DENVER PWM, LLC

ITEM 1 - COVER PAGE ADV PART 2A BROCHURE May 15, 2025 DENVER PWM, LLC dba Denver Private Wealth Management 2000 South Colorado Boulevard | Tower One Suite 3700 Denver, Colorado 80222 Phone: 720.354.3850 Phone | Fax: 720.354.3860 This brochure provides information about the qualifications and business practices of Denver PWM, LLC (“Denver PWM”). If you have any questions about this brochure's contents, please contact us at (720) 354-3850. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or any state securities authority. Denver PWM is a Registered Investment Adviser (“RIA”). Registration as an Investment Adviser with the SEC or any state securities authority does not imply a certain level of skill or training.  Additional information about Denver PWM is available on the SEC's website at http://www.adviserinfo.sec.gov/. You can search this site by a unique identifying number called an IARD number. The IARD number for Denver PWM is 171139. ITEM 2 - MATERIAL CHANGES SUMMARY OF MATERIAL CHANGES This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s Public disclosure website (IAPD) (SEC Advisor Info). Our last annual amendment was filed on March 25, 2024. There have been the following material changes to our Firm’s Brochure since our last Annual Amendment Filing. • Denver PWM, LLC no longer does business as (DBA) Harmony Private Client Advisers or Flourish Financial Partners • The Firm has increased its minimum initial account value to $500,000. • The Chief Compliance Officer of the firm is now Brian Rettig If you would like another copy of this Brochure, please download it from the SEC Website as indicated above or you may contact our Chief Compliance Officer, Brian Rettig at (720) 354-3850 or brettig@denverpwm.com Page 2 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  ITEM 3 - TABLE OF CONTENTS ITEM 1 - COVER PAGE ________________________________________________________________________ 1 ITEM 2 - MATERIAL CHANGES _________________________________________________________________ 2 SUMMARY OF MATERIAL CHANGES ________________________________________________________ 2 ITEM 3 - TABLE OF CONTENTS ________________________________________________________________ 3 ITEM 4 - ADVISORY BUSINESS _________________________________________________________________ 5 ABOUT OUR FIRM ________________________________________________________________________ 5 INVESTMENT MANAGEMENT AND SUPERVISION SERVICES __________________________________ 5 EMPLOYER-SPONSORED RETIREMENT PLAN SERVICES _______________________________________ 6 FINANCIAL PLANNING ____________________________________________________________________ 7 CONSULTING SERVICES ___________________________________________________________________ 8 DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS _________________________________ 8 WRAP FEE PROGRAMS ____________________________________________________________________ 9 ASSETS __________________________________________________________________________________ 9 ITEM 5 – FEES AND COMPENSATION __________________________________________________________ 9 INVESTMENT MANAGEMENT FEES AND COMPENSATION ___________________________________ 9 FINANCIAL PLANNING FEES ______________________________________________________________ 10 EMPLOYER-SPONSORED RETIREMENT PLAN FEES __________________________________________ 11 CONSULTING ___________________________________________________________________________ 11 ADDITIONAL FEES AND EXPENSES ________________________________________________________ 12 ADMINISTRATIVE SERVICES PROVIDED BY ORION AND TAMARAC ___________________________ 12 ITEM 6 -PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT _________________________ 13 ITEM 7 – TYPES OF CLIENTS __________________________________________________________________ 13 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ________________ 13 OVERVIEW ______________________________________________________________________________ 13 INVESTMENT PHILOSOPHY _______________________________________________________________ 14 RISK OF LOSS ___________________________________________________________________________ 14 ITEM 9 – DISCIPLINARY INFORMATION ________________________________________________________ 18 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS _________________________ 18 INSURANCE _____________________________________________________________________________ 18 FINANCIAL INSTITUTION CONSULTING SERVICES – MUTUAL SECURITIES _____________________ 18 ACCOUNTING SERVICES _________________________________________________________________ 18 Page 3 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  ITEM 11 – CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING18 ITEM 12 – BROKERAGE PRACTICES ___________________________________________________________ 19 THE CUSTODIAN AND BROKERS WE USE __________________________________________________ 19 AGGREGATION AND ALLOCATION OF TRANSACTIONS _____________________________________ 22 TRADE ERRORS __________________________________________________________________________ 23 ITEM 13 – REVIEW OF ACCOUNTS ____________________________________________________________ 24 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ____________________________________ 24 ITEM 15 – CUSTODY _________________________________________________________________________ 25 ITEM 16 – INVESTMENT DISCRETION _________________________________________________________ 27 ITEM 17 – VOTING YOUR SECURITIES _________________________________________________________ 27 ITEM 18 – FINANCIAL INFORMATION _________________________________________________________ 27 Page 4 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  ITEM 4 - ADVISORY BUSINESS ABOUT OUR FIRM This Disclosure document is being offered to you by Denver PWM, LLC (“Denver PWM, “us,” “we,” “our firm”) in connection with the investment advisory services we provide. Denver PWM, LLC does business as: • Denver Private Wealth Management This disclosure document discloses information about the services that we provide and the manner in which those services are made available to you, the client. We provide advisory services through Advisory teams, each with their own advisory focus and strategies driven by the types of clients they have. We are an investment management firm located in Colorado. Our main headquarters is located at 2000 South Colorado Boulevard Tower One, Suite 3700 Denver, Colorado 80222. We specialize in investment advisory services for high-net-worth individuals, families, trusts, estates, institutions (including ERISA and other retirement accounts) and profit-sharing plans. The Firm was established by Robert Spicer in March 2014. In January 2019, Darin Snow became the Managing Partner of Denver PWM. Brian Rettig serves as Chief Compliance Officer of the Firm. We are committed to helping clients build, manage, and preserve their wealth, and to providing assistance that helps clients to achieve their stated financial goals. We may offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and Denver PWM execute an engagement letter or client agreement. INVESTMENT