BOULDER WEALTH ADVISORS, LLC

ITEM 1 – COVER PAGE FORM ADV PART 2A – FIRM BROCHURE FEBRUARY 1, 2025 MAIN OFFICE: 2595 CANYON BLVD, SUITE 220 BOULDER, CO 80302 303-444-1161 303-444-5291 (FAX) BOULDERWEALTHADVISORS.COM INFO@BOULDERWA.COM This brochure provides information about the qualifications and business practices of Boulder Wealth Advisors. If you have any questions about the contents of this brochure, please contact us at (303) 444-1161. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Boulder Wealth Advisors is a Registered Investment Advisor. Registration as an Investment Advisor with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about Boulder Wealth Advisors is available on the SEC’s website at www.advisorinfo.sec.gov. You can search this site by a unique identifying number, known as a IARD number. The IARD number for Boulder Wealth Advisors is 115069.  ITEM 2 – MATERIAL CHANGES SUMMARY OF MATERIAL CHANGES This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.advisorinfo.sec.gov. Boulder Wealth Advisors LLC., has had no material changes to its Firm Brochure since the Firm published its last annual Firm Brochure dated March 6, 2024. Whenever you would like to receive a copy of our Firm Brochure (Part 2A of Form ADV), please contact us by telephone at: (303) 444-1161or by email at: info@boulderwa.com. We encourage you to read this document in its entirety. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 2  ITEM 3 - TABLE OF CONTENTS ITEM 1 – COVER PAGE ............................................................................................................................. 1 ITEM 2 – MATERIAL CHANGES ................................................................................................................ 2 ITEM 4 – ADVISORY BUSINESS ................................................................................................................ 4 ITEM 5 - FEES AND COMPENSATION ....................................................................................................... 6 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................... 8 ITEM 7 - TYPES OF CLIENTS ..................................................................................................................... 8 ITEM 8 -INVESTMENT STRATEGIES AND RISK OF LOSS ............................................................................. 8 ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................. 12 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................. 12 ITEM 11 - CODE OF ETHICS .................................................................................................................... 12 ITEM 12 - BROKERAGE PRACTICES ......................................................................................................... 13 ITEM 13 - REVIEW OF ACCOUNTS .......................................................................................................... 17 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................. 17 ITEM 15 – CUSTODY .............................................................................................................................. 18 ITEM 16 – INVESTMENT DISCRETION .................................................................................................... 19 ITEM 17 – VOTING CLIENT SECURITIES .................................................................................................. 20 ITEM 18 – FINANCIAL INFORMATION .................................................................................................... 20 BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 3  ITEM 4 – ADVISORY BUSINESS This Disclosure document is being offered to you by Boulder Wealth Advisors (“Firm”). It discloses information about our services and how those services are made available to you (the “Client”). We are an investment management Firm located in Boulder, CO. Boulder Wealth Advisors provides personalized, confidential financial planning, and investment management to individuals, families, trusts, pension and profit-sharing plans, estates, charitable organizations, and corporations. Our Firm was founded in 1997 and registered as an investment advisor since 2001. The firm is owned by Gary Shirman and Michael Hake. We primarily invest in stocks, bonds, mutual funds, BDCs/REITs, ETFs, and ESG/Social securities. A portion of the account may be held in cash, cash equivalents, or money market funds as part of the overall investment strategy. Cash balances may have a higher concentration and represent a significant portion of your overall portfolio depending on the current investment outlook or strategy. Our Firm generally requires a minimum account size of $500,000 for advisory accounts. However, from time to time, at our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets, related accounts, and other individual Client circumstances. We are committed to helping clients build, manage, and preserve their wealth, and to provide assistance to achieve their stated financial goals. We may offer an initial complimentary meeting upon our discretion. However, investment advisory services are initiated only after a Financial Planning Agreement or Investment Management Agreement has been signed. INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES Our Firm manages advisory accounts on a discretionary basis. Advice is provided through consultation with you, the client, and may include determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate plan reviews. We determine your investment objectives, time horizons, risk tolerance, and liquidity needs during our initial discussions. As appropriate, we also review your prior investment history, family composition, and background. Based on your needs, we develop a personal profile of investments to be included in your portfolio and we will provide ongoing portfolio review and management services. We tailor our advisory services to meet our clients' needs and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions to refrain from investing in limited amounts of securities. We will rebalance and/or make changes to the portfolio, as we deem appropriate, to meet your financial objectives. Once we have determined your profile and investment plan, we will execute the day-to-day transactions without seeking your prior consent. It is the client’s obligation to notify us immediately if circumstances have changed with respect to your goals and/or changes in your personal financial condition. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain capital market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. Clients may engage us to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, 529 Plans, and assets held in employer-sponsored retirement plans. In these situations, Boulder Wealth Advisors directs or recommends BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 4  allocating client assets among the various investment options available. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. FINANCIAL PLANNING Through the financial planning process, our team strives to engage our clients in conversations around the client’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each client in mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and client legacy objectives. Our team partners with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include: • Determination of appropriate income planning strategies for both pre- and post-retirement timeframes. • Review of existing and proposed investment asset mixes to help you meet your overall financial objectives. This would include a review of risk/return issues and a suggested plan of action consistent with your risk tolerance and overall financial objectives. • Calculation of your pre-retirement savings and investing needs. • Assessment of your overall financial position including net worth, cash flow, and debt. • Analysis of IRA-related issues including rollover, distribution, and inheritance planning options. • Estimates of your federal estate taxes and a suggested plan of action to help meet estate planning objectives. • Review and determination of your life and disability insurance needs. • Suggestions for minimizing your federal and state income tax obligations. • Development of investment strategies consistent with your business ownership succession and transition planning, if applicable. Our financial planning services provide you with a personalized financial model to help you make financial decisions. We have designed a unique financial planning software program to create personalized retirement plans. This service helps you make important financial decisions throughout your lifetime. WRAP FEE PROGRAM We do not place clients in a wrap fee program. ASSETS As of December 31, 2024, Boulder Wealth Advisors managed $291,048,832 in Assets under Management. We do not manage assets on a non-discretionary basis. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 5  ITEM 5 - FEES AND COMPENSATION INVESTMENT MANAGEMENT FEES AND COMPENSATION Our Firm charges a fee as compensation for providing Investment Management services on your account(s). These services include advisory services, trade entry, investment supervision, and other account maintenance activities. Our recommended Custodian charges transaction costs, custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for details. A calendar quarterly investment management fee is billed in advance based on the market value of the accounts on the last day of the previous calendar quarter. The investment management fee will cover the period from the first day of the calendar quarter through the last day of the calendar quarter. Our maximum annual advisory fee is 1.50%. The relevant fee and billing method is defined and agreed to by the firm and the client in the executed Investment Advisory Agreement. This fee will be debited directly from your investment account. Fees are assessed on all assets under management, including securities, cash, and money market balances. All of which are considered asset allocation categories for the client’s investment strategy. We may exclude some assets from billing that are agreed upon by Boulder Wealth Advisors and the client. The management fee is based on the size of the account at inception and is reviewed quarterly and reset if the accounts qualify for a lower or higher fee. In addition, some mutual fund assets transferred into the account may have been subject to deferred sales charges and 12(b)(1) fees and other mutual fund annual expenses as described in the fund’s prospectus. Furthermore, some existing variable annuities may be subject to trailing service fees, deferred sales charges, and mortality and expense fees. 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. 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 our Firm and you as the client. In certain circumstances, our fees and the timing of the fee payments may be negotiated. Our employees and their family related accounts are charged a reduced fee for our services. Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of determining the account size and annualized fee. The common practice is often referred to as “house- holding” portfolios for fee purposes and may result in lower fees than if fees were calculated on portfolios separately. Our method of house-holding accounts for fee purposes looks at the overall family dynamic and relationship. When applicable, and noted in Appendix of the Investment Management Agreement, legacy positions will also be excluded from the fee calculation. The independent and qualified custodian holding your funds and securities will debit your account directly for the advisory fee and pay that fee to us. When establishing a relationship with Boulder Wealth Advisors, you 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 to you on a monthly basis indicating all the amounts deducted from the account including our advisory fees. Either Boulder Wealth Advisors or you may terminate the management agreement, upon written notice to the other party. The management fee will be pro-rated to the date of termination, for the quarter in which the cancellation notice was given, and any unearned fees will be refunded to you. Upon termination, you BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 6  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. In the event of client’s death or disability, Boulder Wealth Advisors will continue management of the account until we are notified of client’s death or disability and given alternative instructions by an authorized party. In no case are our fees based on, or related to, the performance of your funds or investments. FINANCIAL PLANNING FEES Your fee for the designated financial advisory services will be determined in one of the following ways: Fixed Fee: Under a fixed fee arrangement, any fee will be agreed upon by you and Boulder Wealth Advisors in advance of services being performed and signing the Financial Planning Agreement. The fee will be determined based on factors including the complexity of your financial situation, agreed upon deliverables, and whether or not you intend to implement any recommendations through Boulder Wealth Advisors. When Boulder Wealth Advisors is chosen to implement your plan, we may at our discretion waive or reduce a portion of our financial planning fees. Half of the fee is payable upon signing the agreement, and the balance is payable after presentation of the plan. If you are an annual financial planning client, you may pay fees on a quarterly basis. Fixed fees range between $1,500 and $7,000. You may cancel the agreement prior to delivery and receive a full refund. If you decide to terminate your agreement before the agreed- upon service is provided, a full refund will also be provided. Hourly Rate: Under an hourly rate agreement, we will provide consulting, analysis, and any deliverables agreed upon and our fees will be based on the amount of time we spend providing such services and