COMPASS FINANCIAL SERVICES

Item 1: Cover Page Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, Iowa 50266 Telephone: (515) 327-1020 website: www.compassiowa.com IARD/CRD Number: 109441 February 4, 2026 This brochure provides information about the qualifications and business practices of Compass Financial Services, Inc. If you have any questions about the contents of this brochure, please email us at caleb.pearson@compassiowa.com or call 515-327-1020. 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. Compass Financial Services, Inc. is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Compass Financial Services, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 1  Item 2: Summary of Material Changes There have been no material changes since the February 13, 2025, filing on the IARD system. 2  Item 3: Table of Contents Item 1: Cover Page ............................................................................................. 1 Item 2: Summary of Material Changes ............................................................... 2 Item 3: Table of Contents .................................................................................. 3 Item 4: Advisory Business .................................................................................. 4 Item 5: Fees and Compensation ......................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management ....................... 7 Item 7: Types of Clients ..................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................ 7 Item 9: Disciplinary Information ........................................................................ 9 Item 10: Other Financial Industry Activities and Affiliations ............................... 9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................................... 10 Item 12: Brokerage Practices ............................................................................. 11 Item 13: Review of Accounts ............................................................................. 13 Item 14: Client Referrals and Other Compensation ............................................ 14 Item 15: Custody ............................................................................................... 15 Item 16: Investment Discretion .......................................................................... 15 Item 17: Voting Client Securities ........................................................................ 15 Item 18: Financial Information ........................................................................... 16 Privacy Notice ................................................................................................... 16 Form ADV Part 2b for Each Supervised Person ................................................... 17 3  ITEM 4 – ADVISORY BUSINESS Compass Financial Services, Inc. (“Compass”) was organized in 1999. The owners of Compass are Steve Conard, Caleb Pearson, Guy Leman, Julie Greer, and Justin Van Houten with Steve Conard and Justin Van Houten as principal owners. We provide investment advice to individuals, retirement plans, trusts, estates, charitable organizations, corporations and other business entities through our wrap program. We also provide advice to clients on financial planning, retirement planning, estate planning, tax planning which may include mortgages, automobiles, 529 plans, and other similar financial matters. Advice may be provided on matters that include, but are not limited to, life insurance, property and casualty insurance, and long-term care insurance. Compass is a fiduciary and is required to act in a client’s best interest at all times. Our wrap fee program allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Because our firm absorbs client transaction fees under a wrap arrangement, an incentive exists to limit trading activities in client accounts. Custodial transaction costs 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. This conflict of interest is mitigated by our fiduciary responsibility to always act in our client’s best interest, and as such we do not manage wrap accounts in any manner different from non-wrap accounts. Our Wrap Advisory Services Clients can engage our wrap fee program to manage all or a portion of their assets on a discretionary basis. Clients can establish accounts at LPL Financial (“LPL”) for the custody of assets, with our assistance. We typically provide investment advice on mutual fund shares, insurance products (including variable annuities and life insurance) and ETFs (exchange-traded funds). We may also provide investment advice on exchange-listed securities, securities traded over-the-counter, certificates of deposit, securities option contracts, REITs (real estate investment trusts), and any type of investment held in a client’s portfolio at the inception of the advisory relationship. This may not be an all-inclusive list. We may also render non-discretionary investment advisory services to clients relative to their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, we either direct or recommend the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Investment Management We use a time-tested, disciplined approach to investing. We are a “total portfolio” manager using an active, diversified investment approach. We believe that a portfolio should be diversified using asset classes that cross correlate. Typically, we tailor our portfolios to the individual needs of our clients by evaluating the client’s investment guidelines and objectives which we use to guide us in making investment decisions for each client. If you desire, you may impose restrictions on the securities or types of securities you would like us to invest in. Financial Planning & Consulting Services We provide financial planning and consulting services consistent with a client’s financial and tax status, in addition to risk tolerance and investment objectives. Financial plans typically include net worth analysis, estate planning, accumulation goals, business planning and investment strategy. Financial planning services include conducting assessments of a client’s net worth, cash flow 4  statement, retirement goals, estate planning objectives, investment analysis and debt reduction strategies. Services may also include budgetary, estate, tax, business and other planning services as needed. The Adviser starts the comprehensive financial planning process by taking a financial inventory. This generally involves gathering enough data to perform an analysis of client liabilities, cash flow, net worth and tax assessments. The Adviser also evaluates client insurance coverage and needs. The Adviser’s next step typically involves assisting clients with formalizing their goals and plotting their investment timelines as part of the financial planning process. Retirement Planning Retirement planning and financial planning are not one and the same. We have worked with many clients through their earning years and into the distribution phase of their lives. We assist clients with the management of their portfolios to ensure longevity through retirement while at the same time providing needed income. We have experience working with clients on a range of retirement planning issues, including rollover of 401(k) plans, level of income needed for retirement and tax-efficient distribution of after-tax and before-tax assets. Tax Planning Whether it’s the sale of a security, the exercise of a stock option, the transfer of real estate or the gifting of appreciated securities, advanced planning regarding the tax impact of a transaction is critical. Our team has many years of experience in assisting clients with tax issues. Our goal is to help our clients minimize their lifetime tax liability so they can hold onto the hard-earned dollars they work their entire careers to amass. General Information All Asset Management Services are provided on a discretionary or nondiscretionary basis by us. Discretion means the trading activity within the Client’s account(s) is entered by us without receiving prior authorization for each trade. This discretion is authorized by the Client in writing (upon signing the specific Investment Management Agreement) and may be revoked at any time by submitting a written request to us. Assets are managed on a discretionary basis unless the client prefers otherwise and we agree on a non-discretionary arrangement. The Client will receive confirmations and statements showing all trading activity in the account(s). Assets under Management As of December 31, 2025, we manage $407,449,818 in client assets on a discretionary basis for total assets under management. Wrap Program Please see our Wrap Brochure that includes the details our wrap program. We do not recommend or offer the wrap program services of other providers. ITEM 5 – FEES AND COMPENSATION We offer our services on a fee basis, which may include hourly and/or fixed fees, as well as fees based upon assets under management. Additionally, certain of our Investment Adviser Representatives, in their individual capacities, may offer securities brokerage services and insurance products under a commission arrangement. The firm reserves the right, in its sole discretion, to negotiate, reduce or waive the advisory fee for certain client accounts and for any period of time as determined by the firm. 5  Financial Planning & Consulting Fees The Adviser charges an hourly rate of $250 for financial planning and consulting services. Client fees are due and payable after services are provided and are not negotiable. The Adviser will invoice fees once the agreed upon services are provided. If clients elect to implement recommendations made in a financial plan, their accounts may incur transaction costs, retirement plan administration fees, and other mutual fund annual expenses that are charged by broker-dealers, plan administrators or mutual fund companies that sell securities or provide additional services to Adviser clients. These fees are in addition to and separate from financial planning and consulting fees. The Adviser considers fees for financial planning or consulting to be earned as progress is realized toward creation of the plan or completion of the service. Under no circumstances will the Adviser earn fees in excess of $1,200 more than six months in advance of services rendered. Clients will have a period of five (5) business days from the date of signing an advisory agreement to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, either party may terminate the advisory agreement upon giving 30 days written notice. Since fees are payable only after services are provided, there are no unearned fees and the client will not have a refund due upon early termination of the advisory agreement. Commissions or Sales Charges for Recommendations of Securities Clients can engage certain persons associated with the firm (but not the firm itself) to render securities brokerage services under a commission arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with this firm. Under this arrangement, clients may implement securities transactions through certain of our Investment Adviser Representatives in their respective individual capacities as registered representatives of LPL, an SEC registered broker-dealer and member of FINRA. LPL may charge brokerage commissions to effect these securities transactions and thereafter, a portion of these commissions may be paid by LPL to such representatives. Prior to effecting any transactions clients are required to enter into a new account agreement with LPL. The brokerage commissions charged by LPL may be higher or lower than those charged by other broker-dealers. We do not charge an advisory fee on the same assets for which our Investment Adviser Representatives receive commissions. First and foremost, our objective as a firm is to place nothing before the best interests of our clients. However, a conflict of interest exists to the extent that advisory representatives can recommend the purchase of securities where they receive commissions or other additional incentive for advisory compensation as a result. The receipt of commissions provides an representatives to recommend investment products based on compensation they will receive from selling such products, rather than on the client’s needs. We do not allow advisors to earn a commission on products that are included within our advisory accounts. We take the following steps to mitigate the possibility that the advisory representatives will recommend an investment product based on commission rather than on the client’s needs: we address the inherent conflicts as noted in the paragraph above, by disclosing them to you in this Brochure and disclosure is made to the client at the time a brokerage account is opened through LPL, identifying the nature of the transaction or relationship, the role to be played by LPL and the advisory representative, individually, and any compensation (e.g. commissions) to be paid by the client. We use LPL as our primary custodian. Some of our associated persons are registered representatives of LPL. The individuals that are licensed as registered representatives of LPL are subject to regulations that restrict them from conducting securities transactions away from LPL without written authorization from LPL. Please see Item 12 for additional disclosures about the LPL relationship. 