First Affirmative Financial Network LLC

Summary of Material Changes to the Apex Clearing Wrap Fee Brochure, Appendix 1C Consistent with SEC rules, annual updates that are material in nature are required to be provided to all clients of First Affirmative Financial Network, LLC DBA Formative (“Formative”) through a “Material Changes” document within 120 days of the close of the firm’s fiscal year, which is the calendar year. Throughout the year, all clients will be provided with additional information about material changes, as necessary. This summary of the material changes to the Apex Clearing Wrap Fee Brochure, Appendix 1C and ADV Disclosure Brochure (Summary of Material Changes) is intended to provide you with sufficient information to determine whether you would like to review the Apex Wrap Fee Brochure, Appendix 1C and ADV Disclosure Brochure in their entirety. You can obtain an electronic copy of the current Apex Wrap Fee Brochure, Appendix 1C and ADV Disclosure Brochure and this Summary of Material Changes in a publicly accessible area on the Formative website at www.firstaffirmative.com or by contacting Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov. You can search the SEC’s website for information about a registered investment advisor (RIA) by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. First Affirmative Financial Network, LLC’s doing business as (DBA) name, is Formative. 

Form ADV Part 2A – Appendix 1C April 17, 2026 Apex Clearing, Inc. Wrap Fee Brochure for Clients and Prospective Clients of First Affirmative Financial Network, LLC DBA Formative Item 1: Introduction and Overview This Wrap Fee Brochure provides information about the qualifications and business practices of First Affirmative Financial Network, LLC DBA Formative (“Formative”). Capitalized terms not defined in this Wrap Fee Brochure are defined in Formative’s Form ADV Part 2A (Disclosure Brochure). Formative is an independent, employee-owned, and managed investment advisor registered (RIA) with the U.S. Securities and Exchange Commission (SEC) with its principal place of business at 5475 Mark Dabling Boulevard, Suite 320, Colorado Springs, CO 80918. The fact that Formative is registered with the SEC should not be read as an endorsement of Formative or that Formative has a certain level or training. This Wrap Fee Brochure is required to be delivered to any prospective client of the Formative sponsored wrap fee program involving Apex Clearing, Inc. (Apex) prior to or at the time of entering into an investment advisory relationship with Formative that includes participation in the wrap program with Apex Clearing, Inc. (Apex) (Apex Wrap Fee Program). Formative also sponsors a wrap fee program with Goldman Sachs Advisor Solutions, (Goldman Sachs) (Goldman Sachs Wrap Fee Program). A separate Wrap Fee Brochure is available for clients whose investment advisory relationship with Formative includes participation in the Formative sponsored wrap fee program involving Orion Portfolio Solutions, (OPS) (Orion Wrap Fee Program). A separate Wrap Fee Brochure is available for clients whose investment advisory relationship with Formative includes participation in the OPS Wrap Fee Program. An electronic copy is available on a publicly accessible area on the Formative website www.firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov.You can search the SEC’s website for information about an RIA by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. You can also access an electronic copy of this document in a publicly accessible area on the Formative website www.firstaffirmative.com. If you have any questions about the contents of this Wrap Fee Brochure, please contact Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. While submitted to the SEC, the information in this Wrap  Fee Brochure has not been approved or verified by the SEC or by any state securities authority. Item 2: Material Changes Consistent with SEC rules, Formative updates this Wrap Fee Brochure at least annually, within 90 days of the close of its fiscal year, which is December 31. If there are material changes from the prior annual update of this Wrap Fee Brochure, and you received a prior version of this Wrap Fee Brochure, such changes will be set forth in the “Summary of Material Changes” accompanying this Wrap Fee Brochure. Item 4: Services, Fees, and Compensation Description of the Apex Wrap Fee Program The Apex Wrap Fee Program applies to discretionary investment advisory services offered by Formative, through its Network Advisors or Solicitors/Endorsers (as defined in the Disclosure Brochure), consistent with its Sustainable Investment Solutions advisory offering (as described in the Disclosure Brochure). Formative serves as a manager of our Values Aligned Direct Index Solution (VADIS) and Managed Mutual Fund (MMF) Account Manager described below. As the Manager of VADIS accounts, Formative, with respect to accounts custodied at Apex, only recommends Proprietary Portfolios to clients. VADIS accounts are customized for