also rebranded its affiliated Sierra Mutual Funds under the Ocean Park Mutual Funds brand.
As a result of this change, the following material changes were made to this Brochure effective October 1, 2024:
Item 4: Revised the language discussing the organizational structure of Sierra, its affiliates, and its principal owners. Incorporated a discussion regarding the rebranding of the Sierra Mutual Funds to the Ocean Park Mutual Funds. Revised, in accordance with these organizational and brand changes, the language used in describing Sierra’s conflicts of interest.