6  Wrap Program Please see our Wrap Brochure that includes the details our wrap program fees. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees nor do we engage in side-by-side management. ITEM 7 – TYPES OF CLIENTS We provide investment advice to individuals, retirement plans, trusts, estates, charitable organizations, corporations and other business entities. The Adviser has no minimum account size. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Each Investment Advisor Representative (IAR) determines the most suitable investment strategy when managing client accounts, while adhering to the guidelines set forth by the Investment Committee. The following provides information regarding the methods of analysis and investment strategies that may be used by our advisory representatives. Methods of Analysis We typically use, directly or indirectly, fundamental and technical analysis to assist with investment decisions. Fundamental analysis involves the financial condition, operating performance, management, and competitive position of individual companies. The primary risk in using fundamental analysis for individual companies is that while the overall health and position of a company may be good, overall market conditions may negatively affect the value of its securities. When applied to securities markets, fundamental analysis evaluates prevailing macroeconomic and fiscal/monetary policy conditions in an effort to determine the relative level of risk and opportunity present in the overall investing environment. We base investment decisions in selected proprietary model portfolios on relative valuation; our assessment of whether markets are fairly priced, overvalued, or undervalued relative to historical norms and the prevailing fundamental investing landscape. The primary risk of using fundamental analysis in the context of securities markets is that prevailing investor sentiment may not be consistent with our assessment of the fundamental landscape. Technical analysis involves the analysis of past market data rather than specific company data in making investment decisions. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the underlying fundamentals of companies and markets. The primary risk in using technical analysis is that spotting historical trends does not guarantee that we will be able to predict accurately future reoccurrence of such trends. We do not directly employ technical analysis in our investment process. Investment Strategies We generally manage client portfolios by allocating portfolio assets among various mutual funds and ETFs using one or more of its proprietary model portfolios. We actively manage each model portfolio in a manner consistent with the financial circumstances and investment objectives of the clients assigned thereto. We believe that the long-term benefit of active portfolio management versus passive “Buy & Hold” investing derives from the proper management of risk over full-market cycles. Furthermore, we believe that the most meaningful measure of investment “risk” is the magnitude of market-induced drawdown in portfolio value and that changing market conditions dictate choosing which types of risk to assume and/or minimize. Mitigating the negative impact of the relative few “bear market” cycles produces superior long-term total returns versus a “buy and hold” investment strategy. We feel that portfolio construction based on how investments interact with, relate to, and correlate 7  with each other – can produce more consistent returns than basic asset allocation alone. We further believe that “beating the market” is not a meaningful investment objective, but that achieving investment returns that enable our clients to reach their financial goals without assuming unnecessary levels of risk is a superior objective. Model Portfolios Under normal circumstances, IARs will assign client accounts to one of our proprietary model portfolios based on a combination of the following factors: 1) primary investment objective; 2) time horizon in which the client anticipates drawing income from the account; 3) the client’s risk tolerance. We will manage accounts not assigned to any model portfolio for reasons determined by the IAR and client, in a manner consistent with a combination of the foregoing factors, and any other considerations deemed appropriate by the advisor and client. Proprietary model portfolios fall into one of three classifications: Growth, Volatility-Managed, or Income. Growth models shall pursue a primary investment objective of capital appreciation; Volatility- Managed models shall pursue a primary investment objective of total return consistent with limiting market-induced portfolio value declines; Income models shall pursue a primary investment objective of current income. We will operate within prescribed risk-management parameters for all model portfolios, regardless of which classification they fall under. To the extent that we have long-established relationships with certain product vendors, we expect to continue utilizing certain of those vendors’ funds in various model portfolios as ‘core’ strategic holdings. The designation of such ‘core’ holdings reflects our many years of experience with said products, in addition to other resources provided by these asset managers. Such resources include access to fund managers and other product experts, market intelligence and economic analysis, professional portfolio construction analytics, continuing education (CE) opportunities, client educational seminars and materials, access to technology-based analytical tools, and long-standing relationships with local representatives who understand and support our investment philosophy and practice. Given the foregoing resources are made available to us at no monetary cost, and that said vendors have historically provided financial sponsorship to events we offer to our clients (educational, entertainment, client appreciation), such support in all its forms presents a conflict of interest in the context of optimal investment selection for client portfolios. Other conflicts of interest in this regard may arise from our access to cost-free trading of certain vendors’ products. Recognizing that many of these ancillary resources serve to add tangible value to our investment process and cost savings to us, we expect our clients to benefit through enhanced investment performance, and for the associated cost savings to contribute to our ability to hold down client fees to the best of our ability over time. Notwithstanding the foregoing, to address these and any other conflicts of interest that may arise, we shall perform recurring due diligence on all incumbent products annually, employing the same process applied to the selection of new products. Each proprietary model portfolio has defined intervals and/or triggering events, which could necessitate reallocating the portfolio. We will review and evaluate every model portfolio for possible reallocation effective the first week of every calendar quarter. We may augment this “scheduled” trading review with “unscheduled” trading triggered by market-wide events or security-specific developments deemed significantly impactful to act on immediately. We benchmark each proprietary model portfolio against an appropriate recognized market index or blend of multiple indices. We will determine what constitutes a “best fit” benchmark for any given model portfolio based on the model’s primary investment objective and the investment strategy defined for the model. We will employ benchmarking for the primary purpose of tracking the efficacy of its investment strategies relative to passive market exposure employing no risk management. We will identify sources of tracking error when returns vary significantly versus those of the assigned 8  benchmark. Given the asset allocation strategy employed by some model portfolios, their portfolio composition may, at any given point in time, depart significantly from the benchmark weightings due to our efforts to enhance returns and/or mitigate investment risks. Risk of Loss Mutual Funds and Exchange Traded Funds (ETFs) An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”). The per-share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Market Risks The profitability of a significant portion of our recommendations or selections may depend to a great extent upon correctly assessing the future course of price movements of various securities in which it invests. There can be no assurance that we will be able to predict those price movements accurately. Please review the prospectus for a list of the specific risks for each fund. General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. ITEM 9 – DISCIPLINARY INFORMATION We, nor anyone on our management team, have been, or is currently, subject to any criminal, civil, or disciplinary action. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Individuals associated with us will provide its investment advisory services. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on behalf of us. Such individuals are known as Investment Adviser Representatives. None of our employees has a pending application to register as an associated person of a futures commission merchant, a commodity pool operator, or a commodity trading adviser. We do not have a pending application to register as a broker-dealer, a futures commission merchant, a commodity pool operator, or a commodity trading adviser. 9  Receipt of Securities Commission We participate in LPL’s hybrid RIA program. As such, some of the investment advisory representatives are also registered representatives of LPL. LPL is a broker-dealer that is independently owned and operated and is not affiliated with the firm. Please refer to Item 12 for a discussion of the benefits the firm receives from LPL and the conflicts of interest associated with receipt of such benefits. In such capacity, those advisory representatives that are also registered representatives of LPL will receive commissions for recommending the purchase or sale of securities. As a result of this relationship, LPL has access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about our clients, even if the client does not establish any account through LPL. Any client who would like a copy of the LPL privacy policy may contact the firm. Receipt of Insurance Commission Certain of our Investment Adviser Representatives, in their individual capacities, are licensed insurance agents with various insurance companies, and in such capacity, may recommend, on a fully- disclosed commission basis, the purchase of certain insurance products. Although we do not sell such insurance products to our investment advisory clients, we do permit the advisory representatives, in their individual capacities as licensed insurance agents, to sell insurance products to our investment advisory clients. A conflict of interest exists to the extent that we recommend the purchase of insurance products where its advisory representatives receive insurance commissions or other additional compensation. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We recognize that the personal investment transactions of the associated persons of the firm necessitates the implementation and strict adherence to a robust set of values, or Code of Ethics. W e h a v e adopted such a Code that sets forth the standards of conduct expected of its associated persons and requires compliance with applicable securities laws (“Code of Ethics”). In accordance with Section 204A of the Investment Advisers Act of 1940 (the “Advisers Act”), our Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public information by any of o u r associated persons. The Code of Ethics also requires that certain personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain pre- approval of certain investments such as initial public offerings and limited offerings. Unless specifically permitted in o u r Code of Ethics, none of our Access Persons may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household as the Access Person) any transactions in a security which is being actively purchased or sold on behalf of any of our clients. When we are purchasing or considering for purchase any security on behalf of a client, no Access Person may effect a transaction in that security prior to the completion of the purchase or until a decision has been made not to purchase such security. Similarly, when we are selling or considering the sale of any security on behalf of a client, no Access Person may effect a transaction in that security prior to the completion of the sale or until a decision has been made not to sell such security. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. A copy of our Code of Ethics is available upon request to any of our clients or prospective clients. 10  ITEM 12 – BROKERAGE PRACTICES We do not maintain physical custody of the assets we manage on your behalf. Your assets must be maintained in an account at a “qualified custodian,” generally defined as a broker-dealer or bank. At the current time we primarily recommend LPL as the sole and exclusive broker/dealer and custodian to execute transactions for investment management accounts. LPL provides brokerage and custodial services to independent investment advisory firms, including us. For the firm’s accounts custodied at LPL, LPL generally is compensated by clients through commissions, trails, or other transaction-based fees for trades that are executed through LPL or that settle into LPL accounts. For IRA accounts, LPL generally charges account maintenance fees. In addition, LPL also charges clients miscellaneous fees and charges, such as account transfer fees. LPL charges the firm an asset-based administration fee for administrative services provided by LPL. Such administration fees are not directly borne by clients, but may be taken into account when the firm negotiates its advisory fee with clients. While we believe that LPL has execution procedures that are designed to obtain the best execution possible, there can be no assurance that best execution will be obtained. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution for client transactions. Therefore, directed brokerage may cost clients more money. While LPL does not participate in, or influence the formulation of, the investment advice the firm provides, certain supervised persons of the firm are Dually Registered Persons. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or executing client transactions in such client accounts through any broker-dealer or custodian that is not approved by LPL. As a result, the use of other trading platforms must be approved not only by the firm, but also by LPL. Clients should also be aware that for accounts where LPL serves as the custodian, the firm is limited to offering services and investment vehicles that are approved by LPL, and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians, some of which may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL. Clients should also understand that LPL is responsible under FINRA rules for supervising certain business activities of the firm and its Dually Registered Persons that are conducted through broker- dealers and custodians other than LPL. LPL charges a fee for its oversight of activities conducted through these other broker-dealers and custodians. This arrangement presents a conflict of interest because the firm has a financial incentive to recommend that you maintain your account with LPL rather than with another broker-dealer or custodian to avoid incurring the oversight fee. Factors which we consider in recommending LPL or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. The commissions and/or transaction fees charged by LPL may be higher or lower than those charged by other financial institutions. We receive support services and/or products from LPL, many of which assist us to better monitor and service accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate, and may include the following: investment-related research software and other technology that provide access to client account data compliance and/or practice management-related programs and publications consulting services • • pricing information and market data • • • • attendance at conferences, meetings, and other educational and/or social events • marketing support 11  transition assistance for new advisory representatives computer hardware and/or software • • electronic communication network • duplicate client confirmations and statements • • other products and services used by us in the furtherance of its investment advisory business LPL Financial may provide these services and products directly or may arrange for third party vendors to provide the services or products to the firm. In the case of third party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services noted above are provided to the firm based on the overall relationship between our firm and LPL. It is not the result of soft dollar arrangements or any other express arrangements that involves the execution of client transactions as a condition to the receipt of services. We will continue to receive the above services regardless of the volume of client transaction executed with LPL. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by our firm to LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the above. The commissions paid by brokerage clients comply with our duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where we determine that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a financial institution’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. We seek competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. We periodically and systematically review our policies and procedures regarding the recommendation of LPL in light of our duty to obtain best execution. Transactions for each client generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among our clients’ differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as to price and allocated among our clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that we determine to aggregate client orders for the purchase or sale of securities, including securities in which our advisory representatives may invest, we will do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. We do not receive any additional compensation or remuneration as a result of the aggregation. In the event that the firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot 12 participate in an allocation, shares may be reallocated to other accounts (this may be due to  unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, we may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Within Retirement Plan Consulting Services, we may assist with to the retirement plan sponsor. This could include investment research and recommendations recommendations for consideration and selection by the plan sponsor, of specific investments to be held in the plan or, in the case of a participant-directed defined contribution plan, to be made available as an investment option under the plan. The plan sponsor is responsible for the selection of any vendor, broker/dealer or custodian for plan assets, and is responsible for placing any transactions deemed appropriate. Commissions or Sales Charges for Recommendations of Securities As stated previously, some individuals associated with us are licensed as registered representatives of LPL Financial. As a result of this licensing relationship, LPL Financial is responsible for supervising certain activities of the firm to the extent we manage assets at a broker/dealer and custodian other than LPL Financial. LPL Financial charges a fee for this oversight. This presents a conflict of interest in that the firm has a financial incentive to recommend that you maintain your account with LPL Financial rather than another custodian in order to avoid the oversight fee. However, to the extent the firm recommends you use LPL Financial for such services, it is because the firm believes that it is in your best interest to do so based on the quality and pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by LPL Financial. We are also cognizant of our duty to obtain best execution from all execution sources and have implemented policies and procedures reasonably designed in such pursuit. If we make a trade error that results in a loss to a client, we will make the client whole. If we make a trade error that results in a gain to a client, LPL, and not us, keeps the gain. In that case, LPL will keep the gain to defray the processing costs associated with errors. ITEM 13 – REVIEW OF ACCOUNTS Your accounts are under continuous review by our Investment Adviser Representatives. Our Investment Committee reviews our proprietary model portfolios on a weekly basis; changes made to any model portfolio by the committee will be reflected in all client accounts assigned to that model(s). Portfolio reviews are conducted frequently to judge the appropriateness of securities held in your account. Accounts are reviewed if there is an extraordinary event such as abnormal performance of a mutual fund or individual equity, if there is a change in a mutual fund manager or if there is a significant market swing. Caleb Pearson reviews all accounts and each Investment Adviser Representative is assigned his/her respective accounts under management. In addition to the written statements that our clients receive from LPL through the mail or via email our clients receive quarterly, semiannual, or annual reviews that include, but are not limited to, evaluation and review of securities currently held in an account, performance review, and review of activity in the account since the last review. 13  ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION We are required to disclose any relationship or arrangement where we receive an economic benefit from a third party (non-client) for providing advisory services. In addition, we are required to disclose any direct or indirect compensation that we provide for client referrals. At this time, we do not use the services of solicitors, affiliated or non-affiliated. As a result of our relationship with LPL, we may receive production bonuses, stock or stock options to purchase shares of LPL’s parent company, and other things of value such as free or reduced- cost attendance at LPL’s national sales conference or top producer forums and events. Such compensation may be based on overall business produced and/or the amount of assets serviced through LPL. Thus, there is a financial incentive for us to recommend that you select LPL as the custodian for your investment management account so that we will be compensated. We take our responsibilities to clients very seriously and we will only recommend that clients hire us for management services if we believe it is appropriate and in the client’s best interests. In addition, we receive an economic benefit from LPL Financial in the form of a loan, which is forgiven if we meet certain conditions in terms of maintaining a relationship with LPL Financial. We also receive payments from LPL to reimburse for marketing related expenses, technology costs, and to pay for transitioning new advisory representatives to the firm. Please see detailed discussion of the conditions and conflicts of interest in Item 12 Brokerage Practices. We receive an economic benefit from LPL in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at LPL. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12- Brokerage Practices). The availability to us of LPL's products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. LPL’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage trading, custody, reporting and related services – many of which are not typically available to LPL retail customers. LPL also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Here is a more detailed description of LPL’s support services: Services that Benefit You. LPL’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 LPL include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. LPL’s services described in this paragraph generally benefit you and your account. Services that May Indirectly Benefit You. LPL also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both LPL’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at LPL. In addition to investment research, LPL also makes available software and other technology that: • provide 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; and assist with back-office functions, recordkeeping and client reporting. 14  Services that Generally Benefit Our Firm. LPL also offers other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. LPL may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. LPL may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. LPL may also provide us with other benefits such as occasional business entertainment of our personnel. We do not use client brokerage commissions to obtain research or other products or services. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As a result of receiving these services, we have an incentive to continue to use or expand the use of LPL services. Our firm examined this conflict of interest when we chose to enter into the relationship with LPL and we have determined that the relationship is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. LPL charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). LPL enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. LPL commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by LPL may be higher or lower than those charged by other custodians and broker- dealers. ITEM 15 – CUSTODY We do not have physical custody of client funds or securities. Clients receive quarterly statements from the account custodian unless clients choose to receive monthly statements. Clients may request an updated position report from their advisor at any time. Clients should carefully review those statements. We do direct deduct fees from client’s accounts which is a form of custody. Clients may have standing letters of authorization on their accounts which is also a form of custody. We have reviewed all of those relationships and determined that they meet the IAA no action letter seven conditions and do not trigger the surprise custody audit. ITEM 16 – INVESTMENT DISCRETION Typically, we manage accounts on a discretionary basis. This means that you give us full and complete discretion and authority with respect to the management of your assets, including the authority to purchase, sell, exchange, convert and trade your assets, and to subcontract and use sub-advisers. If you desire, you may impose restrictions on the securities or types of securities you would like us to invest in. We will not exercise any discretionary authority when providing Retirement Plan Consulting Services. ITEM 17 – VOTING CLIENT SECURITIES We will not vote proxies on behalf of client accounts. Although we may, on rare occasions and only at the client's request, offer clients advice regarding corporate actions and the exercise of proxy voting rights. 15  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. As an advisory firm that maintains discretionary authority for client accounts and is deemed to have custody of some assets, we are also required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. We have no additional financial circumstances to report. Notice Regarding Treatment of Confidential Information Privacy Notice To Our Clients. We have adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that the customer expects us to service their accounts in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about our customers. We want the customer to know what information we collect and how we use and safeguard that information. What Information We Collect We collect certain nonpublic personal identifying information about our customers (such as name, address, social security number, etc.) from information that the customer provides on applications or other forms as well as communications (electronic, telephone, written, or in person) with the customer or authorized representatives (such as attorneys, accountants, etc.). We also collect information about brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.). What Information We Disclose We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship and then only to those persons necessary to effect the transactions and provide the services that the customer authorizes (such as broker-dealers, custodians, independent managers, etc.); (ii) persons assessing our compliance with industry standards (e.g. professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about our customers to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any purpose. If the customer decides at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time. Security of Customer Information We restrict access to customer nonpublic personal information to those employees who need to know that information to service the accounts. We maintain physical, electronic, and procedural safeguards that comply with applicable federal or state standards to protect customer personal information. Changes To Our Privacy Policy Or Relationship With The Customer Our policy about obtaining and disclosing information may change from time to time. We will provide the customer notice of any material change to this policy before we implement the change. If your personal information with us becomes inaccurate, or if you need to make a change to that information, please contact us at the number shown below so we can update our records. Further Information. For additional information regarding our privacy policy, please contact us by writing to us at 4801 Westown Parkway, West Des Moines, Iowa 50266, or calling (515) 327-1020. 16  Investment Adviser Brochure Supplement Part 2B Steven Anthony Conard Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, Iowa 50266 Telephone: (515) 327-1020 website: www.compassiowa.com CRD Number: 4370333 February 4, 2026 This brochure supplement provides information about Steven Anthony Conard that supplements the Compass Financial Services, Inc.’s brochure. You should have received a copy of that brochure. Please contact Caleb Pearson, Chief Compliance Officer, at 515-327-1020 if you did not receive a Compass Financial Services, Inc.’s brochure or if you have any questions about the contents of this supplement. information about Steven Conard is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 17  Item 2 – Educational Background and Business Experience Steven Anthony Conard was born in 1961. He received a Bachelor of Science degree in Business Administration from the University of Minnesota in 1983. He has passed Series 7 (05/2001), Series 66 (10/2004) and Series 63 (05/2001). Mr. Conard has earned and maintains the following professional designation with the qualifications listed: CERTIFIED FINANCIAL PLANNER® (CFP®) Year earned – 2007 In order to achieve and maintain certification, CFP® professionals must: 1) pass the comprehensive CFP® Certification Examination, 2) pass the CFP Board's Fitness Standards for Candidates and Registrants, 3) agree to abide by CFP Board's Code of Ethics and Professional Responsibility and Rules of Conduct which put clients' interests first, 4) comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement, and 5) complete 30 hours of continuing education (including 2 hours of approved Ethics CE) every two years. - See more at: http://www.cfp.net/become-a-cfp-professional/cfp-certification- requirements#sthash.qwXJz3yF.dpuf. Business Experience Compass Financial Services, Inc., West Des Moines, Iowa, Principal (01/2017 to present), Investment Adviser Representative (10/2004 to present) LPL Financial, LLC, West Des Moines, Iowa, Registered Representative, 10/2004 to present Item 3 – Disciplinary Information Steven Anthony Conard does not have any legal or disciplinary events to disclose. Mr. Conard is not the subject of any pending legal, disciplinary or administrative proceedings. Item 4 – Other Business Activities Mr. Conard is a registered representative of LPL Financial, a registered broker-dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), the Securities Investor Protection Corporation (“SIPC”) and a registered investment adviser. Mr. Conard is also an insurance agent appointed with various insurance companies. In these capacities Mr. Conard may recommend securities, insurance, or other products and receive commissions and other compensation if products are purchased through any firms with which Mr. Conard is affiliated. Thus, a conflict of interest exists between the interests of Mr. Conard and those of the advisory clients. However, clients are under no obligation to act upon any recommendations of Mr. Conard or affect any transactions through Mr. Conard if they decide to follow the recommendations. Item 5 – Additional Compensation Please refer to Item 4 -Other Business Activities. Item 6 – Supervision An Executive Team member reviews the performance of Steven Conard at least annually. Caleb Pearson, Chief Compliance Officer, is responsible for monitoring the activities of our supervised persons. Mr. Pearson’s telephone number is 515-327-1020. The Investment Committee reviews all accounts and re-balances assets as needed within the portfolio at least every quarter. The Investment Committee currently includes: Steven Conard, Caleb Pearson, Guy Leman, Justin Van Houten, and Alan 18  Hulstein. The Investment Committee meets weekly and reviews economic and market data, mutual fund and manager performance, and allocation analysis to determine whether any changes are required in client portfolios. Mr. Pearson, or his designee, reviews all written client performance materials and newsletters prior to use. All Adviser employees receive our Investment Adviser Supervisory Manual and Code of Ethics and are asked to annually certify to their understanding of the material. Most meetings with clients are in conjunction with another professional staff member who helps prepare the meeting materials and captures meeting notes in the client file. 19  Investment Adviser Brochure Supplement Part 2B Michele Ann Bjorkgren Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, Iowa 50266 Telephone: (515) 327-1020 website: www.compassiowa.com CRD Number: 4578500 February 4, 2026 This brochure supplement provides information about Michele Ann Bjorkgren that supplements the Compass Financial Services, Inc.’s brochure. You should have received a copy of that brochure. Please contact Caleb Pearson, Chief Compliance Officer, at 515-327-1020 if you did not receive a Compass Financial Services, Inc.’s brochure or if you have any questions about the contents of this supplement. information about Michele Bjorkgren is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 20  Item 2 – Educational Background and Business Experience Michele Ann Bjorkgren was born in 1966. She attended the University of Northern Iowa from 1984 to 1985; however, she did not receive a degree. She has passed Series 7 (01/2017), Series 65 (11/2012), Series 6 (01/2008) and Series 63 (09/2008). Business Experience Compass Financial Services, Inc., West Des Moines, Iowa, Investment Adviser Representative 08/2002 to present LPL Financial, LLC, West Des Moines, Iowa, Registered Representative, 08/2002 to present Item 3 – Disciplinary Information Michele Ann Bjorkgren does not have any legal or disciplinary events to disclose. Ms. Bjorkgren is not the subject of any pending legal, disciplinary or administrative proceedings. Item 4 – Other Business Activities Ms. Bjorkgren is a registered representative of LPL Financial, a registered broker-dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), the Securities Investor Protection Corporation (“SIPC”) and a registered investment adviser. Ms. Bjorkgren is also an insurance agent appointed with various insurance companies. In these capacities Ms. Bjorkgren may recommend securities, insurance, or other products and receive commissions and other compensation if products are purchased through any firms with which Ms. Bjorkgren is affiliated. Thus, a conflict of interest exists between the interests of Ms. Bjorkgren and those of the advisory clients. However, clients are under no obligation to act upon any recommendations of Ms. Bjorkgren or affect any transactions through Ms. Bjorkgren if they decide to follow the recommendations. Item 5 – Additional Compensation Please refer to Item 4 -Other Business Activities. Item 6 – Supervision An Executive Team member reviews the performance of Michele Bjorkgren at least annually. Caleb Pearson, Chief Compliance Officer, is responsible for monitoring the activities of our supervised persons. Mr. Pearson’s telephone number is 515-327-1020. The Investment Committee reviews all accounts and re-balances assets as needed within the portfolio at least every quarter. The Investment Committee currently includes: Steven Conard, Caleb Pearson, Guy Leman, Justin Van Houten, and Alan Hulstein. The Investment Committee meets weekly and reviews economic and market data, mutual fund and manager performance, and allocation analysis to determine whether any changes are required in client portfolios.. Mr. Pearson, or his designee, reviews all written client performance materials and newsletters prior to use. All Adviser employees receive our Investment Adviser Supervisory Manual and Code of Ethics and are asked to annually certify to their understanding of the material. Most meetings with clients are in conjunction with another professional