deliverables. This includes time spent meeting with you, time we spend researching and analyzing the agreed upon issues, as well as time we spend documenting or communicating with you about those issues. Our hourly rate is $350/hr. You may cancel the agreement at any time and receive a full refund less the hourly charges already incurred. Typically, we complete a plan within a month and will present it to you within 60 days of the contract date, if you have provided us all information needed to prepare the financial plan. One hundred (100%) of the Financial Planning Fee is collected upon delivery of the Plan to you. You may terminate the financial planning agreement by providing us with written notice. There is no penalty for termination of your financial planning agreement prior to the plan being delivered to you. We will not require prepayment of more than $1,200 in fees per client, six (6) or more months in advance of providing any services. When investment management or plan implementation and financial planning services are offered, there is a potential conflict of interest since there is an incentive for the party offering financial planning services to recommend products or services for which Boulder Wealth Advisors, or a related party, may receive compensation. However, as a financial planning client, you are under no obligation to act upon any of our recommendations or effect the transaction(s) through us if you decide to follow the recommendations. ADDITIONAL FEES AND EXPENSES In addition to the advisory fees paid to our Firm, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks, and other financial institutions (collectively “Financial Institutions”). These additional charges will include securities transaction fees, custodial fees, fees charged by the Independent Managers, charges imposed directly by a mutual fund company or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 7  electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Our Firm’s brokerage practices are described at length in Item 12, below. Further, our Firm does not share in any of these additional fees and expenses outlined above. We may include mutual funds and exchange-traded funds (“ETFs”), Closed End Funds, Interval Funds, or alternative investments in our investment strategies. Generally, our policy is to purchase institutional share classes, or the share class that is in the best interest of our client(s). The expense ratio is the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for funds expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and all other asset-based costs incurred by the fund. Some fund families offer different classes of the same fund, and one share class may have a lower expense ratio than another share class. Fund fees and expenses could impact the client’s account performance. Fund expenses are in addition to the Boulder Wealth Advisors fee, and we do not receive any portion of these charges. Clients who transfer mutual funds into their accounts with Boulder Wealth Advisors would bear the expense of any contingent or deferred sales loads incurred upon selling the product. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits, or tax harvesting). All mutual fund expenses and fees are disclosed in the respective mutual fund prospectus. The mutual fund and exchange-traded fund companies that choose to participate in your custodian's no transaction fee (“NTF”) fund program pay a fee to be included in the NTF program. The fees paid by these companies to participate in the program are ultimately borne by the mutual fund or exchange-traded fund owners, including clients of our Firm. When we decide whether to choose a fund from your custodian's NTF list or not, we consider our expected holding period of the fund, the position size, and the fund's expense ratio versus alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best interest. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client account (so-called performance-based fees), nor engage side by side management. ITEM 7 - TYPES OF CLIENTS Boulder Wealth Advisors offers personalized, confidential financial planning and investment management to individuals, families, pension and profit-sharing plans, trusts, estates, and charitable organizations. Our Firm maintains a $500,000 minimum in aggregate investable assets to engage our advisory services. In certain instances, at the discretion of our Firm, our minimum requirements may be waived. ITEM 8 -INVESTMENT STRATEGIES AND RISK OF LOSS The basic tenets under which this Policy will be managed include the following: INVESTMENT STRATEGIES & METHODS OF ANALYSIS We invest our client accounts in one of our five basic portfolio models: Ultra Aggressive, Aggressive, Growth, Growth & Income, and Bond only. Clients may have different models for different accounts. With some exceptions, our client assets are invested into one of these portfolio models. All of our portfolios consist of a diversified mix of stock and bond funds. The stock portion may include asset classes such as: large and small capitalization companies, value, and growth-oriented companies, developed and emerging market companies, and other market sectors. In addition, the bond portion of our portfolios may contain a variety BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 8  of bonds such as: U.S. government, municipals, corporate, foreign corporate, emerging markets, sovereign, and high yield bonds. We design diversified portfolios to minimize downside losses. Our model portfolios may vary in stock and bond mix, depending on market conditions. The Ultra-Aggressive Portfolio will con- tain the highest amount of stocks and the Growth and Income Portfolio will contain the least amount of stocks. Our determination of allocation is primarily tactical in nature. On occasion, we will employ charting tech- niques. We rely on many sources of information, including financial newsletters and magazines, subscrip- tion services, research material prepared by others, annual reports and prospectuses, and company re- leases. Our allocation analysis could be described as top-down. This analysis begins with looking at eco- nomic indicators, both national and international, such as; GDP growth rates, inflation, interest rates, ex- change rates, productivity, and energy prices. We then narrow our focus to market sectors or industries that we believe will perform well in the given economic environment. We then employ proprietary metrics to select mutual funds that we determine should outperform their benchmarks. This process includes ex- amining the funds price to earnings ratios, price to book, turnover rates, management tenure, bond dura- tion, and other metrics. We purchase securities with the intent to hold them for the long term. Occasionally, we purchase securities for a shorter time period, depending on market conditions. We exercise the right to buy and sell options, perform margin transactions, and do frequent trading; however, we have rarely performed any of these transactions