each individual client. An example of our billing method can be found in the Disclosure Brochure. Wrap Fee for the Apex Wrap Fee Program – Fiduciary The Apex Wrap Fee Program fee includes all costs for investment management, impact preferences, trade execution, and custody and clearing, unless specifically noted as a separate charge below. Fees on assets included in the Apex Wrap Fee Program are charged as a percentage of assets under management, annualized, in arrears, using the average daily balance calculation method. Fees are charged on a quarterly basis according to the schedule below. Fees for services provided by Network Advisors or Solicitors/Endorsers are in addition to the fees presented below and will be collected along with the fees as described below as part of the wrap fee.  Cumulative (For Internal Use) Formative: Managed Mutual Funds Tiers Apex: Custody & Clearing Formative: VADIS including YourStake Impact Preferences Platform On the First 2,000,000 2,000,000 0.36% 0.31% 0.08% On the Next 8,000,000 10,000,000 0.31% 0.26% 0.08% On the Next 10,000,000 20,000,000 0.26% 0.21% 0.08% Above 20,000,000 0.26% 0.21% 0.08% New accounts are subject to the following minimums: VADIS Accounts: $25,000 Managed Mutual Fund Accounts: $50,000 These minimums are negotiable on a case-by-case basis and are dependent on a variety of factors, including but not limited to other accounts in a client household (adults who all live at the same address who have investment accounts with Formative). Accounts billed for the same program, on the same custodial platform, will be grouped together for breakpoints unless such grouping is prohibited by regulatory rule or Internal Revenue Service (IRS) restrictions. Additional information on the billing process is available in the Disclosure Brochure. The Wrap Fee may be more or less than the aggregate fee for services if they were offered separately. Some factors that may contribute to the relative cost differential include, but are not limited to, the brokerage and clearing costs, commissions based on trading frequency or commissions based on type of security (e.g., mutual fund or ETF versus single stock), and the mutual fund share classes that may be available. Mutual Fund Expenses Mutual funds have internal expenses, such as portfolio management, legal and accounting, printing, marketing, trading costs and other administrative expenses, including fees paid to custodians. Fund expenses are more fully disclosed in each mutual fund prospectus. They are accounted for and charged internally by the mutual funds and monies collected or retained are not shared with Formative, any affiliate of Formative or any Network Advisor or  Solicitor/Endorser. Any mutual fund sale within a defined period of time may, per the mutual fund prospectus, after the initial purchase, trigger a contingent deferred sales charge by the mutual fund company on the transaction. These charges vary among the mutual funds that are held in a client account. Incidental Fees Apex RIA Miscellaneous Services Pricing Term Sheet Pricing Current as of May 1, 2021 Fees are subject to change without notice. Miscellaneous Services fees are amounts due to Apex and do not count towards any minimum charges you may owe to Apex. Customer Charged Miscellaneous Services. A. Retirement: Annual IRA Maintenance Fee (See Advisor Agreement) IRA Closing Fee $60 per account B. Banking: Outgoing Wire Transfers (Domestic Bank) $25.00 per wire Outgoing Wire Transfers (Foreign Bank) $50.00 per wire Paper Check Draft (Domestic) $5.00 per check Paper Check Draft (International) $10.00 per check Returned Checks, ACH, Wires and Recalls $30.00 per item (including amendments/repairs) ACH Notice of Correction $5.00 per notice Stop Payments on Apex Issued Checks $30.00 each Check Copies $15.00 each Third Party Distribution Notifications $2.00 per notification Third Party Journal (TPJ) $0.05 per journal C. Operations: Electronically Delivered Documents Confirms-No Charge Statements-No Charge Tax Statements-No Charge Postage and Handling (Paper Only) Confirms $2.00 per confirm Statements (Monthly and Quarterly $5.00 per statement Outgoing ACAT Transfers $75.00 per account Incoming ACAT Transfers-No Charge Limited Partnerships/Private Placements (IRA only) $250.00 per investment Margin If you choose to trade using margin, your account will be assessed the margin interest charges in accordance with the margin interest rates in effect at the time of your margin loan and as disclosed by your Network Advisor.  