staff member who helps prepare the meeting materials and captures meeting notes in the client file. 21  Investment Adviser Brochure Supplement Part 2B Caleb Wellington Pearson Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, Iowa 50266 Telephone: (515) 327-1020 website: www.compassiowa.com CRD Number: 5802474 February 4, 2026 This brochure supplement provides information about Caleb Wellington Pearson that supplements the Compass Financial Services, Inc.’s brochure. You should have received a copy of that brochure. Please contact Caleb Pearson, Chief Compliance Officer, at 515-327-1020 if you did not receive a Compass Financial Services, Inc.’s brochure or if you have any questions about the contents of this supplement. Additional information about Caleb Wellington Pearson is available on the SEC’s website at www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 22  Item 2 – Educational Background and Business Experience Caleb Wellington Pearson was born in 1988. He received a Bachelor’s degree in Finance from the University of Iowa in 2011. He has passed Series 7 (11/2014), Series 65 (06/2013), Series 6 (04/2012), Series 63 (11/2012), and Series 24 (12/2023). Business Experience LPL Financial, LLC, West Des Moines, Iowa, Investment Adviser Representative, 10/2023 to present Compass Financial Services, Inc., West Des Moines, Iowa, Principal (01/2017 to present), Investment Adviser Representative (09/2012 to present) LPL Financial, LLC, West Des Moines, Iowa, Registered Representative, 08/2012 to present Item 3 – Disciplinary Information Caleb Wellington Pearson does not have any legal or disciplinary events to disclose. Mr. Caleb Pearson is not the subject of any pending legal, disciplinary or administrative proceedings. Item 4 – Other Business Activities Mr. Caleb Pearson is a registered representative, registered principal, branch office manager, and investment adviser representative of LPL Financial, a registered broker-dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), the Securities Investor Protection Corporation (“SIPC”) and a registered investment adviser. Mr. Caleb Pearson is also an insurance agent appointed with various insurance companies. In these capacities Mr. Caleb Pearson may recommend securities, insurance, advisory, or other products and receive commissions and other compensation if products are purchased through any firms with which Mr. Caleb Pearson is affiliated. Thus, a conflict of interest exists between the interests of Mr. Caleb Pearson and those of the advisory clients. However, clients are under no obligation to act upon any recommendations of Mr. Caleb Pearson or affect any transactions through Mr. Caleb Pearson if they decide to follow the recommendations. Item 5 – Additional Compensation Please refer to Item 4 -Other Business Activities. Item 6 – Supervision An Executive Team member reviews the performance of Caleb Pearson at least annually. Caleb Pearson, Chief Compliance Officer, is responsible for monitoring the activities of our supervised persons. Mr. Caleb Pearson’s telephone number is 515-327-1020. The Investment Committee reviews all accounts and re-balances assets as needed within the portfolio at least every quarter. The Investment Committee currently includes: Steven Conard, Caleb Pearson, Guy Leman, Justin Van Houten, and Alan Hulstein. The Investment Committee meets weekly and reviews economic and market data, mutual fund and manager performance, and allocation analysis to determine whether any changes are required in client portfolios.. Mr. Caleb Pearson, or his designee, reviews all written client performance materials and newsletters prior to use. All Adviser employees receive our Investment Adviser Supervisory Manual and Code of Ethics and are asked to annually certify to their understanding of the material. Most meetings with clients are in conjunction with another professional staff member who helps prepare the meeting materials and captures meeting notes in the client file. 23  Investment Adviser Brochure Supplement Part 2B Guy Allen Duane Leman Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, Iowa 50266 Telephone: (515) 327-1020 website: www.compassiowa.com CRD Number: 6191212 February 4, 2026 This brochure supplement provides information about Guy Allen Duane Leman that supplements the Compass Financial Services, Inc.’s brochure. You should have received a copy of that brochure. Please contact Caleb Pearson, Chief Compliance Officer, at 515-327-1020 if you did not receive a Compass Financial Services, Inc.’s brochure or if you have any questions about the contents of this supplement. Additional information about Guy Leman is available on the SEC’s website at www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 24  Item 2 – Educational Background and Business Experience Guy Allen Duane Leman was born in 1977. He received a Bachelor of Arts degree in Environmental Science from Simpson College in 1999. He has passed Series 7 (07/2013) and Series 66 (08/2013). Mr. Leman has earned and maintains the following professional designation with the qualifications listed: CERTIFIED FINANCIAL PLANNER (CFP®) Year earned – 2010 In order to achieve and maintain certification, CFP® professionals must: 1) pass the comprehensive CFP® Certification Examination, 2) pass the CFP Board's Fitness Standards for Candidates and Registrants, 3) agree to abide by CFP Board's Code of Ethics and Professional Responsibility and Rules of Conduct which put clients' interests first, 4) comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement, and 5) complete 30 hours of continuing education (including 2 hours of approved Ethics CE) every two years. - See more at: http://www.cfp.net/become-a-cfp-professional/cfp-certification- requirements#sthash.qwXJz3yF.dpuf. Business Experience LPL Financial, LLC, West Des Moines, Iowa, Investment Adviser Representative, 10/2023 to present Compass Financial Services, Inc., West Des Moines, Iowa, Principal (01/2019 to present), Investment Adviser Representative (08/2013 to present) LPL Financial, LLC, West Des Moines, Iowa, Registered Representative, 06/2013 to present Item 3 – Disciplinary Information Guy Allen Duane Leman does not have any legal or disciplinary events to disclose. Mr. Leman is not the subject of any pending legal, disciplinary or administrative proceedings. Item 4 – Other Business Activities Mr. Leman is a registered principal, branch office manager and investment adviser representative of LPL Financial, a registered broker-dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), the Securities Investor Protection Corporation (“SIPC”) and a registered investment adviser. Mr. Leman is also an insurance agent appointed with various insurance companies. In these capacities Mr. Leman may recommend securities, insurance, advisory, or other products and receive commissions and other compensation if products are purchased through any firms with which Mr. Leman is affiliated. Thus, a conflict of interest exists between the interests of Mr. Leman and those of the advisory clients. However, clients are under no obligation to act upon any recommendations of Mr. Leman or affect any transactions through Mr. Pearson if they decide to follow the recommendations. Item 5 – Additional Compensation Please refer to Item 4 -Other Business Activities. Item 6 – Supervision An Executive Team member reviews the performance of Guy Leman at least annually. Caleb Pearson, Chief Compliance Officer, is responsible for monitoring the activities of our supervised persons. Mr. Pearson’s telephone number is 515-327-1020. The Investment Committee reviews all accounts and re-balances assets as needed within the portfolio at least every quarter. The Investment 25  Committee currently includes: Steven Conard, Caleb Pearson, Guy Leman, Justin Van Houten, and Alan Hulstein. The Investment Committee meets weekly and reviews economic and market data, mutual fund and manager performance, and allocation analysis to determine whether any changes are required in client portfolios. Mr. Pearson, or his designee, reviews all written client performance materials and newsletters prior to use. All Adviser employees receive our Investment Adviser Supervisory Manual and Code of Ethics and are asked to annually certify to their understanding of the material. Most meetings with clients are in conjunction with another professional staff member who helps prepare the meeting materials and captures meeting notes in the client file. 26  Investment Adviser Brochure Supplement Part 2B Justin Van Houten Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, IA 50266 Main Telephone No. (515) 327-1020 General Website www.compassiowa.com CRD Number: 7044437 February 4, 2026 This brochure supplement provides information about Justin Van Houten that supplements the Compass Financial Services, Inc.’s brochure. You should have received a copy of that brochure. Please contact Caleb Pearson, Chief Compliance Officer, at 515-327-1020 if you did not receive a Compass Financial Services, Inc.’s brochure or if you have any questions about the contents of this supplement. information about Justin Van Houten is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 27  Item 2 – Educational Background and Business Experience Justin Van Houten was born in 1981. He received a Bachelor of Arts degree with majors in Mass Communication and Journalism from Grand View University in 2008 and a Master of Science degree with a major in Business (Organizational Leadership) from Grand View University in 2011. He has passed Series 7TO (05/2019) and Series 66 (07/2019). Business Experience Firm Name and Title Compass Financial Services, Chief Executive Officer Compass Financial Services, Investment Adviser Representative LPL Financial, Registered Representative McPherson College, Assistant Football Coach Dates 01/2024 to present 07/2019 to present 07/2019 to present 03/2012 to 07/2018 Item 3 – Disciplinary Information Justin Van Houten does not have any legal or disciplinary events to disclose. Mr. Van Houten is not the subject of any pending legal, disciplinary or administrative proceedings. Item 4 – Other Business Activities Mr. Van Houten is a registered representative of LPL Financial, a registered broker-dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), the Securities Investor Protection Corporation (“SIPC”) and a registered investment adviser. In these capacities Mr. Van Houten may recommend securities or other products and receive commissions and other compensation if products are purchased through any firms with which Mr. Van Houten is affiliated. Thus, a conflict of interest exist between the interests of Mr. Van Houten and those of the advisory clients. However, clients are under no obligation to act upon any recommendations of Mr. Van Houten or affect any transactions through Mr. Van Houten if they decide to follow the recommendations. Item 5 – Additional Compensation Please refer to Item 4 - Other Business Activities above. Item 6 – Supervision An Executive Team member reviews the performance of Justin Van Houten at least annually. Caleb Pearson, Chief Compliance Officer, is responsible for monitoring the activities of our supervised persons. Mr. Pearson’s telephone number is 515-327-1020. The Investment Committee reviews all accounts and re-balances assets as needed within the portfolio at least every quarter. The Investment Committee currently includes: Steven Conard, Caleb Pearson, Guy Leman, Justin Van Houten, and Alan Hulstein. The Investment Committee meets weekly and reviews economic and market data, mutual fund and manager performance, and allocation analysis to determine whether any changes are required in client portfolios.. Mr. Pearson, or his designee, reviews all written client performance materials and newsletters prior to use. All Adviser employees receive our Investment Adviser Supervisory Manual and Code of Ethics and are asked to annually certify to their understanding of the material. Most meetings with clients are in conjunction with another professional staff member who helps prepare the meeting materials and captures meeting notes in the client file. 28  Investment Adviser Brochure Supplement Part 2B Alan David Hulstein Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, Iowa 50266 Telephone: (515) 327-1020 website: www.compassiowa.com CRD Number: 7349864 February 4, 2026 This brochure supplement provides information about Alan David Hulstein that supplements the Compass Financial Services, Inc.’s brochure. You should have received a copy of that brochure. Please contact Caleb Pearson, Chief Compliance Officer, at 515-327-1020 if you did not receive a Compass Financial Services, Inc.’s brochure or if you have any questions about the contents of this