since we have been in business. Client’s assets are held at Charles Schwab & Co. They have trading minimums that require us to treat ac- counts valued at less than $10,000 differently than larger account sizes. These smaller accounts will be allocated to our model portfolio percentages in stock and bond funds and may contain different mutual funds than larger accounts, due to certain fund’s minimum initial purchase constraints. We assess our clients’ risk-return level to determine which portfolio model best fits their objectives. We do not build tailored models for individual clients. However, if they have an existing position that they transfer in or if the client requests to buy a specific security, we will hold that in addition to our model portfolio holdings. These exceptions are documented in our Investment Policy Statement. Special situa- tions may require that the client hold additional cash in their account. A description of our four portfolio models are as follows: • ULTRA AGGRESSIVE – Typically 97% or more in equities, primarily investing in mutual funds, Ex- change Traded Funds (ETFS). Individual stocks may be used as well. The portfolio has a range of 70% to 100% of the portfolio invested in equities. The range of equity exposure depends on market conditions. The primary objective of this portfolio is to maximize growth and capital appreciation, with no emphasis on income generation. Designed for investors with a high-risk tolerance and a long-term investment horizon, this portfolio carries the highest level of risk and includes significant allocations to volatile asset classes such as stocks. To mitigate risk, Boulder Wealth Advisors may incorporate bonds, cash, alternative investments, trend-following strategies, or real asset strate- gies, utilizing ETFs and mutual funds. • AGGRESSIVE – Typically 80% stock funds, primarily investing in mutual funds and Exchange Traded Funds (ETFs), with a range of 45% to 90% invested in stocks depending on market conditions. The goal of this portfolio is to maximize growth and capital appreciation. There is no focus on generat- ing income. This portfolio has the highest risk level and is for investors with a long-time horizon. This portfolio has a large allocation to volatile asset classes, such as stocks, and has some defensive asset classes such as bonds and cash. • GROWTH – Typically 65% stock funds, primarily investing in mutual funds and Exchange Traded Funds (ETFs) with a range of 35% to 80% invested in stocks depending on market conditions. The goal of this portfolio is to maximize long-term growth and capital appreciation, with less volatility than the Aggressive Growth portfolio. This portfolio has a sizable stock allocation as it is designed BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 9  for moderate growth. The bond allocation may include, government, corporate, mortgage, emerg- ing market, high yield, and structured credit bonds which can be more volatile but provide diver- sification and upside potential. • GROWTH & INCOME – Typically 50% stock funds, primarily investing in mutual funds and Exchange Traded Funds (ETFs), with a range of 25% to 65% invested in stocks depending on market condi- tions. The goal of this portfolio is modest capital growth with some focus on generating current income. This portfolio maintains a moderate level of stock exposure, with a higher level of bond exposure than the Growth portfolio. The bond allocation may include, government, corporate, mortgage, emerging market, high yield, and structured credit bonds which can be more volatile but provide diversification and upside potential. § USE OF ALTERNATIVE INVESTMENTS - If deemed appropriate for your portfolio, our Firm may recommend investments classified as "alternative investments”. Alternative investments may include a broad range of underlying assets including, but not limited to, hedge funds, private equity, venture capital, and registered, publicly traded securities. Alternative investments are speculative, not suitable for all clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with a single adviser; absence of information regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees than other investment options such as mutual funds. The SEC requires investors be accredited to invest in these more speculative alternative investments. Investing in a fund that concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility. Portfolio strategies and concentration limits may deviate from the portfolio descriptions above depending on market conditions. RISK OF LOSS Clients must understand that past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different types of investments, there will be varying degrees of risk. Clients and prospective clients should be pre- pared to bear investment loss, including loss of original principal. Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully iden- tify market tops or bottoms, or insulate you from losses due to market corrections or general declines. Investors should be aware that accounts are subject to the following risks: • • MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money, and your investment may be worth more or less upon liquidation. FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging- market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 10  • • CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services. Their stocks have historically been more volatile than the stocks of larger, more established companies. INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally declines, and the value of equity securities may be adversely affected. • • CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and thus, impact the fund’s performance. EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets, and disruption in the creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset value.” • PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the asset allocation portfolios. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. • ALTERNATIVE STRATEGY MUTUAL FUNDS OR ETFS – We may use certain ETFs and mutual funds in our models and accounts that invest primarily in alternative investments and/or strategies. Investing in these alternative investments and strategies may not be suitable for all our Clients. These include special risks, such as those associated with commodities, real estate, and leverage, selling securities short, use of derivatives, potential adverse market forces, regulatory changes, and potential ill-liquidity. There are special risks associated with ETFs that invest principally in real estate securities, such as sensitivity to changes in real estate values and/or changes in interest rates and price volatility due to the ETF’s concentration in the real estate market. • NON-LIQUID ALTERNATIVE INVESTMENTS - From time to time, our Firm will recommend to certain qualifying clients that a portion of such clients’ assets be invested in private funds, private fund-of-funds and/or other alternative investments (collectively, “Nonliquid Alternative Investments”). Nonliquid Alternative Investments are not suitable for all our Firm’s clients and are offered only to those qualifying clients for whom our Firm believes such an investment is suitable and in line with their overall investment strategy. Nonliquid Alternative Investments typically are available to only a limited number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), or “qualified client” under the Investment Advisers Act of 1940, or “qualified purchaser” under the Investment Company Act of 1940. Nonliquid Alternative Investments present special risks for our Firm’s clients, including without limitation, limited liquidity, higher fees and expenses, volatile performance, no assurance of investment returns, heightened risk of loss, limited transparency, additional reliance on underlying management of the investment, special tax considerations, subjective valuations, use of leverage and limited regulatory oversight. When a Nonliquid Alternative Investment invests part or all of its assets in real estate properties, there are additional risks that are unique to real estate investing, including but not limited to: limitations of the appraisal value; the borrower’s financial conditions (if the underlying property has been obtained by a loan), including the risk of foreclosures on the property; neighborhood values; the supply of and demand for properties of like kind; and certain city, state and/or federal regulations. Additionally, real estate investing is also subject to possible loss due to uninsured losses from natural and man-made disasters. The above list is not exhaustive of all risks related to an investment in Nonliquid Alternative Investments. A more comprehensive discussion of the risks BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 11  associated with a particular Nonliquid Investment is set forth in that fund’s offering documents, which will be provided to each client subscribing to a Nonliquid Alternative Investment, for review and consideration. It is important that each potential, qualified investor carefully read each offering or private placement memorandum prior to investing. • CYBERSECURITY RISK – In addition to the Material Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at Boulder Wealth Advisors or one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or another misuse of confidential information, and generally compromise our Firm’s ability to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk that cybersecurity breaches may not be detected. ITEM 9 – DISCIPLINARY INFORMATION We do not have any legal, financial, or other “disciplinary” item to report. Our Firm does not have any legal disciplinary events, criminal, or civil actions material to a client’s decision to choose to engage advisory services from our Firm. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Neither Boulder Wealth Advisors, nor any of its managers or employees, is a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. OTHER AFFILIATIONS Gary Shirman is currently licensed with Protective Life Insurance Company to sell various life insurance products, long term care insurance and annuities. As a result, Boulder Wealth Advisors or certain associated persons may receive compensation for these activities as insurance agents. A limited portion of the time we spend (generally less than 1%) is in connection with these activities and it represents less than 1% of our ongoing revenue. ITEM 11 - CODE OF ETHICS Our Firm and our associated persons are allowed to invest for their own accounts or to have a financial investment in the same securities or other investments that we recommend or acquire for your account and may engage in transactions that are the same as or different than transactions recommended to or made for your account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in your best interest and have established policies to mitigate conflicts of interest. We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, and the prohibition against the use of inside information. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 12  The Code of Ethics is designed to protect our clients, to detect and deter misconduct, educate personnel regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and must act with complete propriety at all times, protect the reputation of Boulder Wealth Advisors, safeguard against the violation of the securities laws, and establish procedures for personnel to follow so that we may determine whether their personnel are complying with the Firm’s ethical principles. We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities: • A director, officer, or employee of Boulder Wealth Advisors shall not buy or sell any securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No supervised employee of Boulder Wealth Advisors shall prefer his or her own interest to that of the advisory client. Trades for supervised employees are traded alongside client accounts. • We maintain a list of all securities holdings of anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed regularly, by an appropriate officer/individual of Boulder Wealth Advisors. • We emphasize the client's unrestricted right to decline the implementation of any advice rendered, except in situations where we are granted the discretionary authority of the client's account. • We require that all supervised employees act according to all applicable Federal and State regulations governing registered investment advisory practices. • Any supervised employee not in observance of the above may be subject to termination. You may request a complete copy of our Code by contacting us at the address, telephone, or email on the cover page of this Part 2; ATTN: Chief Compliance Officer. ITEM 12 - BROKERAGE PRACTICES We generally recommend that our Clients utilize Charles Schwab & Co., Inc. Advisor Services ("Schwab"), a registered broker-dealer, Member SIPC, as the qualified Custodian. Our Firm is independently owned and operated and unaffiliated with Schwab. Schwab will hold Client assets in a brokerage account and buy and sell securities when our Firm instructs them. While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to do so and open accounts with Schwab by entering into account agreements directly with them. The Client opens the accounts with Schwab. The accounts will always be held in the Client's name and never in our Firm’s. HOW OUR FIRM SELECTS CUSTODIAN-BROKER Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the transactions on terms that are, overall, most advantageous compared to other available providers and their services. Our Firm considers a wide range of factors, including, among others: • Combination of transaction execution and asset custody services (generally without a separate fee for custody). • Capability to execute, clear, and settle trades (buy and sell securities for Client accounts). • Capability to facilitate transfers and payments to and from accounts (wire transfers, check re- • quests, bill payments, etc.). The breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.). BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 13  • Availability of investment research and tools that assist us in making investment decisions. • Quality of services. • Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices. Prior service to our Firm and our other Clients. • Reputation, financial strength, and stability. • • Availability of other products and services that benefit our Firm, as discussed below (see “Products And Services Available To Us From Schwab”). CLIENT BROKERAGE & CUSTODY COSTS For Clients' accounts, Schwab maintains and generally does not charge separately for custody services. However, Schwab receives compensation by charging ticket charges or other fees on trades it executes or settling into Clients' Schwab accounts. In addition to commissions, Schwab charges a flat dollar amount as a "prime broker" or "trade away" fee for each trade that our Firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Client’s Schwab account. These fees are in addition to the ticket charges or compensation the Client pays the executing broker-dealer. Because of this, our Firm has Schwab execute most trades for Client accounts to minimize trading costs. Our Firm has determined that having Schwab execute most trades is consistent with our duty to seek the "best execution" of Client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see How Our Firm Selects Custodian-Broker). PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment advisory Firms and Clients with access to its institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts; others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis and at no charge to our Firm. These are typically considered soft dollar benefits because there is an incentive to do business with Schwab. Receiving soft dollar benefits creates a conflict of interest. We have established policies in this regard to mitigate any conflicts of interest. We believe our selection of Schwab as Custodian-Broker is in the Clients' best interests. Our Firm will always act in the best interest of our Clients and act as fiduciary in carrying out services to Clients. The following is a more detailed description of Schwab’s support services: SERVICES THAT BENEFIT OUR CLIENTS Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client assets. The investment products available through Schwab include some we might not otherwise have access to or would require a significantly higher minimum initial investment by our Clients. Schwab’s services described in this paragraph generally benefit our Clients and their accounts. SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS Schwab also makes other products and services available that benefit our Firm but may not directly benefit our Clients or their accounts. These products and services assist our Firm in managing and administering our Clients’ accounts. They include investment research, both Schwab’s own and BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 14  that of third parties. Our Firm may use this research to service all or a substantial number of our Client's accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to Client account data (such as duplicate trade confirmations and account statements). Facilitate trade execution and allocate aggregated trade orders for multiple Client accounts. Provide pricing and other market data. Facilitate payment of our fees from our Clients’ accounts. • • • • Assist with back-office functions, recordkeeping, and Client reporting. SERVICES THAT GENERALLY BENEFIT ONLY US Schwab also offers other services to help our Firm manage and further develop our business enterprise. These services include: Educational conferences and events Publications and conferences on practice management and business succession • • Consulting on technology, compliance, legal, and business needs • • Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to our Firm. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide our Firm with other benefits, such as occasional business entertainment for our personnel. OUR INTEREST IN SCHWAB’S SERVICES • • The availability of these services from Schwab benefits our Firm because we do not have to pro- duce or purchase them. These services are not contingent upon our Firm committing any specific amount of business to Schwab in trading commissions. We believe our selection of Schwab as Cus- todian and Broker is in our Client’s best interests. Some of the products, services, and other benefits provided by Schwab benefit our Firm and may not benefit our Client accounts. Our recommendation or requirement that you place assets in Schwab's custody may be based, in part, on the benefits Schwab provides to our Firm or our Agree- ment to maintain certain Assets Under Management at Schwab and not solely on the nature, cost, or quality of custody and execution services provided by Schwab. • Our Firm places trades for our Clients' accounts subject to its duty to seek the best execution and other fiduciary duties. Schwab's execution quality may be different from other broker-dealers. • Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transactions through a specified Custodian. Additionally, our Firm typically does not permit the Client to direct brokerage. We place trades for Client accounts subject to our duty to seek the best execution and other fiduciary duties. • We will aggregate trades for ourselves or our associated persons with your trades, providing that the following conditions are met: o Our policy for the aggregation of transactions shall be fully disclosed separately to our existing Clients (if any) and the broker/dealer(s) through which such transactions will be placed. o We will only aggregate transactions if we believe that aggregation is consistent with our duty to seek the best execution (which includes the duty to seek the best price) for the Client and is consistent with the terms of our investment advisory agreement. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 15  o No advisory Client will be favored over any other Client; each Client that participates in an aggregated order will participate at the average share price for all transactions in a given security on a given business day, with transaction costs based on each Client's par- ticipation in the transaction. o Our Firm will prepare a written statement (“Allocation Statement”) specifying the partic- o ipating Client accounts and how to allocate the order among those Clients. If the aggregated order is filled in its entirety, it will be allocated among Clients per the allocation statement; if the order is partially filled, the accounts that did not receive the previous trade's positions should be "first in line" to receive the next allocation. o Notwithstanding the preceding, the order may be allocated on a basis different from that specified if all Client accounts receive fair and equitable treatment. The reason for the difference in allocation will be documented and reviewed by our Firm’s Compliance Of- ficer. Our Firm’s books and records will separately reflect, for each Client account, the orders which are aggregated, and the securities held by and bought for that account. o Our Firm will not receive additional compensation or remuneration of any kind because of the proposed aggregation; and Individual advice and treatment will be accorded to each advisory Client. o BROKERAGE FOR CLIENT REFERRALS Our Firm does not receive Client referrals from any Custodian or third party in exchange for using that broker-dealer or third party. AGGREGATION & ALLOCATION OF TRANSACTIONS Our Firm may aggregate transactions if it believes that aggregation is consistent with the duty to seek the best execution for its Clients and is consistent with the disclosures made to Clients and terms defined in the Investment Advisory Agreement. No Client will be favored over any other Client. Each account in an aggregated order will participate at the average share price (per Custodian) for all transactions in that security on a given business day. If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis. If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we will base the allocation on other relevant factors, which may include: • When only a small percentage of the order is executed, with respect to purchase allocations, allo- cations may be given to accounts high in cash. • Concerning sale allocations, allocations may be given to accounts low in cash. • We may allocate shares to the account with the smallest order, to the smallest position, or to an account that is out of line concerning security or sector weightings relative to other portfolios with similar mandates. • • • We may allocate one account when that account has limitations in its investment guidelines pro- hibiting it from purchasing other securities that we expect to produce similar investment results, and other accounts can purchase that in the block. If an account reaches an investment guideline limit and cannot participate in an allocation, we may reallocate shares to other accounts. For example, this may be due to unforeseen changes in an account's assets after placing an order. If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or more account(s), we may exclude the account(s) from the allocation. • Our Firm will document the reasons for any deviation from a pro-rata allocation. TRADE ERRORS BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 16  Our Firm has implemented procedures designed to prevent trade errors; however, our Firm cannot always avoid Client trade errors. Consistent with our Firm's fiduciary duty, it is our Firm’s policy to correct trade errors in a manner that is in the Client's best interest. In cases where the Client causes the trade error, the Client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the Client may not be able to receive any gains generated due to the error correction. In all situations where the Client does not cause the trade error, the Client will be made whole, and we would absorb any loss resulting from the trade error if our Firm caused the error. If the Custodian causes the error, the Custodian will cover all trade error costs. If an investment error results in a gain when correcting the trade, the gain will be donated to charity. Our Firm will never benefit or profit from trade errors. DIRECTED BROKERAGE Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transaction through a specified broker-dealer. Additionally, our Firm typically does not permit the Client to direct brokerage. Our Firm places trades for Client accounts subject to its duty to seek the best execution and other fiduciary duties. ITEM 13 - REVIEW OF ACCOUNTS ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES We monitor your portfolio on a continuous and ongoing basis to review the previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial and/or investment objectives. More frequent reviews occur but are not necessarily communicated to you unless immediate changes are recommended. Such reviews are conducted by the Firm’s investment advisor representatives and are intended to fulfill the Firm’s fiduciary obligations to their advisory clients. We encourage all advisory clients to discuss their needs, goals, and objectives with us and keep the Firm informed of any changes thereto. STATEMENTS AND REPORTS You are provided with transaction confirmation notices and regular summary account statements directly from the Custodians where your assets are custodied. In addition, we mail quarterly reports to our investment clients. These reports are prepared by Advyzon which is a third party performance reporting service, and contain account and security performance results and a statement of the fees assessed. In addition, the mailing contains a newsletter authored by Boulder Wealth Advisors. You may also receive statements from their custodian, generally Charles Schwab, on a monthly basis. They may also receive information from mutual fund companies and other securities they own. You are encouraged to compare the account statements received from your custodian with any documents or reports you receive from our Firm or an outside service provider. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION As disclosed under Item 12 Brokerage Practices, we participate in the Custodian’s institutional customer programs, and we may recommend a Custodian to our Clients for custody and brokerage services. There is no direct link between our participation in the program and the investment advice we give to our Clients. However, we receive economic benefits through our participation in the program that is typically not BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 17  available to any other independent advisors participating in the program. These benefits include the following products and services (provided without cost or at a discount): • Receipt of duplicate Client statements and confirmations. • Research-related products and tools. • Consulting services. • Access to a trading desk serving adviser participants. • Access to block trading (which provides the ability to aggregate securities transactions for execu- tion and then allocate the appropriate shares to Client accounts); The ability to have advisory fees deducted directly from Client accounts. • • Access to an electronic communications network for Client order entry and account information. • Access to mutual funds with no transaction fees and certain institutional money Managers. • Discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third-party vendors. Custodians may also have paid for business consulting and professional services received by some of our IARs. Some of the products and services made available by Custodians through the program may benefit us but may not benefit your account. These products or services may assist us in managing and administering Client accounts, including accounts not