Compensation for Accounts Under Title I of the Employee Retirement Income Security Act (ERISA) Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its owners, officers, investment advisor representatives, or employees when providing advisory services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. The Department of Labor’s Rule 3.0, known as the Fiduciary Rule, requires investment fiduciaries to review the costs associated with rolling over ERISA plan assets to another retirement vehicle. A conflict of interest occurs if the advisor earns a new fee or its current compensation increases because of the rollover. There also is the possibility of conflicts of interest between clients and any Network Advisor if the service is provided for variable compensation. Formative offers fee-based compensation which tends to reduce or change the possibility of conflicts of interest but cannot eliminate them entirely. While it is Formative’s intent to always offer advice that is in the best interest of the client, it is the client’s responsibility to evaluate that advice and determine if it is appropriate before acting. No client is obligated to accept any recommendation, including recommendations regarding rollovers, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. Mutual Fund Company Payments to Custodians Rule 12b-1 fees are defined as annual marketing or distribution fees on mutual funds. These expenses are included in the fund’s expense ratio and are in some cases shared with custodians. Formative may place trades in mutual funds that pay compensation to custodians. 12b-1 fees paid to custodians are not shared with Formative. As part of Formative’s fiduciary duty, we will evaluate the costs associated with mutual funds to determine which fund, or share class of a fund, is most suitable for client portfolios. If appropriate, Formative will exchange share classes to a less expensive share class. In taxable accounts these exchanges will be made, whenever possible, in conjunction with the fund companies as tax-free exchanges. Additional Apex Fees Fees Upon Termination of Services Apex may charge a termination or transfer-out fee on accounts, which may change from time to time. This fee is determined by Apex and the monies received are not shared with Formative. Mutual Fund Transaction Commissions Charged to Clients Some mutual funds that are included in client investment portfolios offer different types of shares, known as “share classes.” Each share class has different shareholder services and/or  distribution arrangements with different fees and expenses and, therefore, different performance results. For example, class A shares, also called “retail shares”, usually have a front-end load or charge (commission) which is paid to the custodial BD when the mutual fund is purchased. Institutional class shares, in contrast, generally are available only to institutional investors and may have very different fees and expenses from class A shares, but generally do not require front-end commissions. See the SEC website, the Financial Industry Regulatory Authority website or the relevant mutual fund share prospectus for additional information regarding share classes. Formative generally uses only institutional class shares with no front-end loads in the Managed Mutual Fund Accounts and, to the extent it does use a mutual fund that typically has a front- end load, Formative will do so only if the front-end load is waived. Compensation to Network Advisors and Solicitors/Endorsers relating to Client Participation in the Apex Wrap Fee Program Network Advisors and Solicitors/Endorsers are compensated from the Wrap Fee. The amount of this compensation may be more or less than the compensation they may receive if not recommending, or introducing the client to, the Apex Wrap Fee Program. This may create a conflict of interest in that the Network Advisor or Solicitor/Endorser may have a financial incentive to recommend the Apex Wrap Fee Program over other programs and services. Indirect Compensation Specific to Custodians. Formative is charged an annual fee per client account to Orion Advisor Technology (OAT) for the use of their Astro platform. This technology allows us to design, implement, and reoptimize portfolios. Formative employs this technology for accounts held at each of our approved custodians. The Formative service fees charged to the Client are the same for each platform except for OPS. Item 5: Account Requirements and Types of Clients Formative does not accept clients that are under any restriction as it relates to the USA Patriot Act or Bank Secrecy Act or comparable legislation. The minimums for wrap fee accounts at Apex are: VADIS Accounts: $25,000 Managed Mutual Fund Accounts: $50,000 These minimums are negotiable on a case-by-case basis and are dependent on a variety of factors, including but not limited to other accounts in a client household (adults who all live at the same address that have investment accounts with Formative). Accounts in the same  program, on the same custodial platform, will be grouped together for breakpoints unless such grouping is prohibited by regulatory rule or Internal Revenue Service (IRS) restrictions. Additional information on the billing process is available in the Disclosure Brochure. The following types of clients may participate in the Apex Wrap Fee Program: Individuals (to include high net worth individuals) • • Trusts, estates, and charitable organizations • Nonprofit organizations and other non-governmental organizations • Corporations or other businesses