WRAP FEE BROCHURE

Item 1: Cover Page Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure Association Financial Services, Inc. Wrap Program Sponsored by: Association Financial Services, Inc. 1935 Vine Street Suite 120 Salt Lake City, Utah 84121 www.truenorthwealth.com www.tnrs.com www.imafs.org August 22, 2026 Firm Contact: Jared Empey Chief Compliance Officer This wrap fee program brochure provides information about the qualifications and business practices of Association Financial Services, Inc. If clients have any questions about the contents of this brochure, please contact us at 801-274-1820. 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. Additional information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #2251777. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Association Financial Services, Inc. is required to make clients aware of information that has changed since the last annual update. Since our firm's last annual amendment was filed on March 6, 2026, we have amended this Disclosure Brochure to disclose the following material changes: On August 22, 2026, this Disclosure Brochure was updated to disclose that we may charge fees that exceed the disclosed tiered schedule, but under no circumstances will the fee exceed 1.00% of assets under management. Please refer to Item 4 (Services, Fees & Compensation section) of this Disclosure Brochure for more information. If you have any questions, please call our office and ask to speak with the Chief Compliance Officer. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 2 Association Financial Services, Inc.  Item 3: Table of Contents Item 1: Cover Page ................................................................................................................................................................ .. 1 Item 2: Material Changes...................................................................................................................................................... 2 Item 3: Table of Contents ..................................................................................................................................................... 3 Item 4: Services, Fees & Compensation.......................................................................................................................... 4 Item 5: Account Requirements & Types of Clients .................................................................................................... 6 Item 6: Portfolio Manager Selection & Evaluation..................................................................................................... 6 Item 7: Client Information Provided to Portfolio Manager(s) ............................................................................13 Item 8: Client Contact with Portfolio Manager(s).................................................................................................... 14 Item 9: Additional Information........................................................................................................................................ 14 ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 3 Association Financial Services, Inc.  Item 4: Services, Fees & Compensation Our Firm is a registered investment adviser that provides financial planning and investment counseling services to individuals, corporations, small businesses, 401(k), pensions and profit-sharing plans, estates, trusts, and institutional clients. Our Firm does business as TrueNorth Wealth, TrueNorth Retirement Services, and Idaho Medical Association Financial Services. As of January 31, 2026, the Firm provides continuous management services to approximately $1,265,596,116 in client assets under management. Of this amount, approximately $1,119,480,434 in client assets are managed on a non-discretionary basis and approximately $146,115,682 in client assets are managed on a discretionary basis. Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Transaction fees will be paid by our firm based on a percentage of the dollar amount of assets in the account. Because our firm absorbs client transaction fees, an incentive exists to limit trading activities in client accounts. Custodial transaction costs, however, are not included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the client to their chosen custodian. Depending on the client’s account or portfolio trading activity, clients may pay more for using our wrap fee services than they would for using our non-wrap services. Our Wrap Advisory Services Wrap Asset Management: As part of our Wrap Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. F e e S c h e d u l e M A N A G E D A S S E T M I N I M U M $ 5 0 0 K $0 - $1,000,000 ......................................................................................................... 0 . 8 8 % $1,000,000 - $2,000,000......................................................................................... 0 . 8 2 % $2,000,000 - $4,000,000.........................................................................................0 . 7 4 % $4,000,000 - $6,000,000.........................................................................................0 . 6 8 % $6,000,000 - $10,000,000...................................................................................... 0 . 6 2 % $10,000,000 + ............................................................................................. C O N C I E R G E ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 4 Association Financial Services, Inc.  C o m p r e h e n s i v e F i n a n c i a l P l a n n i n g S e r v i c e s I n c l u d e d R E T I R E M E N T A N A L Y S I S F I N A N C I A L R E V I E W I N V E S T M E N T A N A L Y S I S T A X E V A L U A T I O N S O C I A L S E C U R I T Y A N A L Y S I S E S T A T E E V A L U A T I O N C O N S U L T A N T S E R V I C E S $ 3 0 0 H O U R L Y R A T E Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis monthly in arrears based on the value of the account(s) on the last day of the month. Fees are negotiable and will be deducted from client account(s). Certain engagements may be charged an annualized fee that exceeds the fee schedule above, but under no circumstances will the fee exceed 1.00% of assets under management. All fees and fee payment arrangements will be memorialized in the advisory agreement. For various reason our firm offers clients a discounted fee schedule at its discretion. Each client is charged in accordance with the fee schedule specified in their investment management agreements. Adjustments will be made for deposits and withdrawals during the month. In rare cases, our firm will agree to directly invoice. Other Types of Fees & Expenses: In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark- downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Termination and Refunds: Either party may terminate the advisory agreement signed with our firm for Wrap Asset Management services in writing at any time. Upon notice of termination pro-rata advisory fees for services rendered to the point of termination will be charged. If advisory fees cannot be deducted, our firm will send an invoice for due advisory fees to the client. Wrap Fee Program Recommendations: Our firm does not recommend or offer the wrap program services of other providers. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Association Financial Services, Inc.  Item 5: Account Requirements & Types of Clients • Our requirements for opening and maintaining accounts or otherwise engaging us: Our firm requires a minimum account balance of $500,000 for our Asset Management service. This minimum account balance requirement is generally not negotiable and would be required throughout the course of the client’s relationship with our firm. However, our firm, in its sole discretion may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g.) historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Our firm has the following types of clients: • • • • Individuals and High Net Worth Individuals; Trusts, Estates or Charitable Organizations; Pension and Profit Sharing Plans; Corporations, Limited Liability Companies and/or Other Business Types Item 6: Portfolio Manager Selection & Evaluation Selection of Portfolio Managers: Our firm’s investment adviser representatives (“IARs”) act as portfolio manager(s) for this wrap fee program. A conflict arises in that other investment advisory firms may charge the same or lower fees than our firm for similar services. Our IARs are subject to individual licensing requirements as imposed by state securities boards. Our firm is required to confirm or update each IAR’s Form U4 on an annual basis. IAR supervision is conducted by our Chief Compliance Officer and management personnel. Advisory Business: Our Firm provides investment supervisory services, also known as asset management services and furnishes financial planning and investment advice through consultations. ASSET MANAGEMENT Our Firm offers non-discretionary wrap asset management services to advisory clients custodied at SEI. In a wrap fee program, clients are charged one fee which incorporates asset management and brokerage services. In a traditional asset management services, clients are charged an asset management fee and separately pay for brokerage services. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Association Financial Services, Inc.  ERISA PLAN SERVICES Limited Scope 3(21) Fiduciary. Our Firm provides service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. Our Firm may act as either: 1. Our Firm typically acts as a limited scope 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using our Firm can help mitigate that plan sponsor’s liability by following a diligent process. 3(38) Investment Manager 2. . Our Firm can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. Advisor would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. INSTITUTIONAL CONSULTING Our Firm offers consulting advice, counsel and recommendations to institutional clients on a case- by- case basis. These services include but are not limited to general advice, counsel, and recommendations to staff, governing boards, and investment advisory committees on a variety of matters. Our Firm will analyze, evaluate, and help to improve investment options, underlying investments, asset allocation strategies, and objectives based on age groups of its beneficiaries as well as allocation for risk reduction. FINANCIAL PLANNING AND CONSULTING Services can include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management and/or consulting, education funding, retirement planning, and estate planning. Normally, financial planning is provided in conjunction with investment management services, with the client’s investment management fee also covering the planning work. Our Firm does not actively seek financial planning-only engagements, but may offer them at its sole discretion. In this case, the client will compensate Our Firm on an hourly fee basis detailed under the “Fees and Compensation” section of our Form ADV Part 2A brochure. Our Firm gathers information for financial planning through personal interviews, which may take place in person or by phone, electronic mail, or other means. Related documents supplied by the client are carefully reviewed, and our Firm may provide a financial planning questionnaire. Often, a written financial plan report is prepared. From time to time, clients may request ad hoc consultation on individual planning topics, and a written report may not be necessary. Should a client choose to implement the recommendations in the plan, our Firm suggests the client work closely with his/her attorney, accountant, insurance agent, or other professional(s) as may be necessary. Implementation of financial plan recommendations is entirely at the client’s discretion, and the client is under no obligation to effect transactions through our Firm. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 Association Financial Services, Inc.  EDUCATIONAL SEMINARS/WORKSHOPS Our Firm holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Our Firm does not charge a fee for attendance to these seminars. Our firm allows Wrap Asset Management clients to impose restrictions on investing in certain securities or types of securities. Asset Management services are offered through wrapped accounts and non-wrap accounts, which are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. There is no difference between how accounts in the wrap-fee program and accounts outside of the wrap-fee program are managed. Participation in Wrap Fee Programs: Our firm only offers wrap fee account and traditional management accounts to our clients, which are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. Wrap-fee accounts and traditional management accounts are managed in the same way and charged the same investment management fees. Performance-Based Fees & Side-By-Side Management: Our firm does not charge performance-based fees. Methods of Analysis, Investment Strategies & Risk of Loss: The following methods of analysis are utilized by our firm when formulating investment advice and/or managing client assets: Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing a stock, futures contract, or currency using fundamental analysis there are two basic approaches one