Desert Rose Capital Management, Inc.

• A percentage of assets under your management

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

The brochure lists different fees for different services or strategies. See the firm's brochure (dated March 20, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$192,134,096 as of October 2026, filing dated March 20, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for individuals and/or small businesses
• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients
• Selection of other advisers (including private fund managers)
• Educational seminars/workshops

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2022 (4 years)

Employees

Total: 22. Performing investment advisory functions: 10.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

Charles Schwab & Co., Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

Other offices (Schedule D, Section 1.F)

3 other offices, as of the April 2026 filing

Reno, NVSylvania, OHValley Springs, CA

States registered or notice-filed

39 states or jurisdictions

ALARAZCACODCDEFLGAIDILKSKYLAMDMIMNMOMTNCNENHNJNMNVNYOHOKORPASCSDTNTXUTVAWAWIWY

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

1 Reports 1 disclosure item on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.G Is the firm or an advisory affiliate now the subject of a regulatory proceeding that could result in a yes answer to any part of 11.C, 11.D, or 11.E?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $151,722,562 in the October 2022 data and $192,134,096 in the October 2026 data, up 27%.

Total employees: 7 in October 2022 and 22 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. March 2026
   • Employees performing advisory functions went from 11 to 10.
   • Regulatory assets under management went from $112,679,913 to $192,134,096 (+71%).
   • No longer lists an office in Stockton, CA.
   • Registered or notice-filed in AL, DC, DE, IL, KS, MD, MI, MO, MT, NH, NJ, NY, OK, SD, WI.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.