EDGEROCK CAPITAL LLC

Item 1 – Cover Page Form ADV Part 2A: Brochure 7001 East Belleview Avenue Suite 800 Denver, CO 80237 Telephone: 303-780-7350 August 6, 2025 This brochure provides information about the qualifications and business practices of EdgeRock Capital LLC d/b/a EdgeRock Wealth Management (“EdgeRock”, “us”, “we” or “our”). If you have any questions about the contents of this brochure, please contact us by telephone at 303-780-7350 or by email at dtc@edgerockwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration as an investment adviser with the SEC or with any state securities authority does not imply any level of skill or training. Additional information about EdgeRock is also available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2 – Summary of Material Changes • EdgeRock has updated this brochure in Item 4 – Advisory Business, to reflect our December 31, 2024 Assets Under Management. • EdgeRock has updated Item 4 – Advisory Business, the Financial Planning & Consulting Services section has been updated. • EdgeRock has added language in Item 4 – Advisory Business, to update our investment types we advise on, adding Digital assets and Crypto Funds. • Management of ‘Held Away’ Accounts in Item 4 – Advisory Business, EdgeRock offers investment management of accounts that are not held directly at our custodian(s) and we bill separately for these services. • EdgeRock has updated Item 5 – Fees and Compensation, by adding the section: Financial Planning & Consulting Services. EdgeRock now offers Financial Planning via a sperate agreement and separate fee. • EdgeRock has updated Item 5 – Fees and Compensation, by adding the section: Fees - Held Away Accounts. • EdgeRock has added enhanced language around types of securities offered in Item 8 – Methods Of Analysis, Investment Strategies and Risk Of Loss. Additionally, specific risks around Cryptoassets have been added. • EdgeRock has added language in Item 17 – Voting Fund Securities that we will not advise on legal proceedings of securities. 2  Item 3 – Table of Contents ITEM 1 – COVER PAGE ........................................................................................................................................... 1 ITEM 2 – MATERIAL CHANGES… .................................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS…………………………………………………………….....….3 ITEM 4 – ADVISORY BUSINESS ....................................................................................................4 ITEM 5 – FEES AND COMPENSATION .......................................................................................8 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................. 9 ITEM 7 – TYPES OF CLIENTS .......................................................................................................9 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....10 ITEM 9 – DISCIPLINARY INFORMATION ................................................................................ 16 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................ 16 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN FUND TRANSACTIONS AND PERSONAL TRADING ......................................................................... 17 ITEM 12 – BROKERAGE PRACTICES ......................................................................................... 18 ITEM 13 – REVIEW OF ACCOUNTS ........................................................................................... 20 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ....................................... 21 ITEM 15 – CUSTODY ..................................................................................................................... 21 ITEM 16 – INVESTMENT DISCRETION.................................................................................... 22 ITEM 17 – VOTING FUND SECURITIES .................................................................................... 22 ITEM 18 – FINANCIAL INFORMATION .................................................................................... 22 3  ITEM 4 – ADVISORY BUSINESS EdgeRock Capital LLC, a Colorado limited liability company, is based in Englewood, CO. EdgeRock Capital LLC was established 2018 and conducts its advisory business under the name EdgeRock Wealth Management (“EdgeRock”, “us”, “we” or “our”). Kyle F. O’Dell is our President and principal owner. EdgeRock offers the following services to advisory clients: Investment Supervisory Services EdgeRock offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. EdgeRock develops an investment strategy for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring EdgeRock evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. EdgeRock provides portfolio management services on a discretionary basis, which means we can select securities and place orders with broker-dealers to execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented for each client. Clients are responsible for notifying us of any updates regarding their financial situation, risk tolerance or investment objective and whether they wish to impose or modify existing investment restrictions; however we contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them that is different from the advice we provide to you, or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients. Under certain circumstances, conflicts arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. 4  Retirement Account Rollovers When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An employee may use a combination of those options, such as; (i) leave the funds in the former employer’s plan, if permitted, (ii) roll over the funds to a new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the individual’ s age, result in adverse tax consequences). If your designated IAR recommends that you rollover your retirement plan assets into an account to be managed by our firm, such recommendation creates a conflict of interest insofar as we will earn an advisory fee on the rolled over assets. You are under no obligation to roll over retirement plan assets to an account managed by us. Financial Planning & Consulting Services EdgeRock offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. We provide full written financial plans, which typically address one or more the following topics: investment planning, retirement planning, insurance planning, education planning, portfolio review, and asset allocation. When providing financial planning and consulting services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. Your investment adviser representative will rely on information provided by you. Therefore, issues and information not provided will not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a written financial plan. You must promptly notify our firm if your financial situation, goals, objectives, or needs to be updated. We offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation. You are under no obligation to act on our financial planning recommendations. Should you choose to implement any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. 