can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis from other types of investment analysis, such as quantitative and technical. Fundamental analysis is performed on historical and present data, but with the goal of making financial forecasts. There are several possible objectives: (a) to conduct a company stock valuation and predict its probable price evolution; (b) to make a projection on its business performance; (c) to evaluate its management and make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the intrinsic value of the share. When the objective of the analysis is to determine what stock to buy and at what price, there are two basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be made by purchasing the mispriced security and then waiting for the market to recognize its "mistake" and reprice the security.; and (b) Technical analysis maintains that all information is reflected already in the price of a security. Technical analysts analyze trends and believe that sentiment changes predate and predict trend changes. Investors' emotional responses to price movements lead to recognizable price chart patterns. Technical analysts also analyze historical trends to predict future price movement. Investors can use one or both of these different but complementary methods for stock picking. This presents a potential risk, as the price of a security ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 8 Association Financial Services, Inc.  can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Modern Portfolio Theory (“MPT”) : A mathematical framework for assembling a portfolio of assets such that the expected return is maximized for a given level of risk, defined as variance. Its key insight is that an asset's risk and return should not be assessed by itself, but by how it contributes to a portfolio's overall risk and return. MPT assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists that has better expected returns. The risk, return, and correlation measures used by MPT are based on expected values, which means that they are mathematical statements about the future (the expected value of returns is explicit in the above equations, and implicit in the definitions of variance and covariance). In practice, investors must substitute predictions based on historical measurements of asset return and volatility for these values in the equations. Very often such expected values fail to take account of new circumstances that did not exist when the historical data were generated. Mathematical risk measurements are also useful only to the degree that they reflect investors' true concerns—there is no point minimizing a variable that nobody cares about in practice. MPT uses the mathematical concept of variance to quantify risk, and this might be justified under the assumption of elliptically distributed returns such as normally distributed returns, but for general return distributions other risk measures (like coherent risk measures) might better reflect investors' true preferences. Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. The underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as our firm does not control the underlying investments in a fund or ETF, managers of different funds held by the Client may purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the Client’s portfolio. Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on numbers that can be found on reports such as balance sheets. The two techniques, however, will often be used together in order to examine a company's operations and evaluate its potential as an investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to the social and experiential realm rather than the mathematical one. This approach depends on the kind of intelligence that machines (currently) lack, since things like positive associations with a brand, management trustworthiness, customer satisfaction, competitive advantage and cultural ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 9 Association Financial Services, Inc.  shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative analysis is that subjective judgment may prove incorrect. The following investment strategies are used managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different assets perform differently in different market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer returns that are not perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for return are often derived in the same way. An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally: investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long- term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these three provides a starting point. Usually included are hybrid instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.; Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps; insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products, etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and futures; foreign currency; venture capital; private equity; and/or distressed securities. • There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and diversification. The most common forms of asset allocation are: strategic, dynamic, tactical, and core-satellite. • • Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset mix that seeks to provide the optimal balance between expected risk and return for a long- term investment horizon. Generally speaking, strategic asset allocation strategies are agnostic to economic environments, i.e., they do not change their allocation postures relative to changing market or economic conditions. Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Like strategic allocation strategies, dynamic strategies largely retain exposure to their original asset classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust their postures over time relative to changes in the economic environment. Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a more active approach that tries to position a portfolio into those assets, sectors, or individual stocks that show the most potential for perceived gains. While an original asset mix is ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 10 Association Financial Services, Inc.  formulated much like strategic and dynamic portfolio, tactical strategies are often traded more actively and are free to move entirely in and out of their core asset classes Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core' strategic element making up the most significant portion of the portfolio, while applying a dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this way, core- satellite allocation strategies are a hybrid of the strategic and dynamic/tactical allocation strategies mentioned above. Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that could have been profitable to your account, or it’s possible that the security’s value may decline sharply before our firm makes a decision to sell. Mutual Funds : A mutual fund is a company that pools money from many investors and invests that money in a variety of differing security types based on the objectives of the fund. The portfolio of the fund consists of the combined holdings it owns. Each share represents an investor’s proportionate ownership of the fund’s holdings and the income those holdings generate. The price that investors pay for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades. With an individual stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by checking financial websites or by calling a broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with a mutual fund, the price at which an investor purchases or redeems shares will typically depend on the fund’s NAV, which is calculated daily after market close. The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed by an investment adviser who researches, selects, and monitors the performance of the securities purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading investments across a wide range of companies and industry sectors can help lower the risk if a company or sector fails. Some investors find it easier to achieve diversification through ownership of mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds accommodate investors who do not have a lot of money to invest by setting relatively low dollar amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed on redemption. Mutual funds also have features that some investors might view as disadvantages: (a) Investors must pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending on the timing of their investment, investors may also have to pay taxes on any capital gains distributions they receive. This includes instances where the fund performed poorly after purchasing shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real- time) pricing information with relative ease by checking financial websites or by calling a broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour— or even second to second. By contrast, with a mutual fund, the price at which an investor purchases ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 11 Association Financial Services, Inc.  or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until many hours after the investor placed the order. In general, mutual funds must calculate their NAV at least once every business day, typically after the major U.S. exchanges close. When investors buy and hold an individual stock or bond, the investor must pay income tax each year on the dividends or interest the investor receives. However, the investor will not have to pay any capital gains tax until the investor actually sells and makes a profit. Mutual funds, however, are different. When an investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes on any personal capital gains when the investor sells shares, the investor may have to pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to offset these gains. Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). Our firm does this in an attempt to take advantage of conditions that our firm believes will soon result in a price swing in the securities our firm purchase. Please Note: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask any questions you may have. Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 12 Association Financial Services, Inc.  ETF & Mutual Fund Risk : When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also incur brokerage costs when purchasing ETFs. Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Cybersecurity Risk: Although our Firm has taken measures to decrease the risks associated with a cybersecurity event, the computer systems, networks and devices used by our Firm and its service providers potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. A cybersecurity breach could result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information of clients and investors. A cybersecurity breach may also cause disruptions and impact business operations potentially resulting in a financial loss to a client. Global Economic Risk: Global instability, natural disasters, geopolitical tensions, terrorist attacks, and the threat of a global pandemic may adversely affect the performance of the global economy. These affects include market volatility, market and business uncertainty and closures, supply chain and travel interruptions, the need for employees and vendors to work at external locations, and extensive medical absences. This may result in long-term effects on the United States and worldwide financial markets and may cause further economic uncertainties in the United States and worldwide. We cannot predict the effects of significant future events on the global economy and securities markets. A similar disruption of the financial markets could impact interest rates, credit risk, inflation and other factors. We have policies and procedures to address known situations, but not all events that could affect our business and/or the markets can be determined and addressed in advance. Voting Client Securities: Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. If a conflict of interest exists, it will be disclosed to the client. Item 7: Client Information Provided to Portfolio Manager(s) ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 13 Association Financial Services, Inc.  All accounts are managed by our in-house licensed IARs. The IAR selected to manage the client’s account(s) or portfolio(s) will be privy to the client’s investment goals and objectives, risk tolerance, restrictions placed on the management of the account(s) or portfolio(s) and relevant client notes taken by our firm. IARs communicate directly with clients and all client investment goals and objectives are reviewed at least annually. Item 8: Client Contact with Portfolio Manager(s) Clients are always free to directly contact their portfolio manager(s) with any questions or concerns about their portfolios or other matters. Item 9: Additional Information Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Financial Industry Activities & Affiliations Our firm has no financial industry activities and affiliations to disclose. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading The employees of our Firm have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of our Firm employees and addresses conflicts that may arise. The Code defines acceptable behavior for employees of our Firm. The Code reflects our Firm and its supervised persons’ responsibility to act in the best interest of their client. One area the Code addresses is when employees buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our clients. We do not allow any employees to use non- public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. Our Firm policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of our Firm may recommend any transaction in a security or its derivative to advisory clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Our Firm’s Code is based on the guiding principle that the interests of the client are our top priority. Our Firm’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the client’s interests over the interests of either employees or the company. The Code applies to “access” persons. “Access” persons are employees who have access to non-public information regarding any clients' purchase or sale of securities, or non-public information regarding ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 14 Association Financial Services, Inc.  involved in making securities the portfolio holdings of any reportable fund, who are recommendations to clients, or who have access to such recommendations that are non-public. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. Our Firm and its employees do not recommend to clients securities in which we have a material financial interest. Our Firm does not buy securities from, nor sell securities to any investment advisory client. Our Firm, and its officers, employees, and family members generally hold the same securities our Firm recommends for client accounts. Our Firm prohibits itself and its associated persons from benefiting from the short-term market effects of transactions for clients. Further, employees are required to disclose all reportable securities transactions as well as provide our Firm with copies of their brokerage statements. Our Firm does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, employees may buy or sell securities at the same time they buy or sell securities for clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide our Firm with copies of their brokerage statements. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. The Chief Compliance Officer of our Firm is Jared Empey. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment over employee transactions. Review of Accounts Our Firm’s financial advisors and compliance officer regularly monitor accounts to implement investment strategies that serve each client’s investment objectives. At a minimum, accounts are reviewed at least annually and upon client request. The nature of this review is to learn whether clients’ accounts are in line with their investment objectives, and appropriately positioned based on market conditions. Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Our Firm arranges for the custodian to furnish clients with confirmations of trades or debit/credit advice promptly after completion of any portfolio transaction for which our Firm has placed an order. The confirmations detail the principal amount and any other fees for each transaction. In addition, our Firm arranges for each client and/or client designated representative to receive regular account statements from the custodian showing the activity in each of the client’s accounts and the market value of each security in the accounts. Our Firm sends quarterly newsletters and other updates on markets information. Our Firm generates a written performance report authored by the custodian, which is reviewed during quarterly client meetings and upon request, may provide additional reports showing the industry and sector diversification of a portfolio, the cost basis of securities held, realized capital gains and losses, and other portfolio information. In addition, through meetings, telephone calls, and letters, our Firm regularly keeps clients informed ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 15 Association Financial Services, Inc.  of the investment policy and strategy for achieving clients’ investment objectives. The nature and frequency of these reports and other communications are determined primarily by the particular needs of each client. Product Sponsor Funded Events In an effort to keep our clients informed as to the services we offer and the various financial products we utilize, our firm occasionally sponsors events in conjunction with our product providers. These events are educational in nature and are not dependent upon the use of any specific products. While a conflict of interest may exist given that these events are at least partially funded by custodians, all funds received from the sponsors are used for the education of our clients, and we will always adhere to our fiduciary duties in selecting appropriate investments for our clients. Client Referrals Our Firm as a matter of policy and practice, may compensate persons, i.e., individual or entities, for the referral of advisory clients to the firm provided appropriate disclosures and regulatory requirements are met. In fact, our Firm has an agreement with Idaho Medical Association (IMA) under which IMA has agreed to provide opportunities for our Firm to obtain IMA members as advisory clients. In return, our Firm has agreed to pay IMA five percent of the gross annual revenue received from IMA members who become advisory clients. Our Firm also has an agreement with Wealthramp under which Wealthramp has agreed to refer advisory clients to our Firm. In return our Firm has agreed to pay Wealthramp a percentage of the gross annual revenue from clients referred by Wealthramp. All fees paid to solicitors are paid by our Firm and there is no additional cost to the client. These arrangements creates a relationship where IMA and Wealthramp are acting as a “promoter” as defined under Rule 206(4)-1. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 16 Association Financial Services, Inc.  Financial Information • Our firm is not required to provide financial information in this Brochure because: • • Our firm does not require the prepayment of more than $1200 in fees when services cannot be rendered within 6 months. Our firm does not serve as custodian of client funds or securities. Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. Our firm and its management have never been the subject of a bankruptcy proceeding. Additional Information Individual Retirement Account Rollover Disclosures As a normal extension of financial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 17 Association Financial Services, Inc.