MANAGEMENT AND SUPERVISION SERVICES We offer discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. These services include investment analysis, allocation of investments, quarterly portfolio statements, financial commentaries, financial plans, and ongoing monitoring of client portfolios. We determine your portfolio composition based on your needs, your portfolio restrictions, if any, your financial goals and your risk tolerances. We will work with you to obtain necessary information regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This information enables us to determine the portfolio best suited for your investment objective and needs. In performing our services, we shall not be required to verify any information received from you or from other professionals. If you request, we may recommend and/or engage the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. Once we have determined the types of investments to be included in your portfolio and allocated them, we will provide ongoing portfolio review and management services. This approach requires us to review your portfolio at least quarterly. Page 5 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives. We will trade these portfolios and rebalance them on a discretionary basis based on our market views and on your objectives, using our investment process. Our advisory services are tailored to meet your individual needs. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. However, when using mutual funds or Exchange Traded Funds (“ETFs”), this multi-fund manager approach makes it difficult for us to ensure that your portfolio will not invest in a particular industry or security. However, we are happy to discuss your preferences regarding socially conscious or other investment concerns and, we will try wherever possible, to accommodate them. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate authorization from you. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect an account’s performance. This could result in capital losses in your account. EMPLOYER-SPONSORED RETIREMENT PLAN SERVICES Employer-Sponsored Retirement Plan Advisory Services consist of helping employer plan sponsors establish, monitor and review their company’s retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment selection and monitoring, plan structure, and participant education. Pursuant to Section 402(c)(3) of ERISA, the client may appoint us as the Plan’s “investment manager” with respect to the Plan’s portfolio of investment options. We acknowledge that we are registered as an investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”) and act as a “fiduciary” within the meaning of Section 3(21) and 3(38) of ERISA with respect to the Plan. As a result of the 3(38) appointment, we are granted full trading authority over the Plan and have the sole responsibility for the selection and monitoring of all investment options offered under the Plan in accordance with the investment policy statement and its underlying investment objectives and strategies for the Plan. As a result of the 3(21) appointment, plan sponsors are responsible for making the fund changes within the account. Plan participants have the ability to exercise control over the assets in their account, and we have no authority or discretion to direct the investment of assets of any participant’s account under the Plan, unless a separate Investment Advisory Agreement is executed between the Participant and Denver PWM providing discretionary authority over the account. We offer management of 401(k), 457, and 403(b) accounts both on a plan level and on the individual participant level. PLAN LEVEL We will establish the Plan’s needs and objectives through an initial meeting to collect data, review Plan information, and assist in developing or updating the Plan’s provisions. Ongoing services may include recommendations regarding the selection and review of unaffiliated mutual funds that, in our judgment, are suitable for Plan assets to be invested. We periodically review the investment options selected and Page 6 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  make recommendations to keep or replace Plans investment options as appropriate. We perform a comprehensive review of Investment options and will assist with converting from incumbent service providers to a new service provider if appropriate. We will provide quarterly recommendations for the Plan’s investment allocation. Upon receipt we will review the investment options and provide positions for accounts in accordance with the management style chosen by the client. Plan Sponsors are responsible for making the fund changes within the account. PARTICIPANT LEVEL We can also be engaged to provide financial education to Plan participants. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA. Participant education will relate to general principles for investing and information about the investment options currently in the Plan. We may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for new participants. PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY) Financial Planning services may be offered on a comprehensive or a la carte (limited focus) basis. Financial plans may encompass all or some of the following areas of financial concern to the client: We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. FINANCIAL PLANNING Financial Planning services may be offered on a comprehensive or a la carte (limited focus) basis. Financial plans may encompass all or some of the following areas of financial concern to the client: • Estate Planning Goals • Retirement Planning • Education Planning • Insurance Planning/Risk Management • Investments • Asset Allocation Review and Recommendations Page 7 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  • Cash management and certain treasury services Information is obtained through personal interviews (including discussion of current financial status, future goals and attitude towards risk), and the review of related documents and data supplied by the client. A written financial plan may be prepared and provided. The implementation of financial plan recommendations is entirely at the discretion of the client. Financial plans are not limited in any way to products or services provided by any particular company. However, in general, only products and services that Denver PWM is able to provide will be offered. CONSULTING SERVICES We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we may provide advice on non-securities matters in connection with the rendering of estate planning, insurance, real estate, and/or annuity advice. In these cases, you may be required to select your own investment managers, Custodian and/or insurance companies for the implementation of consulting recommendations. If your needs include brokerage and/or other financial services, we may recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals (“Firms”). You must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm you choose. You are under no obligation to follow the consulting advice that we provide. DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal Page 8 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight. WRAP FEE PROGRAMS We do not offer a Wrap Fee Program. ASSETS As of December 31, 2024, we managed a total of $554,076,246 in discretionary regulatory assets under management. ITEM 5 – FEES AND COMPENSATION INVESTMENT MANAGEMENT FEES AND COMPENSATION We charge a fee as compensation for providing Investment Management services on your account. These services include advisory and consulting services, trade entry, investment supervision, transaction costs, and other account maintenance activities. Our custodian may charge custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for additional details. In addition, some mutual fund assets deposited in your accounts may have been subject to other mutual fund annual management and administrative fees as described in the funds’ prospectuses. These fees are independent of our fees and should be disclosed by the custodian or contained in each fund’s prospectus. You should also note that fees for comparable services vary and lower fees for comparable services may be available from other sources. The fees for portfolio management are based on an annual percentage of assets under management and are applied to the account asset value on a pro-rata basis and billed quarterly in advance. The initial fee will be based upon the date the account is accepted for management by execution of the advisory agreement or when the assets are transferred through the last day of the current calendar quarter. Thereafter, the fee will be based at each previous quarter’s last business day. The market value will be determined as reported by the Custodian. Fees are assessed on all assets under management, including securities, cash and money market balances. There may be a possibility for price or account value discrepancies due to quarter-end transactions in an account. Dividends or trade date settlements may occur, and our third-party billing software may report a slight difference in account valuation at quarter end compared to what is reported on your Statement from the Custodian. Our Firm has the ability to produce billing summaries, which can be provided upon request. Our maximum investment advisory fee is 1.5%. Page 9 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  The specific advisory fees are set forth in your Investment Advisory Agreement. Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account or other reasons agreed upon by us and you as the client. In certain circumstances, our fees and the timing of the fee payments may be negotiated. At our discretion, we will aggregate asset amounts in accounts from your same household together to determine the advisory fee for all your accounts. We may do this, for example, where we also service accounts on behalf of your minor children, individual and joint accounts for a spouse, and/or other types of related accounts. This consolidation practice is designed to allow you the benefit of an increased asset total, which could potentially cause your account(s) to be assessed a lower advisory fee based on the asset levels available in our fee schedule. The independent qualified custodian holding your funds and securities will debit your account directly for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be paid directly from your account held by the qualified custodian. Further, the qualified custodian agrees to deliver an account statement at least quarterly directly to you indicating all the amounts deducted from the account including our advisory fees. See Item 15 for details. At our discretion, you may pay the advisory fees by check. You are encouraged to review your account statements for accuracy. Either party may terminate the management agreement thirty (30) days upon written notice. The management fee will be pro-rated to the date of termination, for the quarter in which the cancellation notice was given and refunded to you. The advisor will instruct the custodian to credit the account, or if the advisory account is closed, the firm will issue a check to the client in the amount of the refund. Upon termination, you are responsible for monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those assets. FINANCIAL PLANNING FEES Our Firm will negotiate the planning fees with you. Fees may vary based on the extent and complexity of your individual or family circumstances and the amount of your assets under our management. We will determine your fee for the designated financial advisory services based on a fixed fee arrangement described below. Under our fixed fee arrangement, any fee will be agreed to in advance of services being performed. The fee will be determined based on factors including the complexity of your financial situation, agreed upon deliverables, and whether or not you intend to implement any recommendations through our Firm. Under our fee arrangement, fees for initial financial plans range from $2,000 to $5,000. Typically, we complete a plan within a month and will present it to you within 90 days of the contract date, provided that you have provided us all information needed to prepare the financial plan. Fees are billed in two ways: (1) One hundred percent (100%) up front or (2) one half (50%) of the estimated fee will be due and payable at the time you enter into the financial planning agreement, with the balance due and payable at the time the financial plan is delivered. Typically, fees $500 or less will be billed with 100% upon entering the Agreement with our firm. You may terminate the financial planning agreement by providing us with written notice. Upon termination, fees will be prorated to the date of termination and any unearned portion of the fee will be refunded to you based on an hourly rate of $200.00. Services provided up to date of termination but not yet paid to our Firm will be billed to you based on the hourly rate of $200.00. We will not require prepayment of more than $1,200 in fees per client, six (6) or more months in advance of providing any services. Page 10 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  In no case are our fees based on, or related to, the performance of your funds or investments. When both investment management or plan implementation and Financial Planning services are offered, there is a conflict of interest since there is an incentive for us offering Financial Planning services to recommend products or services for which our Firm receives compensation. However, our Firm will make all recommendations independent of such considerations and based solely on our obligations to consider your objectives and needs. As a Financial Planning client, you have the right not to act upon any of our recommendations and not affect the transaction(s) through us if you decide to follow the recommendations. HOURLY CHARGES We may charge a client an hourly fee for wealth management services or financial planning; please refer to Item 4 for more detail on those services. For the hourly fee, the non-discretionary services will be outlined in a Consulting Agreement. Our Firm’s hourly fee ranges from $200 to $300 per hour. EMPLOYER-SPONSORED