Trinary Capital, LLC
Public-record listing · Anaheim, CA · https://www.trinarycapital.com
What they do
Founded in 2020; says it has raised nine tax-equity funds for accredited investors that own solar and battery-storage projects it develops, builds and operates. Marketing cites a 30%+ federal investment tax credit, about 75%-98% of invested capital recouped in year 1 through credit and bonus depreciation, and a 40% target IRR in years 2-7. EDGAR shows Form D filings for Trinary Solar Group funds (Nov. 2021 - Aug. 2025). SEC IAPD lists a 'Trinary Capital, LLC' adviser registration that was terminated 2026-02-25 (no disclosures); the link to this firm is likely but not confirmed.
Public-record summary. Category: Solar and storage tax-equity funds (S08). Fees: Not published.
Strategies offered
- Solar Investment Credits Public record source
- Accelerated Depreciation Public record source
Evidence score
44 points are pending because the item could not be checked from public records. If every pending item were verified, the score could reach up to 94 (limited by caps or by items that don't apply). How this is calculated.
| Category | Points | |
|---|---|---|
| Regulatory record (weight 25) | 15 / 25 | |
| Tax-controversy record (weight 20) | 20 / 20 | |
| Litigation & complaints (weight 15) | 9 / 15 | |
| Transparency (weight 15) | 2 / 15 | |
| Substance & verifiability (weight 15) | 1 / 15 | |
| Structure quality (weight 10) | 1 / 8 |
Red flags
No red flags (RF1-RF13) were triggered by the public evidence reviewed.
Evidence by item
Each line shows the points awarded, how it was checked and a source link where one exists.
Regulatory record · 15 / 25
| Item | Points | Status | Evidence |
|---|---|---|---|
| R1 Registration status verified for firm and soliciting individuals where required (BD/IA/state; insurance producer if relevant) | 3 / 5 | PARTIAL | SEC IAPD lists Trinary Capital, LLC (CRD 310183): registration terminated 2026-02-25, no disclosures. No BrokerCheck broker-dealer record. Funds are sold under Reg D (Form D filed); who solicits investors and whether they are registered is not public. source |
| R2 No SEC/FINRA disciplinary events for the firm (10-yr lookback) | 8 / 8 | VERIFIED (nothing found) | No SEC/FINRA disciplinary events for Trinary Capital, LLC on IAPD; no federal case captioned against the firm (CourtListener RECAP 0). source |
| R3 No disciplinary events for principals/control persons (10-yr lookback) | 0 / 6 | UNVERIFIED | Individual-level checks for principals were not performed in this review (principals are not listed on this page). |
| R4 No state securities-regulator or state AG actions against firm/principals | 4 / 4 | VERIFIED (nothing found) | No state securities-regulator or AG action found by web search. Not exhaustive. |
| R5 Named licensed professionals (CPA/attorney/EA) in good standing | 0 / 2 | UNVERIFIED | Licensed-professional good standing needs state CPA board / bar lookups for named individuals; not performed in this pilot. |
Tax-controversy record · 20 / 20
| Item | Points | Status | Evidence |
|---|---|---|---|
| T1 Strategy is not a listed transaction / transaction of interest and not a current Dirty Dozen theme | 8 / 8 | VERIFIED | Solar ITC (Sec. 48E) is not a listed transaction/TOI and not a 2026 Dirty Dozen theme. source |
| T2 No DOJ Tax Division injunctions / IRC ยงยง6700, 6701 promoter cases against firm or principals | 6 / 6 | VERIFIED (nothing found) | No DOJ injunction or promoter case found (CourtListener RECAP). source |
| T3 No adverse Tax Court / appellate opinions involving the sponsor's prior deals | 4 / 4 | VERIFIED (nothing found) | No Tax Court or appellate opinions naming the firm (CourtListener opinions). source |
| T4 Provides clear reportable-transaction disclosure guidance (Form 8886/8918) where applicable | 2 / 2 | VERIFIED | Strategy is not a listed transaction/TOI, so Form 8886/8918 guidance is N/A-justified (rubric: 2 = clear or N/A-justified). source |
Litigation & complaints · 9 / 15
| Item | Points | Status | Evidence |
|---|---|---|---|
| L1 No material civil fraud/misrepresentation litigation (firm, principals, affiliates) | 6 / 6 | VERIFIED (nothing found) | No federal civil case captioned against the firm found (CourtListener RECAP 0). State courts not searched. source |