supplement. information about Alan David Hulstein is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 29  Item 2 – Educational Background and Business Experience Alan David Hulstein was born in 1998. He received a degree in Agriculture Business/Finance from Northwestern College (Orange City, IA) in 2021. He has passed Series 7TO (03/2022), Series 66 (05/2022), and SIE – Securities Industry Essentials Examination (12/2021). Mr. Hulstein has earned and maintains the following professional designation with the qualifications listed: CERTIFIED FINANCIAL PLANNER (CFP®) Year earned – 2023 In order to achieve and maintain certification, CFP® professionals must: 1) pass the comprehensive CFP® Certification Examination, 2) pass the CFP Board's Fitness Standards for Candidates and Registrants, 3) agree to abide by CFP Board's Code of Ethics and Professional Responsibility and Rules of Conduct which put clients' interests first, 4) comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement, and 5) complete 30 hours of continuing education (including 2 hours of approved Ethics CE) every two years. - See more at: http://www.cfp.net/become-a-cfp-professional/cfp-certification- requirements#sthash.qwXJz3yF.dpuf. Business Experience Compass Financial Services, Inc., West Des Moines, Iowa, Administrative Associate (06/2021 to present), Investment Adviser Representative (09/2022 to present) LPL Financial, LLC, West Des Moines, Iowa, Administrative Associate, 07/2021 to present Compass Financial Services, Inc., West Des Moines, Iowa, Intern, 03/2021 to 05/2021 Northwestern College, Orange City, Iowa, Full-time student, 08/2017 to 04/2021 Farmers Coop Society, Sioux Center, Iowa, Feed Truck Driver, 01/2017 to 04/2021 5A Transfer, Sioux Center, Iowa, Semi-truck Driver, 01/2017 to 04/2021 Item 3 – Disciplinary Information Alan David Hulstein does not have any legal or disciplinary events to disclose. Mr. Alan Hulstein is not the subject of any pending legal, disciplinary or administrative proceedings. Item 4 – Other Business Activities Mr. Alan Hulstein is a registered representative of LPL Financial, a registered broker-dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), the Securities Investor Protection Corporation (“SIPC”) and a registered investment adviser. Mr. Alan Hulstein is also an insurance agent appointed with various insurance companies. In these capacities Mr. Alan Hulstein may recommend securities, insurance, or other products and receive commissions and other compensation if products are purchased through any firms with which Mr. Alan Hulstein is affiliated. Thus, a conflict of interest exists between the interests of Mr. Alan Hulstein and those of the advisory clients. However, clients are under no obligation to act upon any recommendations of Mr. Alan Hulstein or affect any transactions through Mr. Alan Hulstein if they decide to follow the recommendations. Item 5 – Additional Compensation Please refer to Item 4 -Other Business Activities. 30  Item 6 – Supervision An Executive Team member reviews the performance of Alan Hulstein at least annually. Caleb Pearson, Chief Compliance Officer, is responsible for monitoring the activities of our supervised persons. Mr. Caleb Pearson’s telephone number is 515-327-1020. The Investment Committee reviews all accounts and re-balances assets as needed within the portfolio at least every quarter. The Investment Committee currently includes: Steven Conard, Caleb Pearson, Guy Leman, Justin Van Houten, and Alan Hulstein. The Investment Committee meets weekly and reviews economic and market data, mutual fund and manager performance, and allocation analysis to determine whether any changes are required in client portfolios.. Mr. Caleb Pearson, or his designee, reviews all written client performance materials and newsletters prior to use. All Adviser employees receive our Investment Adviser Supervisory Manual and Code of Ethics and are asked to annually certify to their understanding of the material. Most meetings with clients are in conjunction with another professional staff member who helps prepare the meeting materials and captures meeting notes in the client file. 31 

Item 1: Cover Page Compass Financial Services, Inc. 4801 Westown Parkway West Des Moines, Iowa 50266 Telephone: (515) 327-1020 website: www.compassiowa.com IARD/CRD Number: 109441 Form ADV Part 2A - Appendix 1 Wrap Fee Program Brochure February 4, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Compass Financial Services, Inc. If you have any questions about the contents of this brochure, please email us at caleb.pearson@compassiowa.com or call 515-327-1020. 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. Compass Financial Services, Inc. is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Compass Financial Services, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Compass Financial Services, Inc.’s CRD number is 109441. 1  Item 2 – Summary of Material Changes There have been no material changes since the February 13, 2025, filing on the IARD system. 2  Item 3: Table of Contents Item 1 Cover Page .................................................................................................................... 1 Item 2 Summary of Material Changes ...................................................................................... 2 Item 3 Table of Contents ......................................................................................................... 3 Item 4 Services, Fees and Compensation ................................................................................. 4 Item 5 Account Requirements and Types of Clients ................................................................. 6 Item 6 Portfolio Manager Selection and Evaluation ................................................................. 6 Item 7 Client Information Provided to Portfolio Managers ....................................................... 9 Item 8 Client Contact with Portfolio Managers ........................................................................ 9 Item 9 Additional Information ................................................................................................ 10 3  Item 4 – Services, Fees, and Compensation4: Services, Fees & Compensation Description of Our Advisory Firm Compass Financial Services, Inc. (“Compass”) was organized in 1999. The owners of Compass are Steve Conard, Caleb Pearson, Guy Leman, Julie Greer, and Justin Van Houten with Steve Conard and Justin Van Houten as principal owners. We provide investment advice to individuals, retirement plans, trusts, estates, charitable organizations, corporations and other business entities through our wrap program. We also provide advice to clients on financial planning, retirement planning, estate planning, tax planning which may include mortgages, automobiles, 529 plans, and other similar financial matters. Advice may be provided on matters that include, but are not limited to, life insurance, property and casualty insurance, and long-term care insurance. Compass is a fiduciary and is required to act in a client’s best interest at all times. Wrap Fee Program Our wrap fee program allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Because our firm absorbs client transaction fees under a wrap arrangement, an incentive exists to limit trading activities in client accounts. Custodial transaction costs 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. This conflict of interest is mitigated by our fiduciary responsibility to always act in our client’s best interest, and as such we do not manage wrap accounts in any manner different from non-wrap accounts. Clients can engage our wrap fee program to manage all or a portion of their assets on a discretionary basis. Clients can establish accounts at LPL Financial (“LPL”) for the custody of assets, with our assistance. We typically provide investment advice on mutual fund shares, insurance products (including variable annuities and life insurance) and ETFs (exchange-traded funds). We may also provide investment advice on exchange-listed securities, securities traded over-the-counter, certificates of deposit, securities option contracts, REITs (real estate investment trusts), and any type of investment held in a client’s portfolio at the inception of the advisory relationship. This may not be an all-inclusive list. We may also render non-discretionary investment advisory services to clients relative to their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, we either direct or recommend the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Investment Management We use a time-tested, disciplined approach to investing. We are a “total portfolio” manager using an active, diversified investment approach. We believe that a portfolio should be diversified using asset classes that cross correlate. Typically, we tailor our portfolios to the individual needs of our clients by evaluating the client’s investment guidelines and objectives which we use to guide us in making investment decisions for each client. If you desire, you may impose restrictions on the securities or types of securities you would like us to invest in. As of December 31, 2025, we manage $407,449,818 in client assets on a discretionary basis for total assets under management. Fees and Compensation Investment Management Fee We provide investment management services for an annual fee based upon a percentage of the market value of the assets being managed. Our investment management fee does include transaction 4  executions costs, custodial fees, or other costs. On an annualized basis, our current fees for investment management services will not exceed 1.75% of the assets under management. Our annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by us on the last day of the previous quarter. The annual fee is negotiable and we may charge additional fixed fees for planning/projects in certain circumstances. Fees for Management during Partial Quarters of Service For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement will continue in effect until terminated by either party pursuant to the terms of the Agreement. Our fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. If assets are deposited into or withdrawn from an account after the inception of a quarter, the fee payable with respect to such assets will be adjusted or prorated based on the number of days remaining in the quarter. Although the Adviser believes its management fee is competitive, clients may be able to find similar services at higher or lower costs. Clients should also be aware of the fact that different clients are charged different negotiated fees, thus some clients pay more or less than others for similar services. Also, there can be no assurance that transactions effected through us result in the lowest per transaction cost possible to a client. Prospective clients should be aware that in addition to the advisory fees, each mutual fund in which a client's assets are invested also pays its own advisory fees and other internal expenses which already have been deducted from the fund's reported performance. Depending on the fund, a client may be able to invest directly in the shares issued by the fund with or without incurring any sales or third-party management fees. Account maintenance fees are also deducted by the Custodian. In addition, there are tax effects pertaining to fund share redemptions, and other sales, made by the Adviser on behalf of clients. Redemptions and sales are taxable events which may accelerate the recognition of capital gains, and losses, and frequent redemptions and sales may result in short-term, rather than long-term, capital gains and losses. Fees payable to the Adviser for Investment Management Services are, with the client’s prior permission, automatically deducted from the client's account when due. The Adviser will liquidate money market shares to pay the fee and, if money market shares or cash value are not available, other investments will be liquidated. Authorization for the deduction of fees from the managed account is contained in the Agreement. The client may terminate the authorization for automatic deduction at any time by notifying the Adviser in writing. If we make a trade error that results in a loss to a client, we will make the client whole. If we make a trade error that results in a gain to a client, LPL, and not us, keeps the gain. In that case, LPL will keep the gain to defray the processing costs associated with errors. Other Compensation Commissions or Sales Charges for Recommendations of Securities Clients can engage certain persons associated with the firm (but not the firm itself) to render securities brokerage services under a commission arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with