RETIREMENT PLAN FEES For Retirement Plan Advisory Services compensation, we charge an annual fee as negotiated with the client and disclosed in the Employer-Sponsored Retirement Plans Investment Advisory Agreement. The compensation method is explained and agreed upon in advance before any services are rendered. Fees range from 0.20% to 1.00% annually. Plan advisory services begin with the effective date of the Investment Advisory Agreement, which is the date you sign the Investment Advisory Agreement. For that calendar quarter, fees will be adjusted pro rata based upon the number of calendar days in the calendar quarter that the Agreement was effective. Our fee is billed in advance on the last business day of the calendar quarter. Invoices are sent out each quarter to either the client or the custodian of the Plan. For Plans where our fee is billed to the custodian, the fee is deducted directly from the participant accounts. Written authorization permitting us to be paid directly from the custodial account is outlined in the Investment Advisory Agreement. Either party may terminate the Investment Advisory Agreement at any time upon immediate notice. You are responsible to pay for services rendered until the termination of the agreement. CONSULTING We provide planning services for clients who need advice on a limited scope of work. We will negotiate consulting fees with you. Fees may vary based on the extent and complexity of the consulting project. Fees are negotiated and you will be billed as services are rendered. Either party may terminate the agreement. Upon termination, fees will be prorated to the date of termination and any unearned portion of the fee will be refunded to you as described above. PONTERA Our Firm is engaged with Pontera, an unaffiliated third-party service provider, for Client accounts not directly held with our recommended Custodian; but where our team has discretion and leverages an Page 11 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  Order Management System to implement asset allocation or rebalancing strategies on behalf of the Client. These are primarily 401(k) accounts, 403(b) accounts, 529 plans, variable annuities, and other assets not held with the recommended Custodian. We regularly review the current holdings and available investment options in these accounts, monitor the account, rebalance, and implement our Firm’s strategies as necessary. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client, allowing them to connect an account(s) to the platform. Once the Client account(s) is connected to the platform, Adviser will review the current account allocations and investment options. When we are authorized with discretionary management, we will rebalance the account, considering Client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during complex markets, and manage internal fees that harm account performance. Client account(s) will be reviewed quarterly, and allocation changes will be made as necessary. ADDITIONAL FEES AND EXPENSES Advisory fees payable to us do not include all the fees you will pay when we purchase or sell securities for your Account(s). The following list of fees or expenses are what you may pay directly to third parties only, whether a security is being purchased, sold or held in your Account(s) under our management. • Transaction fees; • SEC fees; • Custodial Fees; • Transfer taxes; • Wire transfer and electronic fund processing fees. Please refer to the “Brokerage Practices” below for discussion of our brokerage practices. ADMINISTRATIVE SERVICES PROVIDED BY ORION AND TAMARAC We have contracted Tamarac to utilize its technology platform to support data reconciliation, performance reporting, fee calculation and billing, client database maintenance, quarterly performance evaluations, payable reports, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Tamarac will have access to client information, but will not serve as an investment adviser to our clients. Denver PWM, Tamarac are nonaffiliated companies. Orion and Tamarac charge our Firm an annual fee for each account administered by them. Please note that the fee charged to the client will not increase due to the annual fee Denver PWM pays to Tamarac. The annual fee is paid from the portion of the management fee retained by our Firm. Page 12 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  ITEM 6 -PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client account (so-called performance-based fees). Our advisory fee compensation is charged only as disclosed above in Fees and Compensation. ITEM 7 – TYPES OF CLIENTS We provide investment advice to individuals, high-net-worth individuals, families, small businesses, pensions, foundations, trusts and estates. Our minimum initial account value is $500,000; however, we may accept accounts for less than the minimum at our sole discretion. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS OVERVIEW We seek to recommend investment strategies that will give a client a diversified portfolio consistent with the client’s investment objective. We do this by analyzing the various securities and investment strategies. The goal is to identify a client’s risk tolerance, and then find a manager with the maximum expected return for that level of risk. Our investment strategies and advice may vary depending upon each client’s specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. We utilize both fundamental and technical analysis. We gather our information from a broad array of financial resources including financial newspapers, magazines, research prepared by others, corporate rating services, company press releases, annual reports, prospectuses and filings with the Securities and Exchange Commission. We determine how to allocate assets among the various asset classes based on the investment strategy chosen, prevailing economic conditions and our determination of where we are in the economic cycle. Potential risks and opportunities are weighed to determine to what degree the portfolio should be invested. Our Firm employs the following investments: exchange-traded funds, mutual funds, fixed income, closed-end funds, alternative investments, and individual equities securities. Other strategies and securities may also be used for individual portfolios as necessary to meet investor objectives such as leveraged and non-leveraged closed end funds, exchange traded notes (ETNs), managed futures, real assets, oil and gas interests and covered call/put option writing. We may also utilize currency ETFs to diversify clients USD portfolio holdings. The previously mentioned investments shall have liquidity that is not less than quarterly subject to 90 days’ notice to the Investment Manager. Page 13 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  Market conditions may cause your account to vary from the established allocation from time to time. To remain consistent with the asset allocation guidelines established, your account is monitored on an ongoing basis and rebalanced to the original allocation or, if deemed beneficial, to a new allocation based on the then-prevailing