not listed above Item 6: Portfolio Manager Selection and Evaluation Use of Proprietary Models As noted above, Formative makes available Proprietary Models on the Apex Platform that may be used by Network Advisors and Solicitors/Endorsers in the process of providing investment advisory services in the Apex Wrap Fee Program. Formative manages the VADIS accounts and the managed mutual fund models on a proprietary basis. One IAR is a member of Formative senior management and the Investment Committee. In his role, he provides investment advisory services to individual clients, while also working on developing Proprietary Models. Proprietary Models developed by this IAR are subject to the same selection and review process as other Third- Party Models and other Proprietary Models. Further, he does not receive compensation relating to his development of Proprietary Models. Formative’s Advisory Business – Fiduciary Formative provides investment advice consistent with sustainable and responsible investing philosophies, making use of available values-aligned data. Clients who choose to invest with Formative make a conscious choice to put their money to work for a dual purpose—to provide for a secure retirement, for example, while working for a better, more socially just, and environmentally sustainable future for all. Through Network Advisors and Solicitors/Endorsers (as defined in the Disclosure Brochure) Formative provides discretionary investment advisory services to investors, tailored to the individual needs of the client, that integrate values criteria into the investment analysis process according to the clients’ preference. Formative can create portfolios, using mutual funds, and/or individual securities such as stocks, bonds, exchange traded funds (ETFs), exchange traded notes (ETNs), real estate investment trusts (REITs), American depository receipts (ADRs), government agency or Treasury securities, corporate or municipal bonds, certificates of deposit (CODs), commercial paper or other securities. The different investment programs offered by Formative may not all offer the ability to invest in all the securities listed above. Formative does  not offer discretionary investment advisory services concerning direct ownership of commodities, futures, derivatives, or short selling. Discretionary Investment Advisory Services – Sustainable Investment Solutions in Practice Discretionary Investment Advice Through its Network Advisors and Solicitors/Endorsers (as defined in the Disclosure Brochure) Formative creates unique relationships with clients by combining discretionary investment advisory services and advanced financial technologies with responsible investment strategies that consider values-aligning factors. Generally, Formative’s innovative approach combines: Fiduciary Responsibility. In Formative’s relationship with clients where Formative is providing discretionary investment advice, Formative acknowledges that it serves and acts in a fiduciary capacity under the Investment Advisers Act of 1940. When we provide investment advice to you regarding your retirement plan account or individual retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests. Under both rules Formative and the Network Advisors and Solicitors/Endorsers we work with operate in your best interest and do not place their needs ahead of yours. The types of rollovers include an existing Retirement Plan to an IRA; an existing IRA to a Retirement Plan; an employer Retirement Plan to a new employer Retirement Plan; an IRA to an IRA; and a change from one retirement account type to another type, including from commission billing to fees. Individualized Advice. One size does not fit all. Formative offers a variety of fee-based investment options, each designed to best meet the needs of individual clients and/or specific types of clients. The client has the opportunity to place reasonable restrictions on the types of investments to be held in the client account. Objectivity. Network Advisors and Solicitors/Endorsers provide their clients with objective advice. Fees for account management are generally based on assets under management and, as a result, the client’s interests, the interests of the Network Advisor, Solicitor/Endorser, and the interests of Formative are closely aligned. Wrap Fee Program Participation Formative participates in a wrap fee program – sponsored by Geneos Wealth Management,  Inc., (Axiom) by making its Proprietary Models available on the platform. The Proprietary Models on the Axiom platform are required to meet certain criteria set by Axiom and any models listed are subject to ongoing reviews. Formative constructs such models with the same investment philosophy and process as it uses in other Proprietary Models. However, the included securities are restricted to securities that are approved by Axiom and are consistent with Axiom’s asset allocation strategies and model construction guidelines. Formative exercises no discretion with respect to clients subscribed to the model portfolios but