5  EdgeRock provides Financial Planning and Consulting Services as a separate, a la carte service. Model Portfolio Solutions EdgeRock offers model portfolio selection services, which allows EdgeRock to exercise discretion to select model portfolios managed by the EdgeRock investment committee and/or third-party unaffiliated investment managers. An investment adviser representative will assist you in completing a client profile questionnaire and review the information you provide. We will then select the model portfolio(s) that aligns with your disclosed risk tolerance and investment objectives. We will be available at reasonable times to answer questions that you may have regarding your account. We will have the ability to select the model portfolio(s) as well as the ability to reallocate funds from or to the model portfolio(s) and funds in other accounts over which you have granted us discretionary authority. You should be aware that there may be other model portfolios not recommended by our firm, that are suitable for you and that may be less costly than arrangements recommended by our firm. No guarantees can be made that your financial goals or objectives will be achieved through our model program or by a recommended/selected model portfolio. Further, no guarantees of performance can ever be offered by our firm (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details.) Use of Independent Managers We may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. EdgeRock will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with the Client’s investment objectives and overall best interests. The Client, prior to entering into an agreement with an unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Newsletters EdgeRock occasionally prepares general, educational and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Newsletters are provided to clients and prospective clients at no charge. Workshops EdgeRock occasionally provides workshops in areas such as financial planning, retirement planning, estate planning, college planning, and charitable planning. Seminars are always offered on an impersonal basis and do not focus on the individual needs of participants. Attendees are asked to reimburse EdgeRock only for the cost of workshop handbooks and printout materials purchased in advance by EdgeRock. Webinars EdgeRock occasionally prepares webinars for its clients and prospective clients that present information in areas such as financial planning and current market developments. Webinars are always offered on an impersonal basis and do not focus on the individual needs of participants. No fees are charged for Webinars. Webinars can only be accessed via electronic invitation. 6  Tailored Advisory Services to Individual Needs of Clients EdgeRock’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose reasonable restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Management of ‘Held Away’ Accounts EdgeRock uses the third-party platform within Fidelity Brokerage Services LLC via a service called Brokerage Link. (collectively referred to as “Third Party Platform”) to manage “held away” accounts. A held away account is an account that you maintain that is not held with a broker-dealer or custodian where we have a custodial relationship or where we provide investment management services where our firm cannot bill the ‘held away’ account on directly. For example, a 401(k)-account sponsored by your employer is a held away account. Prior to us managing any held away account, you will be provided with a link allowing you to connect one or more accounts to the platform and allow us to manage your investments on your behalf. Once an account is connected to the platform, we will review the current allocations, and when deemed necessary, we will rebalance the account to the target asset allocation. When clients engage EdgeRock in this capacity, they are responsible to keep the Third Party Platform link active, so that EdgeRock will be able to access and manage the respective account without delay. If EdgeRock determines that an Order Management System link has become inactive, EdgeRock will use its best efforts to notify the client to resolve the issue. Limited Advice for Certain Types of Investments EdgeRock provides investment advice on the following types of investments: • Mutual Funds • Exchange-listed Securities • US Government Securities • Fixed Income Securities • Exchange Traded Funds (ETFs) • Structured Notes • Real Estate Investment Trusts (REITs) • Options • Limited Partnerships • Digital assets and Crypto Funds Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. Under certain circumstances, we will modify our investment strategy to accommodate special situations such as low cost basis 7  stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) As of December 31, 2024, EdgeRock managed approximately $470,476,415 on a discretionary basis. ITEM 5 – FEES AND COMPENSATION Investment Supervisory Services Our standard annual fee, based on a percentage of your assets under our management, follows the table below: Less than $500,000.00 From $500,000.00 to $999,999.99 From $1,000,000.00 to $2,999,999.99 $3,000,000.00 or above 1.50% 1.35% 1.20% 1.00% Investment management fees are payable monthly in advance. Fees charged for our direct asset management services are charged based on the market value of assets under management at the end of the prior calendar month. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. Investment management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor, via its delegate (Envestnet) shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the month. The amount due is calculated by applying the annual rate divided by the number of days in the year multiplied by the number of days in the upcoming month to the total assets under management with EdgeRock at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by EdgeRock to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. In certain limited instances, a client may be invoiced for wealth management fees. In addition, under certain circumstances, you will incur certain charges imposed by third parties other than EdgeRock in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, management fees, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by EdgeRock are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. For Clients with accounts[s] allocated to an Independent Manager, the Client’s overall fee will be deducted from the Client’s account[s] with the respective Independent Manager and a portion of the fee will be provided to EdgeRock based on EdgeRocks’s investment advisory agreement with the Client. EdgeRock is responsible for 8  negotiating the fees with the Independent Manager on behalf of the Client. EdgeRock does not receive any compensation or fees from the Independent Manager. Limited Negotiability of Advisory Fees: Although EdgeRock has established the standard fee schedule mentioned above, we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the written investment advisory agreement between EdgeRock and each client. Termination Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the month. In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and that Independent Manager. EdgeRock will assist the Client with the termination and transition as appropriate. Fees - Held Away Accounts Fees for held away accounts managed through a Third Party Platform