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.
In Sierra’s March 26, 2024 Annual Amendment, almost every component of this Sierra Firm Brochure was modified, in large part to refresh the layout, language used, and approach to discussing each item. Sierra recommended that this Firm Brochure be read in its entirety as a result.
While Sierra considers the majority of the changes made in March to not be substantive or material alterations of prior disclosures related to each Item referenced in the Table of Contents, Sierra highlighted below a summary of those specific changes we considered to be material since the last prior annual update of this Brochure.
The following material changes were made to this Brochure effective March 26, 2024:
Item 4: Added details and disclosures related to Sierra’s advisory services provided to Private
Placement Variable Annuity separate accounts.
Item 5: Provided additional disclosure related to our Advisory Fees across our advisory services offerings, including updated descriptions of additional fees and expenses as applicable.
Item 7: Updated information related to our clients and minimum household and account sizes, as well as other requirements for advisory services.
Item 8: Updated descriptions related to our methods of analysis, investment strategies, and associated risks.
Item 13: Updated description on our methods related to the review of accounts.
Item 14: Updated disclosures related to Sierra’s Promoter and Operator relationships.