| L2 Complaint pattern reasonable (BBB, state AG, CFPB where relevant) | 0 / 4 | UNVERIFIED | Complaint history (BBB / state AG) not checked. |
| L3 No bankruptcy/insolvency pattern among principals or affiliates | 3 / 3 | VERIFIED (nothing found) | No bankruptcy case captioned against the firm found (CourtListener). source |
| L4 Entities in good standing with Secretary of State; legal entity names match marketing | 0 / 2 | UNVERIFIED | Secretary of State good-standing not checked: state portals checked use CAPTCHA (e.g., SC businessfilings.sc.gov); not bypassed. Needs a manual lookup or paid registry pull. |
Transparency · 2 / 15
| Item | Points | Status | Evidence |
|---|---|---|---|
| X1 Fees and total costs published or provided in writing before commitment | 0 / 4 | UNVERIFIED | Fees are not published on the pages reviewed. |
| X2 Offering documents available before commitment; Form D on EDGAR where applicable | 2 / 4 | PARTIAL | EDGAR lists Form D filings for Trinary Solar Group LLC and Groups II-V and VIII (2021-11-30 through 2025-08-26). The offering documents themselves are not public (investor portal), so document availability before commitment is unconfirmed. source |
| X3 Names tax counsel / opinion issuer and allows direct verification | 0 / 4 | UNVERIFIED | Site says funds provide 'qualified tax opinions from independent counsel' but does not name the issuer. source |
| X4 Discloses audit/examination and claim history of prior deals | 0 / 3 | UNVERIFIED | Audit/examination and claim history of prior deals is not in public records; would need firm disclosure. |
Substance & verifiability · 1 / 15
| Item | Points | Status | Evidence |
|---|---|---|---|
| V1 Underlying assets independently verifiable (e.g., interconnection agreements, utility records, deeds, dated site evidence) | 0 / 6 | UNVERIFIED | Site describes a live investor portal showing project status, energy produced and billings, but project locations, interconnection and utility records are not public. source |
| V2 Placed-in-service / completion evidence for prior projects | 0 / 4 | UNVERIFIED | No public completion / placed-in-service evidence. |
| V3 Appraisals by independent credentialed appraisers (not promoter-selected) | 0 / 3 | UNVERIFIED | Appraisals / valuations not public. |
| V4 Pre-tax economic substance: investment case exists apart from tax benefits | 1 / 2 | PARTIAL | Contracted PPA cash yield over a 7-year hold is described; no PPA, offtaker or pro forma is public, and the headline 40% target IRR depends heavily on tax benefits. source |
Structure quality · 1 / 8
| Item | Points | Status | Evidence |
|---|---|---|---|
| Q1 Independent legal opinion (not solely promoter-paid boilerplate) | 0 / 4 | UNVERIFIED | Legal opinion not seen; independence unknown. |
| Q2 Tax insurance verified directly with named carrier/broker (policy exists, scope understood) | n/a | Not applicable | No tax insurance is claimed in the materials reviewed. |
| Q3 Fees reasonable relative to comparable offerings | 0 / 2 | UNVERIFIED | Needs a written fee comparison set of >=3 comparable offerings; not built in this pilot. |
| Q4 No guaranteed outcomes, benefit multiples or 'audit-proof' claims | 1 / 2 | PARTIAL | Marketing states target returns and capital recoupment ranges ('~75%-98% of invested capital recouped in Year 1', '40% Target IRR') without guarantee language, but these are benefit-multiple style claims that depend on investor tax position and on meeting passive-activity rules. source |
Questions to ask this firm
- Which entity sponsors each fund, who solicits investors, and are they registered or exempt?
- Who is the independent counsel issuing the tax opinion, and does it cover Sec. 469 passive-activity treatment?
- What are the fund-level fees and the investor's recapture exposure if the project is sold or fails?
- Provide placed-in-service evidence and offtaker details for prior funds.
Complaints
0 complaints under review · 0 substantiated · 0 with a response from the firm.
Complaints are an allegation until a reviewer decides. We show only the category and status, never the complainant’s identity, the description or any documents. Private complaints are counted but not itemized. The firm can respond by claiming this listing.
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