are calculated and billed separately from our advisory fees and are outlined in your investment advisory agreement. Fees are debited from your taxable accounts or billed directly, also as disclosed in your investment advisory agreement. If you terminate our services in the middle of a billing period, we will refund you for any fees received during partial billing periods. Fees - Financial Planning & Consulting Services We charge a fixed fee for financial planning services, which generally ranges between $0 to $75,000. The first half of the estimated fee is due in advance of services rendered with the remaining balance payable upon completion of the contracted services. The fee is negotiable depending upon the complexity and scope of the plan, your financial situation, and your objectives. You may terminate the financial planning agreement upon written notice to our firm. If you have pre-paid financial planning fees that we have not yet earned, you will receive a prorated refund of those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee based on services performed prior to termination of the financial planning agreement. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT EdgeRock does not charge any performance‐based fees, which are fees based upon a share of capital gains on or capital appreciation of the assets of a client. ITEM 7 – TYPES OF CLIENTS EdgeRock provides investment advisory services to individuals, high net worth individuals, 401(k) plans, corporations and charitable organizations. EdgeRock has a minimum account size of $80,000 but is subject 9  to management’s discretion. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis and Investment Strategies EdgeRock uses the following methods of analysis in formulating investment advice: Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong, and could therefore lead to an unfavorable investment decision. Technical – This method evaluates securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly, since future trading volume is an unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. There are risks involved in using any analysis method. To conduct the analysis, EdgeRock gathers information from financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, 10  prospectuses and filings with the SEC, and company press releases. Investment Strategies EdgeRock uses the following investment strategies when managing client assets and/or providing investment advice: Long term purchases: Investments held at least a year. Long term investing is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term purchases: Investments held for less than a year. Short term investing is designed to minimize risk factors such as market volatility and interest rate risk, while still attempting to earn a rate of return. EdgeRock will recommend this type of investing to clients that have an alternate use for their capital within a 3-12 month time frame. Tactical asset allocation. A tactical asset allocation strategy allows for a range of percentages in each asset class (such as Stocks = 40-50%). The ranges establish minimum and maximum acceptable percentages that permit the investor to take advantage of market conditions within these parameters. Thus, a minor form of market timing is possible, since the investor can move to the higher end of the range when stocks are expected to do better and to the lower end when the economic outlook is bleak. Strategic asset allocation. A strategic asset allocation strategy calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. Value Investing. Value Investing can be described as a strategy of selecting stocks that trade for less than their intrinsic values. Value investors typically seek stocks of companies that they believe the market has undervalued. They believe the market overreacts to good and bad news, resulting in stock price movements that do not correspond with the company's long-term fundamentals. The result is an opportunity for value investors to profit by buying when the price is deflated. Often, value investors select stocks with lower-than-average price-to-book or price-to-earnings ratios and/or high dividend yields. The risks associated with value-investing include incorrectly analyzing and overestimating the intrinsic value of a business, concentration risk, under performance relative to major benchmarks, macro-economic risks, investing in value traps i.e. businesses that remain perpetually undervalued, and lost purchasing power on cash holdings in the case of inflation. Primarily Recommend One Type of Security We do not primarily recommend one type of security to clients. Instead, we recommend any product that may be suitable for each client relative to that client’s specific circumstances and needs. Risks of Specific Securities Utilized EdgeRock generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. 11  Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above). Interval Funds: An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. Equity Investments: Equity investment generally refers to buying shares of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the investment may incur a loss (sometimes up to a 100% loss in the case of a bankruptcy of a stock holding). Treasury Inflation Protected/Inflation Linked Bonds: The risk of default on these bonds is dependent upon the U.S. Treasury defaulting on its obligations (which is extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Fixed Income: Fixed income is an investment in debt securities that guarantees fixed periodic payments in the future that may involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of principal risk, etc. Fixed income securities carry risks such as the possibility of default on the principal, fluctuation in interest rates, and counterparties being unable to meet obligations. Exchange Traded Funds (“ETF” or “ETFs”): Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investing in Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) also carries the risk of capital loss. Structured Notes: Structured notes are complex instruments consisting of a bond component and an imbedded derivative component that adjusts the security’s risk-return profile. There are both principal-at- risk and principal-protected notes. Principal-protected notes offer full principal protection, subject to the credit risk of the issuer, even if the market is down at the note’s maturity. Principal-at-risk notes offer no principal protection, and an investor can lose some or all of their invested principal at maturity. A structured note will result in loss of principal if the reference asset declines by more than the stated buffer or barrier level, either at maturity, or on a scheduled observation date. Structured notes are classified as senior unsecured debt and are therefore subject to the risk of default. They lack liquidity, are not listed on securities exchanges, and do not participate in dividends. Typically, the issuer will maintain a secondary market; but there is no obligation to do so. Therefore, there may be little to no secondary market available. To the extent a secondary market may exist, a sale in the secondary market prior to maturity may result in a significant discount in the sale price of the note resulting in a loss of principal. Structured notes are also 12  subject to credit and call risks. The credit risk involves a situation where, if the issuer were to default on its payment obligations, you may not receive any amount owed under the structured note and you could lose your entire principal investment. Certain notes may be callable automatically or at the option of the issuer. If a note is called, the investor will not receive any interest payments that would have been payable for the remainder of the term of the note. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, or market volatility. After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity. Real Estate Investment Trusts (“REITs”): REITs have specific risks including valuation due to cash flows, dividends paid in stock rather than cash, and the payment of debt resulting in dilution of shares. Options: Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Limited Partnerships: The performance of limited partnership investments can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Cryptoassets Risk: Among other risks associated with Cryptoassets, the prices of Cryptoassets can be and have been extremely volatile, and crypto asset exchanges have been closed due to fraud, failure, or security breaches. Cryptoassets are created, issued, transmitted, and stored according to protocols run by computers in Cryptoasset networks. It is possible that these protocols have undiscovered flaws which could result in the loss of some or all Cryptoassets held by the Client. The following list of Cryptoasset risks is meant to be informative of the specific risks of Cryptoassets, but should not be considered a comprehensive list: • Cryptoassets do not have stable values. Cryptoassets represent a speculative investment and involve a high degree of risk. As relatively new products and technologies, Cryptoassets have not been widely adopted as a means of payment for goods and services by major retail and commercial outlets. Conversely, a significant portion of the demand for Cryptoassets is generated by speculators and investors seeking to profit from the short‐ or long-term holding of Cryptoassets. The relative lack of acceptance of Cryptoassets in the retail and commercial marketplace limits the ability of end clients to pay for goods and services with Cryptoassets. A lack of expansion by Cryptoassets into retail and commercial markets, or a contraction of such use, may result in increased volatility. Prices of the Cryptoassets have fluctuated widely for a variety of reasons and may continue to experience significant price fluctuations. Several factors may affect the price of the Cryptoassets, including, without limitation: (i) total Cryptoassets in existence; (ii) global Cryptoasset supply and demand; (iii) Clients’ expectations with respect to the rate of inflation of fiat currencies; (iv) currency‐ and crypto asset‐exchange rates; (v) interest rates; (vi) fiat currency withdrawal and deposit policies of the Cryptoasset exchanges; (vii) trade volume and liquidity on crypto asset exchanges; (viii) interruptions, suspensions, or terminations of major crypto asset exchanges; (ix) cyber theft of Cryptoassets from online Cryptoasset wallet providers, or news of such theft from such providers, or theft from individual Cryptoasset wallets; (x) investment and trading activities of hedge funds and other large Cryptoasset investors; (xi) sovereign monetary policies, trade restrictions, and inflation controls; (xii) regulatory measures that affect the usability of Cryptoassets as a form of legal tender and/or otherwise restrict or facilitate Cryptoasset purchases, sales, or holdings; (xiii) availability and popularity of businesses that provide crypto asset‐related services; (xiv) development and maintenance of open‐source software protocols for crypto asset networks, applications or platforms; (xv) increased competition from other payment services; and (xvi) domestic and foreign political, economic, and financial events and/or uncertainty. If crypto asset markets continue to be 13  subject to high volatility, Clients may experience losses based on their investments. Even if Clients are able to hold their Cryptoassets for long, potentially indefinite periods, their Cryptoassets may never generate a profit. Additionally, Clients should be aware that there is no assurance that the Cryptoassets will maintain their long‐ term value in terms of future purchasing power. • Prior performance of a Cryptoasset is not necessarily indicative of future results. Many Cryptoassets have experienced high levels of performance and rapid increases in price, followed by significant downturns in performance and similarly rapid decreases in price. • Cryptoassets may not have long‐term viability. Cryptoassets are a new and relatively untested product. There is considerable uncertainty about their long‐ term viability, which could be affected by a variety of factors, including many market‐based factors such as economic growth, inflation, and others. In addition, the success of Cryptoassets will depend on the long‐term utility and economic viability of blockchain and other new technologies related to Cryptoassets. Due in part to these uncertainties, the price of Cryptoassets are volatile and may be hard to sell. Our firm does not control any of these factors, and therefore may not be able to control the ability of any Cryptoasset to maintain its value over time. • The value of Cryptoassets is uncertain and may not match the price a Client pays. Cryptoassets derive their value from a variety of factors, including demand for the crypto asset associated with its utility or functionality. Additionally, value is affected by demand for the Cryptoasset from speculators. If too many speculators invest in Cryptoassets the value of the Cryptoassets may not correspond to the price at which the Cryptoassets are exchanged. The value of Cryptoassets may in particular be subject to momentum pricing and therefore, an inaccurate valuation. Momentum pricing typically is associated with growth stocks and other assets whose valuation, as determined by the investing public, accounts for anticipated future appreciation in value. The price of a Cryptoasset is determined primarily using data from various currency exchanges, over‐the‐counter markets, and derivative platforms. Momentum pricing of Cryptoassets has resulted, and may continue to result, in speculation regarding future appreciation in the value of the Cryptoassets, inflating and making more volatile the price of such Cryptoassets. The Cryptoassets that lead the market may be subject to even more speculation. In addition, the value of the Cryptoassets on trading venues that are largely unregulated may be inaccurate and the rules or regulations that apply to such trading venues are subject to change, which may result in the listing of the Cryptoassets held by a Client to be removed from certain trading venues, further obscuring the valuation of such Cryptoassets. • Innovations in the Cryptoasset industry may cause the Cryptoassets purchased by our firm on behalf of a Client to lose value. The development and acceptance of the cryptographic and algorithmic protocols governing the issuance of and transactions in Cryptoassets is subject to a variety