may receive an asset-based fee when a model constructed by Formative is used by Axiom or a representative of Axiom in making a recommendation to a client. Retirement Plan Consulting Services Formative may offer the services listed below to individuals and charitable organizations who need assistance with pension, profit sharing, and 401(k) plans for an hourly or one-time fee. This assistance will be reviewed against the Five Part Test developed by the Department of Labor to determine if it rises to the status of fiduciary advice. The DOL Fiduciary Rule requirements will be met, if applicable. The services are comprised of the following non- discretionary consulting services: • Education about investment vehicles for the plan trustees; and • Provision of educational support and investment workshops to self-directed 401(k) plans participants. Formative does not provide investment advisory services to participants in retirement plans where it provides services to the plan. Formative is compensated for its retirement plan consulting services either based on an hourly rate as negotiated between Formative and the plan sponsor or a fee charged based upon assets under advisement by the asset custodian. Formative’s Advisory Business – Non-Fiduciary Formative provides non-fiduciary services to Network Advisors on a limited basis. These services are not available on the Apex platform. Performance-Based Fees Formative does not charge performance-based fees.  Methods of Analysis, Investment Strategies, Risk of Loss Investment Philosophy Formative follows an established investment management process consistent with standards of fiduciary care and with long-term orientation. Formative’s experience suggests that the financial planning and investment needs of most socially conscious investors can be met while providing competitive investment returns without a material increase in risk. For most clients, Formative believes that a long-term, diversified approach is the most appropriate investment strategy. Formative supports strategic asset allocation as well as more active portfolio management strategies. Formative does not offer recommendations concerning direct ownership of commodities, futures, derivatives, or short selling, but does offer tactical investment strategies appropriate for some investors. Formative may use the following types of investment vehicles in service of achieving client goals and objectives. • American depository receipts (ADRs) • Certificates of deposit • Commercial paper • Corporate bonds • Exchange traded funds (ETFs) • Exchange traded notes (ETNs) • Government agency securities • Individual stocks • Municipal bonds • Mutual funds • Options on equities • OTC securities • Other exchange traded securities • Private placements • Real estate investment trusts (REITs) • Warrants Methods of Analysis Formative may use the following forms of analysis in formulating investment advice and/or managing client assets: Asset Allocation. Rather than focusing primarily on securities selection, Formative attempts to identify an appropriate ratio of equities and fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector if it is not included in their allocation. Another risk is that the ratio of equities and fixed income, and cash will change over time due  to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Charting. In this type of technical analysis, charts of market and security activity are to identify when the market is moving up or down, to predict how long the trend may last, and when that trend might reverse. While this is a common method of analysis, there is always the risk that past performance is not representative of future results or that the assumptions made prove to be incorrect. Cyclical Analysis. In this type of technical analysis, the movements of a particular stock against the overall market are analyzed in an attempt to predict the price movement of the security. There always is the risk that past performance is not representative of future results or that the assumptions made prove to be incorrect. Fundamental Analysis. The intrinsic value of a security is analyzed by reviewing economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (suggesting it may be a good time to buy) or overpriced (suggesting it may be a good time to sell). Fundamental analysis does not attempt to anticipate market movements or changes in value. There is risk in the fact that the price of a security can rise or fall along with the overall market, regardless of the economic and financial factors considered in evaluating the stock. Mutual Fund and/or ETF Due Diligence. Formative’s Mutual Fund and Multi-Manager Model formation process incorporates the objectivity of quantitative analysis and the insights of fundamental research. This two-pronged approach begins with our proprietary Mutual and Model Fund Scores, which encompass both financial and sustainability factors. Formative utilizes these Scores as the foundation for in-depth manager reviews. In one-on-one conversations, we