maintained at our recommended Custodian. Other services made available by the Custodian are intended to help us manage and further develop our business enterprise. The benefits our Firm or our IARs receive through participation in the program do not depend on the amount of brokerage transactions directed to the Custodian. Due to these arrangements, our Client does not pay more for assets maintained at Schwab. As part of our fiduciary duties to Clients, we always endeavor to put our Client's interests first. Clients should be aware, however, that receiving economic benefits from our Firm or our IARs in and of itself creates a conflict of interest because the cost of these services would otherwise be borne directly by us. These arrangements could indirectly influence our choice of Custodian for custody and brokerage services. Clients should consider these conflicts of interest when selecting a Custodian. The products and services provided by the Custodian, how they benefit us, and the related conflicts of interest are described above. CLIENT REFERRALS Our Firm neither accepts nor pays fees for Client referrals. Further, we do not have any compensation arrangements other than what is disclosed in this Brochure. PROMOTERS We may enter into agreements with individuals who will promote our Firm (“Promoters”). If a Client is introduced to our Firm by a Promoter, we will pay that Promoter a referral fee per the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940 and any corresponding state securities law requirements. Any referral fee will be paid solely from advisory fees and will not incur additional charges to the Client. The Promoter, at the time of the referral, will disclose the nature of the Promoter relationship and provide each prospective client with a copy of the written disclosure statement from the Promoter to the Client disclosing the terms of the arrangement between our Firm and the Promoter, including the compensation to be received by the Promoter from our Firm. ITEM 15 – CUSTODY We do not have physical custody, as it applies to investment advisors. Custody has been defined by regulators as having access or control over client funds and/or securities. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 18  Boulder Wealth Advisors is deemed to have custody of clients’ funds due to the following arrangements: DEDUCTION OF ADVISORY FEES For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our Firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients, or an independent representative of the client, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address, and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. The client should carefully review those statements and are urged to compare the statements against reports received from Boulder Wealth Advisors. When the client has questions about their account statements or fee deductions, the client should contact Boulder Wealth Advisors or the qualified custodian preparing the statement. Please refer to Item 5 for more information about the deduction of advisor fees. STANDING LETTERS OF AUTHORIZATION (“SLOA”) Our Firm is deemed to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. We do not have a beneficial interest in any of the accounts we are deemed to have custody where SLOAs are on file. In addition, account statements reflecting all activity on the account(s) are delivered directly from the qualified custodian to each client or the client’s independent representative, at least quarterly. The client should carefully review those statements and are urged to compare the statements against reports received from us. When the client has questions about their account statements, the client should contact us, the client’s Advisor or the qualified custodian preparing the statement. ITEM 16 – INVESTMENT DISCRETION For discretionary accounts, prior to engaging Boulder Wealth Advisors to provide investment advisory services, you will enter into a written Agreement with us granting the Firm the authority to supervise and direct, on an ongoing basis, investments in accordance with the client’s investment objective and guidelines. In addition, you will need to execute additional documents required by the custodian to authorize and enable Boulder Wealth Advisors, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange securities in and for your accounts. We are authorized, in our discretion and without prior consultation with you to: (1) buy, sell, exchange, and trade any stocks, bonds, or other securities or assets (2) determine the amount of securities to be bought or sold, and (3) place orders with the custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you, the client. The limitations on investment and brokerage discretion held by Boulder Wealth Advisors for you are: • For discretionary accounts, we require that we be provided with the authority to determine which securities and the amounts of securities to be bought or sold. • Any limitations on this discretionary authority shall be indicated on the Investment Advisory Agreement, Appendix B. You may change/amend these limitations as required. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 19  ITEM 17 – VOTING CLIENT SECURITIES PROXY VOTING Boulder Wealth Advisors accepts authority to vote for clients regarding their securities. In order for us to vote for the client, they authorize us by signing an authorization form. Clients can request our voting record and they can rescind this authorization at any time. We give clients our proxy voting guidelines when they become clients. They can request a copy of our policies and procedures at any time. In general, Boulder Wealth Advisors votes with the recommendations of the board on issues such as governance structure, adoptions and amendments to compensation plans and audits. Upon receipt of a request for more information, we will provide you with a copy of the proxy policy and/or how we voted proxies for you pursuant to this policy. It is our policy not to disclose how we voted your proxy to third parties. CLASS ACTION SUITS A class action is a procedural device used in litigation to determine the rights of and remedies, if any, for large numbers of people whose cases involve common questions of law and/or fact. Class action suits frequently arise against companies that publicly issue securities, including securities recommended by investment advisors to clients. With respect to class action suits and claims, you (or your agent) will have the responsibility for class actions or bankruptcies involving securities purchased for or held in your account. We do not provide such services and are not obligated to forward copies of class action notices we may receive to you or your agents. ITEM 18 – FINANCIAL INFORMATION We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. Boulder Wealth Advisors does not have any financial impairment that will preclude the Firm from meeting the contractual commitment to our clients. BOULDER WEALTH ADVISORS FEBRUARY 2025 | PAGE 20