of factors that are difficult to evaluate and predict. The use of Cryptoassets to, among other things, buy and sell goods and services is part of a new and rapidly evolving commercial practice that employs digital assets based on a computer‐ generated mathematical and/or cryptographic protocol. The growth of this commercial practice in general, and the use of Cryptoassets in particular, is subject to a high degree of uncertainty. Factors affecting further development of the Cryptoasset industry include, among other things, the continued worldwide adoption of Cryptoassets; governmental and quasi‐governmental regulation of Cryptoassets and/or crypto asset exchanges; changing consumer demographics, tastes and preferences; sustained development and maintenance of open‐source software protocols; the popularity and availability of alternative and/or new payment services; and general economic conditions. If these factors negatively affect or impede the development of the Cryptoasset industry, the value of a Client’s investment in Cryptoassets may also be negatively affected. Cryptoassets may be negatively affected by technological advances that undermine the cryptographic consensus mechanism underpinning blockchain and distributed ledger protocols. Advances in cryptography or technical advances such as the development of quantum computing could present risks to the viability of Cryptoassets by undermining or vitiating the cryptographic consensus mechanism that underpins blockchain and distributed ledger protocols. Similarly, legislators could prohibit the use of current and/or future cryptographic protocols. 14  • Cryptoassets may rely on third‐party blockchains. Certain Cryptoassets may rely on or are built on a public or third‐party blockchain and the success of such blockchain may have a direct impact on the success of Cryptoassets. These Cryptoassets are partly dependent on the effectiveness and success of such blockchains, as well as the success of other blockchain and decentralized data storage systems that are being used by the issuer of the Cryptoassets. There is no guarantee that any of these systems or their sponsors will continue to exist or be successful. This could lead to disruptions of the operations of the issuer of Cryptoassets offered and could negatively affect any Cryptoassets held by a Client from such issuer. • Geopolitical events may affect the value of Cryptoassets. The impact of geopolitical events on the supply and demand for Cryptoassets is uncertain. As an alternative to fiat currencies that are backed by central governments, digital assets such as Cryptoassets, which are relatively new, are subject to supply and demand forces based in part upon the desirability of an alternative, decentralized means of buying and selling goods and services. It is unclear how such supply and demand will be impacted by geopolitical events. Nevertheless, political or economic crises may motivate large‐ scale acquisitions or sales of Cryptoassets globally and/or locally. Large‐scale sales of Cryptoassets are likely to result in a reduction in the value of Cryptoassets and may adversely affect a Client’s investment in Cryptoassets. • Cryptoassets do not have insurance protections. Any Cryptoassets held in Client accounts are not subject to any protections provided by the U.S. Federal Deposit Insurance Corporation (the “FDIC”) or the U.S. Securities Investor Protection Corporation. This means that Cryptoassets will not be insured by the FDIC’s Deposit Insurance Fund. In addition, Cryptoassets are not subject to any protections provided by any private insurance company, and it is unclear if and when Cryptoassets in Client accounts will be covered by any insurance protections. • Regulatory changes may affect the value of Cryptoassets. Regulation of Cryptoassets in the U.S. and in foreign jurisdictions is in its early stages of development and is subject to unpredictable changes which may have an adverse impact on the Cryptoassets offered by Fidelity Digital Assets Services, LLC. The regulatory status of Cryptoassets remains unclear or unsettled in many jurisdictions. Legislative and regulatory changes or actions at the local, state, federal, foreign, or international level may adversely affect the use, transfer, exchange, and value of Cryptoassets. These legislative and regulatory changes or actions are difficult to predict and may adversely impact the Cryptoassets offered. As Cryptoassets have grown in popularity and market size, U.S. legislators and regulators have begun to develop laws and regulations and have, at times, released interpretive guidance governing the crypto asset industry. Both legislators and regulators have expressed concerns that Cryptoassets can be used by criminals to evade taxes and launder money. To the extent that future actions by legislators and/or regulators impose restrictions or limitations on the crypto asset market, the demand for Cryptoassets is likely to be reduced. In addition, such actions may limit the ability of Clients to convert Cryptoassets into fiat currency or use Cryptoassets to pay for goods and services, which, in each case, is likely to result in a reduction of demand and, in turn, a decline in the value of Cryptoassets. Additional or changing regulations could also limit the use of Cryptoassets on various Cryptoasset platforms. Such reductions in use could decrease or remove the value of the functionality achieved on those platforms and cause a substantial decrease in the value of the Cryptoassets. Various foreign jurisdictions may adopt laws, regulations, or directives that address the Cryptoasset market and participants in such market. Any such laws, regulations, or directives may (i) conflict with those of the U.S., (ii) negatively impact the acceptance of Cryptoassets inside and outside the U.S., (iii) impede the growth or sustainability of the Cryptoasset market in foreign jurisdictions, and/or (iv) otherwise negatively affect the value of Cryptoassets. These laws, regulations or directives, if any, are impossible to predict, but any such change could be substantial and adverse to the value of investments made by Clients in Cryptoassets. Regulation of Cryptoassets in the U.S. varies by state, and the regulations of certain states may limit the ability of firms to operate within those states. The different regulations by state could affect the transferability of Cryptoassets. To the extent that state regulations differ, certain Cryptoassets may only be tradable in specific states. This could decrease the demand for and market for Cryptoassets. • Clients should not count on any protection or guarantees from federal or state securities laws with respect to Cryptoassets. Many Cryptoassets, including Cryptoassets offered through Fidelity Digital Assets Services, 15  LLC, are not registered with or qualified by the SEC. Although EdgeRock is registered under the Advisers Act and Clients are provided certain protections from fraud under applicable securities laws, Clients will generally not otherwise be afforded the full set of protections provided under the Securities Act of 1933 (the “Securities Act”), Securities Exchange Act of 1934, other federal securities laws or comparable state law with respect to any Cryptoassets held in Client accounts. Thus, Clients should not expect any protection under the Securities Act. Further, if a regulator were to find that a Cryptoasset should have been registered under the Securities Act or state law, it could disrupt the market in that Cryptoasset. If regulators were to take action related to a Cryptoasset that a Client has invested in, it could decrease the value of the Cryptoasset or lead to a determination that the transaction in the Cryptoasset is void. Further, Technological, operational, or other failures, system outages, or errors suffered by Fidelity Digital Assets Services, LLC could result in loss of Client Cryptoassets. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. ITEM 9 – DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. Neither EdgeRock nor any of its supervised persons have been the subject of any legal or disciplinary event that would be material to your evaluation of the integrity of EdgeRock or that of its management. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS EdgeRock is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, a lawyer or law firm, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. We are an independent registered investment adviser and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. Insurance Brokerage Affiliation Kyle F. O’Dell, President of EdgeRock, is also the sole owner of Secure Wealth Strategies, Inc. (“Secure Wealth”), a life insurance brokerage. Secure Wealth continues to receive separate customary compensation for life insurance previously sold through that brokerage, however no new life insurance policies are sold or offered through Secure Wealth. Insurance Business through EdgeRock Wealth Management, LLC and Advisors Excel, LLC EdgeRock Capital, LLC is an affiliate of EdgeRock Wealth Management, LLC which utilizes Advisors Excel, LLC (“AE”) to provide insurance-based solutions to clients. EdgeRock Wealth Management, LLC and EdgeRock Capital, LLC are under common control and ownership. EdgeRock Wealth Management, LLC and EdgeRock Capital, LLC are not affiliated with AE. AE is an independent marketing organization that markets/wholesales life insurance and fixed annuities to third-party insurance agents in exchange for a marketing and/or override fee from the issuer of such life insurance/annuity products. The investment adviser representatives of EdgeRock who serve in a separate capacity as life insurance agents utilize the marketing and wholesaling services of AE. 16  As a client of EdgeRock, your investment adviser representative will also serve as a life insurance agent. This means your investment adviser representative, acting as a life insurance agent, will recommend you place your assets in life insurance products and annuities when he or she believes it is in your best interest to do so. These life insurance products and annuities pay commissions to your investment adviser representative in his or her separate capacity as an insurance agent. This presents a conflict of interest to your investment adviser representative as he or she will be more inclined to recommend you place your assets in life insurance, annuity products or an advisory account depending on which would pay them more. As such, your investment adviser representative acting in his or her separate capacity as a life insurance agent, can suggest that you implement recommendations which include purchasing life insurance or annuities products which are marketed and wholesaled by AE. This receipt of commissions creates an incentive for the investment adviser representative to recommend those products in his or her separate capacity as a life insurance agent. Likewise, the marketing-override payments received by AE also create an incentive for EdgeRock to encourage the recommendation of life insurance and annuity products marketed and wholesaled by AE. As a result of the above, the advice rendered to you could be biased. In the event your investment adviser representative will receive a commission in relation to a recommended product, that fact will be disclosed to you. Commissions are built into the product pricing and are not directly paid by you in the form of a reduction of premium amount. Commissions are set by the applicable life insurance carrier but will typically range from 4-7.5% of the total premium. Investment adviser representatives are eligible to receive incentives and other compensation based on achieving life insurance carrier and third-party (which include affiliates of AE) criteria related to life insurance/annuity transactions, including your life insurance product purchase. These incentives are determined by criteria set by the life insurance carrier or third party. The incentives likely include, but are not limited to: gifts, meals, or entertainment of reasonable value, participation in bonus programs, reimbursement for training, marketing, educational efforts, advertising, or travel expenses to conferences or events sponsored by third parties or life insurance carriers. EdgeRock and our representatives always endeavor to put the interests of each of our clients first. You are under no obligation to implement any life insurance or annuity transaction through your investment adviser representative in his or her capacity as a life insurance agent or utilize life insurance or annuity products wholesaled by AE. EdgeRock has taken steps to manage these conflicts of interest by requiring that each investment adviser representative (i) only recommend life insurance and annuities when in the best interest of the client and without regard to the financial interest of EdgeRock and its investment adviser representative or life insurance agents, (ii) not recommend life insurance and/or annuities which result in your investment adviser representative acting as an life insurance agent and/or an affiliated life insurance agency receiving unreasonable compensation related to the recommendation and (iii) disclose in writing to a client any material conflicts of interest related to life insurance or annuity recommendations. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN FUND TRANSACTIONS AND PERSONAL TRADING We have adopted a Code of Ethics for all employees of the firm describing our high ethical standards of business conduct, including those of applicable Federal and State securities laws. Our Code of Ethics includes policies and procedures relating to maintaining the confidentiality of client information, a prohibition on insider trading, and personal securities trading and review procedures, among other things. Our employees must certify at least annually their receipt, understanding and compliance with our Code of Ethics. A copy of our Code of Ethics is available to our advisory clients and prospective clients, upon request to the Chief 17  Compliance Officer, at the firm’s principal office address. Personal Securities Transactions Disclosure At times, Associated persons of EdgeRock buy or sell for their personal accounts, investment products identical to those recommended to clients. This can create a conflict of interest. It is the express policy of EdgeRock that all persons associated in any manner with my firm must place clients’ interests ahead of their own when implementing personal investments. EdgeRock and its associated persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. To eliminate or mitigate potential conflicts of interest, we have developed written policies and procedures and a Code of Ethics that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, associated persons): • Associated persons cannot prefer their own interests to those of EdgeRock clients. • Associated persons cannot purchase or sell any security for their personal accounts prior to implementing transactions in the same securities for client accounts. • Associated persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment, unless that information is also available to the investing public upon reasonable inquiry. • Associated persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”. • Associated persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted to the Chief Compliance Officer of EdgeRock. Any associated person not observing our policies is subject to sanctions up to and including termination. ITEM 12 – BROKERAGE PRACTICES EdgeRock considers the following factors when determining which broker-dealer or custodian to recommend to clients: • Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with existing systems, ease of monitoring investments) • Products and services offered (e.g., number of mutual funds/ETFs offered, back-office services, technology support) • Financial strength and stability • Reputation and integrity • Ability to maintain confidentiality. Soft Dollars In selecting or recommending broker-dealers, we consider the value research and additional brokerage products and services a broker-dealer has provided or will provide to our clients and our firm. Receipt of these additional brokerage products and services are considered to have been paid for with "soft dollars." When client brokerage commissions (or markups or markdowns) are used for these brokerage products and services, they provide a benefit to our firm because we do not have to produce or pay for the same brokerage products and services, which creates a potential conflict of interest in directing your brokerage business. We 18  have an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our clients’ interest in receiving most favorable execution. To mitigate this potential conflict, before placing orders with a particular broker-dealer, we determine that the commissions to be paid are reasonable in relation to the value of all the brokerage and research products and services provided by that broker-dealer. In some cases, the commissions charged by a particular broker for a particular transaction or set of transactions may or may not be greater than the amounts charged by another broker-dealer that did not provide research services or products. In addition, we have instituted certain procedures governing soft dollar relationships including preparation of a mandated reporting of soft dollar irregularities, annual evaluation of soft dollar relationships, and an annual review of this brochure to ensure adequate disclosures of conflicts of interest regarding our soft dollar relationships. Products and services we receive from broker-dealers includes proprietary and third-party research data and analyses, financial publications, recommendations, or other information about particular companies and industries (through research reports and otherwise), and other products or services (e.g., software and databases) that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Consistent with applicable rules, brokerage products and services consist primarily of computer services and software that permit our firm to effect securities transactions and perform functions incidental to transaction execution. We use such products and services in our general investment decision making, not only for those accounts for which commissions are deemed to have been used to pay for the products or services. The products and services we receive from broker-dealers are used in servicing our clients' accounts. Our use of these products and services will not be limited to the accounts that paid commissions to the broker-dealer for such products and services. In addition, we may not allocate soft dollar benefits to your accounts proportionately to the soft dollar credits the accounts generate. As part of our fiduciary duty to you, we endeavor at all times to put your interests first. As an adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products are in addition to any benefits or research we pay for with soft dollars. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may (or may not) be greater than the amounts another broker who did not provide research services or products might charge. Our use of soft dollars is in accordance with the requirements of Section 28(e) of the Securities Exchange Act of 1934. Section 28(e) provides a "safe harbor" for investment managers who use commissions or transaction fees paid by their advised accounts to obtain investment research services that provide lawful and appropriate assistance to the manager in performing investment decision-making responsibilities. As required by Section 28(e), we will make a good faith determination that the amount of commission or other fees paid is reasonable in relation to the value of the brokerage and research services provided. In making this determination, we typically consider not only the particular transaction or transactions, and not only the value of brokerage and research services and products to a particular client, but also the value of those services and products in our performance of our overall responsibilities to all of our clients. Selection of Broker-Dealers and Custodians We recommend the brokerage and custodial services of National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity"). Clients are advised that there may be transaction charges 19  involved when purchasing or selling securities. Our firm does not share in any portion of the brokerage fees/transaction charges imposed by Fidelity. Additionally, the commission/transaction fees charged by Fidelity may be higher or lower than those charged by other broker-dealer/custodians. EdgeRock has the discretionary authority to determine the broker-dealer to be used, however it does not have the discretionary authority to determine the commission rates to be paid for brokerage transactions. EdgeRock is not affiliated with Fidelity. Not all advisers require clients to direct brokerage. When a client directs brokerage, EdgeRock may be unable to achieve most favorable execution of client transactions, and this practice could cost clients more money. For example, in a directed brokerage account, the client may pay higher brokerage commissions because EdgeRock may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. Best Execution Seeking best execution for our clients is an important aspect of our fiduciary duty. Consequently, we have controls in place to monitor trade executions. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution considering the factors we review, including the quality of services provided by broker-dealers including the quality of executions, commission rates, accuracy and speed of execution, and overall brokerage relationships. Although the commissions and/or transaction fees paid by our clients typically correspond with our duty to obtain best execution, at times, clients will pay a commission that is higher than what another qualified broker -dealer might charge to effect the same transaction when we determine, in good faith, that the commission or transaction fee is reasonable in relation to the value of the brokerage and research services we receive from a particular broker-dealer we recommend. Best execution is also about pricing, not just fees. Accordingly, although we seek competitive rates from the broker-dealers we recommend, we may not necessarily obtain the lowest possible commission rates for client transactions. The brokerage commissions or transaction fees charged by the broker-dealer are exclusive of, and in addition to, our investment management fee. Our best execution responsibility is qualified if the securities we purchase are no-load mutual funds that are traded at net asset value as determined at the daily market close. Block Trading Typically, we implement client transactions separately for each account. Consequently, certain client trades will be executed before others, at a different price and/or commission rate. Additionally, our clients may not receive volume discounts available to advisers who aggregate client trades (a practice known as “block trading”). There are instances where we block trade for clients where possible and when advantageous to clients. In these instances, clients participating in any aggregated transactions will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. Agency Cross Transactions Our associated persons are prohibited from engaging in agency cross transactions, meaning we cannot act as brokers for both the sale and purchase of a single security between two different clients and cannot receive compensation in the form of an agency cross commission or principal mark-up for the trades. ITEM 13 – REVIEW OF ACCOUNTS Investment Supervisory Services While the underlying securities within Investment Supervisory Services accounts are continually monitored, these accounts are reviewed typically each quarter, but no less frequently than annually by EdgeRock. Accounts are reviewed in the context of each client's stated investment objectives and guidelines, as well as their assets under management. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. 20  In addition to the monthly or quarterly statements and confirmations of transactions that Investment Supervisory Services clients will receive from their custodian, EdgeRock may provide written quarterly reports summarizing account performance, balances and holdings. We urge clients to compare reports received from their custodians to those received from EdgeRock. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION EdgeRock has an arrangement with Fidelity through which Fidelity provides EdgeRock with Fidelity's "platform" services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like EdgeRock in conducting business and in serving the best interests of their clients but that may benefit EdgeRock.. Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Fidelity enables EdgeRock to obtain many no-load mutual funds without transaction charges and other no load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to EdgeRock, at no additional charge to EdgeRock, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by EdgeRock (within specified parameters). As a result of receiving such services for no additional cost, EdgeRock may have an incentive to continue to use or expand the use of Fidelity's services. EdgeRock examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of EdgeRock’s clients and satisfies its client obligations, including its duty to seek best execution. A client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where the EdgeRock determines in good faith that the commission is 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 broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although EdgeRock will seek competitive rates, to the benefit of all clients, it may not necessarily obtain the lowest possible commission rates for specific client account transactions. Although the investment research products and services that may be obtained by EdgeRock will generally be used to service all of EdgeRock’s clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. EdgeRock and Fidelity are not affiliates, and no broker-dealer affiliated with EdgeRock is involved in the relationship between EdgeRock and Fidelity. It is EdgeRock's policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. ITEM 15 – CUSTODY EdgeRock is deemed to have constructive custody of client funds as the result of debiting investment advisory fees from separately managed accounts. Physical custody of client funds are maintained at a qualified custodian. Debiting of fees is done pursuant to authorization provided by each individual client and approval of the custodian. No less than quarterly, individual clients will receive account statements directly from the custodian of their account. Custodial statements include account holdings, market values and any activity that occurred during the period, including the deduction of investment advisory fees. Copies of account statements are sent to EdgeRock and available to EdgeRock electronically. In the event that EdgeRock provides individual client reports, EdgeRock urges clients to compare information contained in such reports with the account statements received directly from the account custodian. At times, a client’s portfolio value will appear different between the custodian statement and the EdgeRock report due to various factors, including but not limited to: (1) unsettled trades; (2) accrued income; (3) pricing of securities; and, (4) dividends earned but not received. 21  ITEM 16 – INVESTMENT DISCRETION EdgeRock will maintain ongoing and continuous discretionary authority, pursuant to its written investment advisory agreements with clients, to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Such clients will have the ability to direct the types of assets in which client funds may be invested, and, as described in more detail in Item 4, will have the ability to impose reasonable restrictions on the investment of their account. Discretionary clients grant EdgeRock discretionary authority through limited power of attorney in their investment advisory agreement with EdgeRock to arrange for the execution of securities transactions for the account through brokers or dealers as directed by each client. ITEM 17 – VOTING FUND SECURITIES EdgeRock will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. We may provide clients with consulting assistance regarding proxy issues if clients contact us with questions. Other Legal Actions EdgeRock will not advise or act on behalf of any Clients in any legal proceedings, including bankruptcies or class action suits, involving securities held or previously held or the issuers’ securities. ITEM 18 – FINANCIAL INFORMATION EdgeRock does not require prepayment of more than $1,200 in fees per client six months or more in advance and therefore we do not need to include a balance sheet with this brochure. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients, and we have not been the subject of a bankruptcy proceeding. 22