this firm. Under this arrangement, clients may implement securities transactions through certain of our Investment Adviser Representatives in their respective individual capacities as registered representatives of LPL, an SEC registered broker- dealer and member of FINRA. LPL may charge brokerage commissions to effect these securities transactions and thereafter, a portion of these commissions may be paid by LPL to such representatives. Prior to effecting any transactions clients are required to enter into a new account agreement with LPL. 5  The brokerage commissions charged by LPL may be higher or lower than those charged by other broker- dealers. We do not charge an advisory fee on the same assets for which our Investment Adviser Representatives receive commissions. First and foremost, our objective as a firm is to place nothing before the best interests of our clients. However, a conflict of interest exists to the extent that advisory representatives can recommend the purchase of securities where they receive commissions or other additional compensation as a result. The receipt of commissions provides an incentive for advisory representatives to recommend investment products based on compensation they will receive from selling such products, rather than on the client’s needs. We do not allow advisors to earn a commission on products that are included within our advisory accounts. We take the following steps to mitigate the possibility that the advisory representatives will investment product based on commission rather than on the client’s needs: we recommend an address the inherent conflicts as noted in the paragraph above, by disclosing them to you in this Brochure and disclosure is made to the client at the time a brokerage account is opened through LPL, identifying the nature of the transaction or relationship, the role to be played by LPL and the advisory representative, individually, and any compensation (e.g. commissions) to be paid by the client. Item 5 – Account Requirements and Types of Clients The Adviser usually does not require a minimum account size before accepting accounts for its various management services. The Adviser does not collect more than $1,200, six months in advance for fees. The Adviser makes its' advisory services available to a wide variety of clients including. but not limited to, individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. Item 6 - Portfolio Manager Selection and Evaluation Item 6.A – Selection and Review of Portfolio Managers Client’s investment portfolios are managed our Investment Adviser Representatives using our proprietary models. Item 6.B – Advisory Business, Performance-Based Fees and Side- By-Side Management, Methods of Analysis, Investment Strategies and Risk of Loss, And Voting Client Securities Our wrap fee program allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Because our firm absorbs client transaction fees under a wrap arrangement, an incentive exists to limit trading activities in client accounts. 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 non-wrap services. This conflict of interest is mitigated by our fiduciary responsibility to always act in our client’s best interest, and as such we do not manage wrap accounts in any different manner from non-wrap accounts. Our firm utilizes our licensed investment adviser representatives to mage client portfolios. Prior to becoming licensed with our firm, each IARs industry experience, licensure, outside business activities, client complaints (if any), disciplinary or regulatory history (if any) and financial well-being will be reviewed. Each Investment Adviser Representative will then have a Form U4 and ADV Part 2B on file with our firm. Item 6.B1 – Advisory Business See Item 4 of this Wrap Fee Program Brochure for a full description of Adviser’s wrap fee program. Adviser offers individualized investment advice to clients. Clients have the opportunity to place reasonable restrictions on the types of investments to be held in their portfolio. However, restrictions on investments in 6  certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Item 6.B2 – Performance-Based Fees and Side-By-Side Management The Adviser does not charge or receive, directly or indirectly, any performance-based fees and does not participate in side-by-side arrangements. Item 6.B3 – Methods of Analysis, Investment Strategies and Risk Of Loss Each Investment Advisor Representative (IAR) determines the most suitable investment strategy when managing client accounts, while adhering to the guidelines set forth by the Investment Committee. The following provides information regarding the methods of analysis and investment strategies that may be used by our advisory representatives. Methods of Analysis We typically use, directly or indirectly, fundamental and technical analysis to assist with investment decisions. Fundamental analysis involves the financial condition, operating performance, management, and competitive position of individual companies. The primary risk in using fundamental analysis for individual companies is that while the overall health and position of a company may be good, overall market conditions may negatively affect the value of its securities. When applied to securities markets, fundamental analysis evaluates prevailing macroeconomic and fiscal/monetary policy conditions in an effort to determine the relative level of risk and opportunity present in the overall investing environment. We base investment decisions in selected proprietary model portfolios on relative valuation; our assessment of whether markets are fairly priced, overvalued, or undervalued relative to historical norms and the prevailing fundamental investing landscape. The primary risk of using fundamental analysis in the context of securities markets is that prevailing investor sentiment may not be consistent with our assessment of the fundamental landscape. Technical analysis involves the analysis of past market data rather than specific company data in making investment decisions. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the underlying fundamentals of companies and markets. The primary risk in using technical analysis is that spotting historical trends does not guarantee that we will be able to predict accurately future reoccurrence of such trends. We do not directly employ technical analysis in our investment process. Investment Strategies We generally manage client portfolios by allocating portfolio assets among various mutual funds and ETFs using one or more of its proprietary model portfolios. We actively manage each model portfolio in a manner consistent with the financial circumstances and investment objectives of the clients assigned thereto. We believe that the long-term benefit of active portfolio management versus passive “Buy & Hold” investing derives from the proper management of risk over full-market cycles. Furthermore, we believe that the most meaningful measure of investment “risk” is the magnitude of market-induced drawdown in portfolio value and that changing market conditions dictate choosing which types of risk to assume and/or minimize. Mitigating the negative impact of the relative few “bear market” cycles produces superior long-term total returns versus a “buy and hold” investment strategy. We feel that portfolio construction based on how investments interact with, relate to, and correlate with each other – can produce more consistent returns than basic asset allocation alone. We further believe that “beating the market” is not a meaningful investment objective, but that achieving investment returns that enable our clients to reach their financial goals without assuming unnecessary levels of risk is a superior objective. 7  Model Portfolios Under normal circumstances, IARs will assign client accounts to one of our proprietary model portfolios based on a combination of the following factors: 1) primary investment objective; 2) time horizon in which the client anticipates drawing income from the account; 3) the client’s risk tolerance. We will manage accounts not assigned to any model portfolio for reasons determined by the IAR and client, in a manner consistent with a combination of the foregoing factors, and any other considerations deemed appropriate by the advisor and client. Proprietary model portfolios fall into one of three classifications: Growth, Volatility-Managed, or Income. Growth models shall pursue a primary investment objective of capital appreciation; Volatility- Managed models shall pursue a primary investment objective of total return consistent with limiting market-induced portfolio value declines; Income models shall pursue a primary investment objective of current income. We will operate within prescribed risk-management parameters for all model portfolios, regardless of which classification they fall under. To the extent that we have long-established relationships with certain product vendors, we expect to continue utilizing certain of those vendors’ funds in various model portfolios as ‘core’ strategic holdings. The designation of such ‘core’ holdings reflects our many years of experience with said products, in addition to other resources provided by these asset managers. Such resources include access to fund managers and other product experts, market intelligence and economic analysis, professional portfolio construction analytics, continuing education (CE) opportunities, client educational seminars and materials, access to technology-based analytical tools, and long-standing relationships with local representatives who understand and support our investment philosophy and practice. Given the foregoing resources are made available to us at no monetary cost, and that said vendors have historically provided financial sponsorship to events we offer to our clients (educational, entertainment, client appreciation), such support in all its forms presents a conflict of interest in the context of optimal investment selection for client portfolios. Other conflicts of interest in this regard may arise from our access to cost-free trading of certain vendors’ products. Recognizing that many of these ancillary resources serve to add tangible value to our investment process and cost savings to us, we expect our clients to benefit through enhanced investment performance, and for the associated cost savings to contribute to our ability to hold down client fees to the best of our ability over time. Notwithstanding the foregoing, to address these and any other conflicts of interest that may arise, we shall perform recurring due diligence on all incumbent products annually, employing the same process applied to the selection of new products. Each proprietary model portfolio has defined intervals and/or triggering events, which could necessitate reallocating the portfolio. We will review and evaluate every model portfolio for possible reallocation effective the first week of every calendar quarter. We may augment this “scheduled” trading review with “unscheduled” trading triggered by market-wide events or security-specific developments deemed significantly impactful to act on immediately. We benchmark each proprietary model portfolio against an appropriate recognized market index or blend of multiple indices. We will determine what constitutes a “best fit” benchmark for any given model portfolio based on the model’s primary investment objective and the investment strategy defined for the model. We will employ benchmarking for the primary purpose of tracking the efficacy of its investment strategies relative to passive market exposure employing no risk management. We will identify sources of tracking error when returns vary significantly versus those of the assigned benchmark. Given the asset allocation strategy employed by some model portfolios, their portfolio composition may, at any given point in time, depart significantly from the benchmark weightings due to our efforts to enhance returns and/or mitigate investment risks. 