economic conditions and within the guidelines of the chosen investment strategy. In addition to the rebalancing, overall market conditions and microeconomic factors that affect specific holdings in your account may trigger changes in allocation. Your account may also receive informal reviews more frequently. Our Firm may include mutual funds, and exchange-traded funds (“ETFs”) in our investment strategies. Our policy is to purchase institutional share classes of those mutual funds selected for the client’s portfolio. The institutional share class generally has the lowest expense ratio. The expense ratio is the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for funds’ expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and all other asset- based costs incurred by the fund. Some fund families offer different classes of the same fund and one share class may have a lower expense ratio than another share class. These expenses come from client assets which could impact the client’s account performance. Mutual fund expense ratios are in addition to our fee, and we do not receive any portion of these charges. If an institutional share class is not available for the mutual fund selected, the adviser will purchase the least expensive share class available for the mutual fund. As share classes with lower expense ratios become available, we may use them in the client’s portfolio, and/or convert the existing mutual fund position to the lower cost share class. Clients who transfer mutual funds into their accounts with our Firm would bear the expense of any contingent or deferred sales loads incurred upon selling the product. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). All mutual fund expenses and fees are disclosed in the respective mutual fund prospectus. INVESTMENT PHILOSOPHY Prior to making recommendations, we determine your financial status, needs, time horizon, investment objectives, risk tolerance, and tax status. From this, we create an investor profile and general asset allocation target. While we believe asset allocation is a key factor affecting long-term rate of return, we also believe fundamental research and securities selection are vital. As much as reasonably possible, we strive to: • Diversify strategically with non-correlating assets. • Balance between growth and value styles. • Diversify globally. • Rebalance as markets change. • Manage for tax efficient returns wherever possible. RISK OF LOSS Page 14 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  The securities in our clients’ portfolios typically include exchange-traded funds (ETFs), mutual funds, stocks, corporate and municipal bonds, and other assets, all of which are subject to some or all of the following risk factors: MARKET RISK Even a long-term investment approach cannot guarantee a profit. Economic, political and issuer- specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon liquidation. FOREIGN SECURITIES AND CURRENCY RISK Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. CAPITALIZATION RISK Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. INTEREST RATE RISK In a rising rate environment, the value of fixed-income securities generally declines, and the value of equity securities may be adversely affected. CREDIT RISK Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and, thus, impact the fund’s performance. Securities Lending Risk — Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. DERIVATIVE RISK Derivatives are securities, such as futures contracts, whose value is derived from that of other securities or indices. Derivatives can be used for hedging (attempting to reduce risk by offsetting Page 15 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  one investment position with another) or non-hedging purposes. Hedging with derivatives may increase expenses, and there is no guarantee that a hedging strategy will achieve the desired results. EXCHANGE-TRADED FUNDS RISK ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset value.” PERFORMANCE OF UNDERLYING MANAGERS RISK We select the mutual funds and ETFs in the asset allocation models. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. LIQUIDITY RISK Liquidity risk exists when particular investments would be difficult to purchase or sell, possibly preventing clients from selling such securities at an advantageous time or price. ALTERNATIVE INVESTMENTS RISK Investments classified as “alternative investments” may include a broad range of underlying assets including, but not limited to, hedge funds, private equity, venture capital, and registered, publicly traded securities. Alternative investments are speculative, not suitable for all clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short- selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with a single advisor; absence of information regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees than other investment options such as mutual funds. The SEC requires investors be accredited to invest in these more speculative alternative investments. Investing in a fund that concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility. STRUCTURED NOTE RISK Structured products are designed to facilitate highly customized risk-return objectives. While structured products come in many different forms, they typically consist of a debt security that is structured to make interest and principal payments based upon various assets, rates, or formulas. Page 16 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  Many structured products include an embedded derivative component. Structured products may be structured in the form of a security, in which case these products may receive benefits provided under federal securities law, or they may be cast as derivatives, in which case they are offered in the over- the-counter market and are subject to no regulation. Investment in structured products includes significant risks, including valuation, liquidity, price, credit, and market risks. One common risk associated with structured products is a relative lack of liquidity due to the highly customized nature of the investment. Moreover, the full extent of returns from the complex performance features is often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment decision rather than a means of getting in and out of a position with speed and efficiency. Another risk with structured products is the credit quality of the issuer. Although the cash flows are derived from other sources, the products themselves are legally considered to be the issuing financial institution’s liabilities. The vast majority of structured products are from high-investment-grade issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of alternative structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or commissions among broker-dealers. CYBERSECURITY RISK In addition to the Material Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at our Firm or one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information, and generally compromise our Firm’s ability to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk that cybersecurity breaches may not be