8  Risk of Loss Mutual Funds and Exchange Traded Funds (ETFs) An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”). The per-share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Market Risks The profitability of a significant portion of our recommendations or selections may depend to a great extent upon correctly assessing the future course of price movements of various securities in which it invests. There can be no assurance that we will be able to predict those price movements accurately. Please review the prospectus for a list of the specific risks for each fund. General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. Item 6.B4 – Voting Client Securities We will not vote proxies on behalf of client accounts. Although we may, on rare occasions and only at the client's request, offer clients advice regarding corporate actions and the exercise of proxy voting rights. The Adviser does not vote proxies on behalf of clients who will receive such notices from their account’s custodian. Item 7 - Client Information Provided to Portfolio Manager(s) Client’s portfolios will be managed by our Investment Adviser Representatives who is privy to the client’s investment goals and objectives, risk tolerance, restrictions placed on the management of the account(s) or portfolios(s) and relevant client notes taken by our firm. Please refer to our privacy policy if clients are concerned about the privacy of any non-public information we retain. Item 8 - Client Contact with Portfolio Manager(s) Clients are always free to directly contact any of our Investment Adviser Representatives with any questions or concerns they have about their portfolios or other matters. 9  Item 9 - Additional Information Item 9.A –Disciplinary Information; Other Financial Industry Activities We, nor anyone on our management team, have been, or is currently, subject to any criminal, civil, or disciplinary action. No Adviser employee has a pending application to register as a registered representative, an associated person of a futures commission merchant, a commodity pool operator, or a commodity trading adviser. The Adviser does not have a pending application to register as a broker- dealer, a futures commission merchant, a commodity pool operator, or a commodity trading adviser. Receipt of Securities Commission We participate in LPL’s hybrid RIA program. As such, some of the investment advisory representatives are also registered representatives of LPL. LPL is a broker-dealer that is independently owned and operated and is not affiliated with the firm. Please refer to Item 12 for a discussion of the benefits the firm receives from LPL and the conflicts of interest associated with receipt of such benefits. In such capacity, those advisory representatives that are also registered representatives of LPL will receive commissions for recommending the purchase or sale of securities. As a result of this relationship, LPL has access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about our clients, even if the client does not establish any account through LPL. Any client who would like a copy of the LPL privacy policy may contact the firm. Receipt of Insurance Commission Certain of our Investment Adviser Representatives, in their individual capacities, are licensed insurance agents with various insurance companies, and in such capacity, may recommend, on a fully- disclosed commission basis, the purchase of certain insurance products. Although we do not sell such insurance products to our investment advisory clients, we do permit the advisory representatives, in their individual capacities as licensed insurance agents, to sell insurance products to our investment advisory clients. A conflict of interest exists to the extent that we recommend the purchase of insurance products where its advisory representatives receive insurance commissions or other additional compensation. Item 9.B – Code of Ethics; Review of Accounts; Client Referrals And Other Compensation; And Financial Information We recognize that the personal investment transactions of the associated persons of the firm necessitates the implementation and strict adherence to a robust set of values, or Code of Ethics. We have adopted such a Code that sets forth the standards of conduct expected of its associated persons and requires compliance with applicable securities laws (“Code of Ethics”). In accordance with Section 204A of the Investment Advisers Act of 1940 (the “Advisers Act”), our Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public information by any of our associated persons. The Code of Ethics also requires that certain personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain pre-approval of certain investments such as initial public offerings and limited offerings. Unless specifically permitted in our Code of Ethics, none of our Access Persons may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household as the Access Person) any transactions in a security which is being actively purchased or sold on behalf of any of our clients. When we are purchasing or considering for purchase any security on behalf of a client, no Access Person may effect a transaction in that security prior to the completion of the purchase or until a decision has been made not to purchase such security. Similarly, when we are selling or considering the sale of any security on behalf of a client, no Access Person may effect a transaction in that security prior to the completion of the sale or until a decision has been made not to sell such security. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market 10  instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. A copy of our Code of Ethics is available upon request to any of our clients or prospective clients. Your accounts are under continuous review by our Investment Adviser Representatives. Our Investment Committee reviews our proprietary model portfolios on a weekly basis; changes made to any model portfolio by the committee will be reflected in all client accounts assigned to that model(s). Portfolio reviews are conducted frequently to judge the appropriateness of securities held in your account. Accounts are reviewed if there is an extraordinary event such as abnormal performance of a mutual fund or individual equity, if there is a change in a mutual fund manager or if there is a significant market swing. Caleb Pearson reviews all accounts and each Investment Adviser Representative is assigned his/her respective accounts under management. In addition to the written statements that our clients receive from LPL through the mail or via email our clients receive quarterly, semiannual, or annual reviews that include, but are not limited to, evaluation and review of securities currently held in an account, performance review, and review of activity in the account since the last review. We are required to disclose any relationship or arrangement where we receive an economic benefit from a third party (non-client) for providing advisory services. In addition, we are required to disclose any direct or indirect compensation that we provide for client referrals. At this time, we do not use the services of solicitors, affiliated or non-affiliated. As a result of our relationship with LPL, we may receive production bonuses, stock or stock options to purchase shares of LPL’s parent company, and other things of value such as free or reduced-cost attendance at LPL’s national sales conference or top producer forums and events. Such compensation may be based on overall business produced and/or the amount of assets serviced through LPL. Thus, there is a financial incentive for us to recommend that you select LPL as the custodian for your investment management account so that we will be compensated. We take our responsibilities to clients very seriously and we will only recommend that clients hire us for management services if we believe it is appropriate and in the client’s best interests. In addition, we receive an economic benefit from LPL Financial in the form of a loan, which is forgiven if we meet certain conditions in terms of maintaining a relationship with LPL Financial. We also receive payments from LPL to reimburse for marketing related expenses, technology costs, and to pay for transitioning new advisory representatives to the firm. Please see detailed discussion of the conditions and conflicts of interest in Item 12 Brokerage Practices. We receive an economic benefit from LPL in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at LPL. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12- Brokerage Practices). The availability to us of LPL's products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. LPL’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage trading, custody, reporting and related services – many of which are not typically available to LPL retail customers. LPL also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Here is a more detailed description of LPL’s support services: Services that Benefit You. LPL’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 LPL include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. LPL’s services described in this paragraph generally benefit you and your account. 11  Services that May Indirectly Benefit You. LPL also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both LPL’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at LPL. In addition to investment research, LPL also makes available software and other technology that: • provide 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; and • assist with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Our Firm. LPL also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events • technology, compliance, legal, and business consulting; • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. LPL may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. LPL may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. LPL may also provide us with other benefits such as occasional business entertainment of our personnel. We do not use client brokerage commissions to obtain research or other products or services. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As a result of receiving these services, we have an incentive to continue to use or expand the use of LPL services. Our firm examined this conflict of interest when we chose to enter into the relationship with LPL and we have determined that the relationship is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. LPL charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). LPL enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. LPL commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by LPL may be higher or lower than those charged by other custodians and broker- dealers. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. As an advisory firm that maintains discretionary authority for client accounts and is deemed to have custody of some assets, we are also required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. We have no additional financial circumstances to report. Notice Regarding Treatment of Confidential Information Privacy Notice To Our Clients. We have adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that the customer expects us to service their accounts in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about our customers. We want the customer to know what information we collect and how we use and safeguard that information. 12  What Information We Collect We collect certain nonpublic personal identifying information about our customers (such as name, address, social security number, etc.) from information that the customer provides on applications or other forms as well as communications (electronic, telephone, written, or in person) with the customer or authorized representatives (such as attorneys, accountants, etc.). We also collect information about brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.). What Information We Disclose We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship and then only to those persons necessary to effect the transactions and provide the services that the customer authorizes (such as broker-dealers, custodians, independent managers, etc.); (ii) persons assessing our compliance with industry standards (e.g. professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about our customers to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any purpose. If the customer decides at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time. Security of Customer Information We restrict access to customer nonpublic personal information to those employees who need to know that information to service the accounts. We maintain physical, electronic, and procedural safeguards that comply with applicable federal or state standards to protect customer personal information. Changes To Our Privacy Policy Or Relationship With The Customer Our policy about obtaining and disclosing information may change from time to time. We will provide the customer notice of any material change to this policy before we implement the change. If your personal information with us becomes inaccurate, or if you need to make a change to that information, please contact us at the number shown below so we can update our records. Further Information. For additional information regarding our privacy policy, please contact us by writing to us at 4801 Westown Parkway, West Des Moines, Iowa 50266, or calling (515) 327-1020. 13