detected. SOCIALLY RESPONSIBLE INVESTING AND ESG RISK Clients utilizing responsible investing strategies and environment, social responsibility and corporate governance (ESG) factors may underperform strategies which do not utilize responsible investing and ESG considerations. Socially responsible investing and ESG strategies may operate by either excluding the investments of certain issuers or by selecting investments based on their compliance with factors such as ESG. These strategies may exclude certain sectors or industries from a client’s portfolio, potentially negatively affecting the client’s investment performance if the excluded sector or industry outperforms. Socially responsible investing and ESG are subjective by Page 17 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  nature, and the Firm may rely on analysis and ‘scores’ provided by third parties in determining whether an issuer meets the standards for inclusion or exclusion. A client’s perception may differ from our Firm or a third parties on how to judge an issuers adherence to responsible investing principles. ITEM 9 – DISCIPLINARY INFORMATION We do not have any legal, financial or other “disciplinary” item to report. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS INSURANCE Investment Adviser Representatives (“IAR”) of Denver PWM may act as agents appointed with various life, disability or other insurance companies, receive commissions, trails, or other compensation from the respective product sponsors and/or as a result of effecting insurance transactions for clients. However, clients should note that they are under no obligation to purchase any insurance products through us or our IARs. Please note that IARs spend less than 10% of their time on business relating to Insurance. FINANCIAL INSTITUTION CONSULTING SERVICES – MUTUAL SECURITIES Our Firm has contracted directly with Mutual Securities and will receive payments to provide investment advisory consulting services to the clients of those contracted financial institutions which could be insurance companies or broker dealers. Such contractual engagements do not include assuming discretionary authority over brokerage accounts or the monitoring of securities. Services offered to financial institution clients may include a general review of client investments holdings, which may or may not result in our investment adviser representatives making specific securities recommendations or offering general investment advice. ACCOUNTING SERVICES Some IARs of the firm are CPAs who provide tax services to individuals and corporations. The IARs will receive additional compensation for the tax services performed by the CPA related work. Any fees received through the tax services do not offset advisory fees the client may pay for advisory services under our Firm. Clients should note that they have the right to decide whether or not to engage in services with the CPA and at all times our Firm and its IARs will act in your best interest and as fiduciary in carrying out services provided to you. ITEM 11 – CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Page 18 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  Denver PWM and persons associated with us are allowed to invest for their own accounts or to have a financial interest in the same securities or other investments that we recommend or acquire for your account and may engage in transactions that are the same as or different than transactions recommended to or made for your account. This creates the potential for a conflict of interest. We recognize the fiduciary responsibility to place your interests first and have established policies in this regard to avoid any potential conflicts of interest. We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, the prohibition against the use of inside information and other situations where there is a possibility for conflicts of interest. The Code of Ethics is designed to protect our clients by deterring misconduct, educate personnel regarding the firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and must act with complete propriety at all times, protect the reputation of Denver PWM, guard against violation of the securities laws, and establish procedures for personnel to follow so that we may determine whether their personnel are complying with the firm’s ethical principles. We have established the following restrictions in order to ensure our firm’s fiduciary responsibilities: • No director, officer or employee of Denver PWM shall prefer his or her own interest to that of the advisory client. • We maintain a list of all securities holdings and anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of Denver PWM. • We emphasize the unrestricted right of the client to decline to implement any advice rendered, except in situations where we are granted discretionary authority of the client’s account. • We emphasize the unrestricted right of the client to select and choose any Custodian (except in situations where we are granted discretionary authority) he or she wishes. • We require that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. • Any individual not in observance of the above may be subject to termination. You may request a complete copy of our Code by contacting us at the address, telephone or email on the cover page of this Part 2; Attn: Chief Compliance Officer. ITEM 12 – BROKERAGE PRACTICES THE CUSTODIAN AND BROKERS WE USE Clients must maintain assets in an account at a “qualified custodian,” generally a Custodian or bank. We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”, “Custodian”), a registered Custodian, member SIPC, as the qualified custodian. We are independently owned and operated, and unaffiliated with Page 19 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that clients use Schwab as custodian/broker, client must decide whether to do so and open accounts with Schwab by entering into account agreements directly with them. We will open accounts with Schwab on the client’s behalf and will notify the client in writing of the custodian’s name, address, and the title of the account, promptly when the account is opened and following any changes to this information. The accounts will always be held in the name of the client and never in Denver PWM’s name. Even though clients maintain accounts at Schwab, we can still use other brokers to execute trades for client accounts (see Client Brokerage and Custody Costs, below). HOW WE SELECT BROKERS/CUSTODIANS We seek to recommend a custodian/broker who will hold client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for client accounts) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, and stability • Prior service to Denver PWM and our other clients • Availability of other products and services that benefit us, as discussed below (see Products and Services Available to Us from Schwab) CLIENT BROKERAGE AND CUSTODY COSTS For our clients’ accounts that Schwab maintains, Schwab generally does not charge separately for custody services. However, Schwab receives compensation by charging ticket charges or other fees on trades that it executes or that settle into clients’ Schwab accounts. In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different Custodian but where the securities bought or the funds from the securities sold are deposited (settled) into a Page 20 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  client’s Schwab account. These fees are in addition to the ticket charges or other compensation the client pays the executing Custodian. Because of this, in order to minimize trading costs, we have Schwab execute most trades for client accounts. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see How We Select Brokers/Custodians). PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like us. They provide Denver PWM and our clients with access to its institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts; others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis (we do not have to request them) and at no charge to us. SERVICES THAT BENEFIT OUR CLIENTS Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit our clients and their accounts. SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS Schwab also makes available to us other products and services that benefit us but may not directly benefit our clients or their accounts. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab 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 • Assist with back-office functions, recordkeeping, and client reporting SERVICES THAT GENERALLY BENEFIT ONLY US Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: Page 21 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. OUR INTEREST IN SCHWAB’S SERVICES The availability of these services from Schwab benefits us because we do not have to produce or purchase them. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions. We believe that our selection of Schwab as custodian and broker is in the best interests of our clients. Some of the products, services and other benefits provided by Schwab benefit Denver PWM and may not benefit our client accounts. Our recommendation or requirement that you place assets in Schwab’s custody may be based in part on benefits Schwab provides to us, or our agreement to maintain certain Assets Under Management at Schwab, and not solely on the nature, cost or quality of custody and execution services provided by Schwab. We place trades for our clients’ accounts subject to its duty to seek best execution and its other fiduciary duties. We may use Custodians other than Schwab to execute trades for your accounts maintained at Schwab, but this practice may result in additional costs to clients so that we are more likely to place trades through Schwab rather than other Custodians. Schwab’s execution quality may be different than other Custodians. BROKERAGE FOR CLIENT REFERRALS Denver PWM does not receive client referrals from any Custodian or third party in exchange for using that Custodian or third party. AGGREGATION AND ALLOCATION OF TRANSACTIONS Denver PWM may aggregate transactions if we believe that aggregation is consistent with the duty to seek best execution for our clients and is consistent with the disclosures made to clients and terms defined in the client investment advisory agreement. No advisory client will be favored over any other client, and each account that participates in an aggregated order will participate at the average share price (per custodian) for all transactions in that security on a given business day. Denver PWM does not aggregate trades of our personnel with those of client accounts. Page 22 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis. If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we will base the allocation on other relevant factors, which may include: • When only a small percentage of the order is executed, with respect to purchase allocations, allocations may be given to accounts high in cash; • With respect to sale allocations, allocations may be given to accounts low in cash; • We may allocate shares to the account with the smallest order, or to 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; • We may allocate to one account when that account has limitations in its investment guidelines prohibiting it from purchasing other securities that we expect to produce similar investment results and that can be purchased by other accounts in the block; • If an account reaches an investment guideline limit and cannot participate in an allocation, we may reallocate shares to other accounts. For example, this may be due to unforeseen changes in an account’s assets after an order is placed; • If 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 and disgorge any profits. Generally, de Minimis allocations do not exceed 5% of the total allocation. Additionally, we may execute the transactions on a pro-rata basis. • We will document the reasons for any deviation from a pro-rata allocation. TRADE ERRORS From time to time, our Firm may make an error in submitting a trade order on your behalf. When this occurs, we may place a correcting trade with the Custodian of your account. If an investment gain results from the correcting trade, the gain will remain in your account unless the same error involved other client accounts that should have received the gain, it is not permissible for you to retain the gain, or we confer with you, and you decide to forgo the gain (e.g. due to tax reasons). If the gain does not remain in your account and Charles Schwab & Co. Inc. is the Custodian, Charles Schwab & Co. Inc. will donate the amount of any gain $100 and over to charity. If a loss occurs greater than $100, our Firm will pay for the loss. Charles Schwab & Co Inc. will maintain the loss or gain (if such gain is not retained in your account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in your account, they may be netted. We do not select or recommend Custodians based on receiving client referrals from a Custodian or third party. We do not routinely recommend, request, or require that you direct us to execute transactions through a specified broker dealer. Additionally, we typically do not permit you to direct brokerage. We place trades for your account subject to our duty to seek best execution and other fiduciary duties. We may use Custodians other than your custodian to execute trades for your account, but this practice may result in additional costs to you so that we are more likely to place trades through your custodian rather than other Custodians. Your custodian’s execution quality may be different than other Custodians. Page 23 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  As a matter of policy and practice, we do not utilize research, research-related products and other services obtained from Custodians, or third parties, on a soft dollar commission basis. ITEM 13 – REVIEW OF ACCOUNTS ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES The underlying securities within the investment supervisory services are regularly monitored. These reviews will be made by your individual Investment Advisor and are reviewed by Brian Rettig, our firm’s CCO. An annual review is usually conducted in person or by telephone. The purpose of all these reviews is to ensure that the investment plan continues to be implemented in a manner that matches your objectives and risk tolerances. More frequent reviews may be triggered by material changes in variables such as your individual circumstances or the market, political, or economic environment. You are urged to notify us of any changes in your personal circumstances. Documentation of reviews shall be maintained. STATEMENTS AND REPORTS We will have the ability to provide clients with Performance/Position summary reports upon request. Reports may also be provided at every client meeting. The custodian for the individual client’s account will also provide clients with an account statement at least quarterly. You are urged to compare the reports provided by us against the account statements you receive directly from your account custodian. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION As disclosed under Brokerage Practices, we participate in Schwab’s institutional customer program, and we may recommend Schwab to you for custody and brokerage services. There is no direct link between our participation in the program and the investment advice we give to our clients, although we receive economic benefits through our participation in the program that are typically not available to any other independent Investment Advisors participating in the program. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving Advisor participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to an electronic communications network for Client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third party vendors. Page 24 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  Schwab may also have paid for business consulting and professional services received by some of our related persons. Some of the products and services made available by Schwab through the program may benefit us but may not benefit your account. These products or services may assist us in managing and administering your account, including accounts not maintained at Schwab. Other services made available by Schwab are intended to help us manage and further develop our business enterprise. The benefits received by us or our personnel through participation in the program do not depend on the amount of brokerage transactions directed to Schwab. As part of our fiduciary duties to clients, we endeavor at all times to put the interests of our clients first. You should be aware, however, that the receipt of economic benefits by us or our related persons in and of itself creates a potential conflict of interest and may indirectly influence our choice of Schwab for custody and brokerage services. From time to time, we may receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing such as advertising, publishing and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. IARs endeavor at all times to put the interest of our clients first as a part of their fiduciary duty. However, you should be aware that the receipt of additional compensation through expense reimbursements creates a conflict of interest that may impact the judgment of the IARs when making advisory recommendations. We do not directly or indirectly compensate any person who is not a supervised person for client referrals. NON-CASH REFERRAL ARRANGEMENTS Our Firm may be asked to recommend a financial professional, such as an attorney, accountant, or mortgage broker. In such cases, our Firm does not receive any direct compensation in return for any referrals made to individuals or firms in our professional network. Clients must independently evaluate these firms or individuals before engaging in business with them and clients have the right to choose any financial professional to conduct business. Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm does not pay any direct compensation in return for any referrals made to our Firm. Our Firm does recognize the fiduciary responsibility to place your interests first and have established policies in this regard to mitigate any conflicts of interest. ITEM 15 – CUSTODY Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. Page 25 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  We are deemed to have custody of client funds and securities whenever we are given the authority to have fees deducted directly from client accounts. However, this is the only form of custody we will ever maintain. It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. For accounts in which we are deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from us. When you have questions about your account statements, you should contact us, your Advisor or the qualified custodian preparing the statement. STANDING LETTERS OF AUTHORIZATION While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further described below under “Standing Instructions”. All our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodians: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. Page 26 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ITEM 16 – INVESTMENT DISCRETION Prior to engaging our firm to provide investment advisory services, you will enter into a written Agreement with us granting the firm the authority to supervise and direct, on an on-going basis, investments in accordance with the client’s investment objective and guidelines. In addition, you will need to execute additional documents required by the Custodian so as to authorize and enable Denver PWM, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange securities in and for your accounts. We are authorized, at our discretion and without prior consultation with you, to (1) buy, sell, exchange, and trade any stocks, bonds, or other securities or assets and, (2) determine the amount of securities to be bought or sold and (3) place orders with the custodian. Any limitations to such authority will be communicated by you to us in writing. The limitations on investment and brokerage discretion held by Denver PWM for you are: • For discretionary clients, we require that we be provided with authority to determine which securities and the amounts of securities to be bought or sold. • Any limitations on this discretionary authority shall be included in this written authority statement. You may change/amend these limitations as required. Such amendments shall be submitted in writing. ITEM 17 – VOTING YOUR SECURITIES We will not vote proxies under our limited discretionary authority. You are welcome to vote proxies or designate an independent third-party at your own discretion. You designate proxy voting authority in the custodial account documents. You must ensure that proxy materials are sent directly to you or your assigned third party. We do not take action with respect to any securities or other investments that become the subject of any legal proceedings, including bankruptcies. ITEM 18 – FINANCIAL INFORMATION This item is not applicable to this brochure. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. Page 27 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management  Page 28 MAY 2025 | DENVER PWM, LLC | dba Denver Private Wealth Management