assess individual managers to ensure their investments are aligned with our and our clients’ personal values, social priorities, and mission. We do this by analyzing the firm, portfolio management and research teams, investment process, and values integration methodology, as well as proxy voting, corporate actions, and engagement. Finally, we construct well-diversified portfolios designed to deliver risk-adjusted returns to enable investors to achieve their financial goals. We diversify – across asset classes, geographies, sectors, styles, and market capitalizations – to mitigate risk. Well-diversified and structurally sound, our values-aligned Sustainable Investment Solutions are constructed with the probability of enabling our clients to achieve their investment objectives. Fiduciary duty is at the heart of our investment philosophy. Qualitative Analysis. This type of analysis describes the process of evaluating difficult to quantify factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price  based on that data. A risk in using qualitative analysis is that our subjective judgment may prove to be incorrect. Quantitative Analysis. Mathematical modeling is used in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Risks for all Forms of Analysis and Due Diligence. Formative’s securities analysis methods rely on the assumption that the companies whose securities Formative purchases and sells, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While Formative is alert to indications that data may be incorrect, there is always a risk that analysis may be compromised by inaccurate or misleading information. Technical Analysis. Historical market movements are analyzed, and that analysis is applied to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. Risk is inherent in the fact that a poorly managed or financially unsound company may underperform regardless of market movement. Third-Party Model Manager and/or Sub-Advisor Due Diligence. Formative examines the experience, expertise, investment philosophies, and past performance of independent Third- Party Model Managers and/or Sub-Advisors in an attempt to determine if there has been demonstrated ability to invest over a period of time and in different economic conditions. Formative monitors the Third-Party Model Manager’s model holdings, strategies, concentrations, and leverage as part of its overall periodic risk assessment. Additionally, as part of Formative’s due-diligence process, it surveys a Third-Party Model Manager’s or Sub-Advisor’s compliance and business enterprise risks. A risk of investing using Third-Party Model Manager and/or Sub-Advisors who have been successful in the past is that they may not be able to replicate that success in the future. In addition, as Formative does not control the underlying investments in a Third-Party Model Manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for clients. Moreover, as Formative does not control the manager’s daily business and compliance operations, Formative may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Values-Aligned Direct Index Solution (VADIS). VADIS attempts to replicate the performance of an index by purchasing the underlying individual equities instead of using an ETF or mutual fund in an investor’s portfolio. Formative’s portfolio construction expertise and discretionary investment advisory services may be implemented using our carefully vetted Impact  Preferences, or combined with YourStake’s values-aligned client assessment, data collection and organization, analytics, and reporting capabilities for investors who seek alignment of personal values factors into investment portfolios that attempt to replicate the performance of a chosen benchmark in our Values Aligned Direct Index Solutions. Our VADIS Portfolios are constructed using the Orion Astro platform or the YourStake Platform using client-specific inputs provided by the investment advisor. These inputs include but are not limited to: • Impact Preferences, which may include individual or lists of companies chosen by the client for exclusion or inclusion in the portfolio Benchmarks are a combination of the ACWI/AGG aligned with one of our seven risk levels. We may offer custom benchmarks at the request of the Network Advisor for accounts greater than $1,000,000. Investment strategy constraints and client preferences, such as: • Maximum number of securities • Desired tracking error, security count, and security exposure • Turnover, and trade thresholds, size, and number • Existing legacy positions, specific-company inclusions/exclusions • Tax considerations Values-Aligned Integration. A sustainable and responsible approach to investing includes both quantitative and qualitative analysis. Our investment process integrates analysis of environmental, social, and corporate governance factors in portfolio design. Management of environment, social, and governance issues and impacts can have a material influence (either positive or negative) on company profitability, value, and share price. Risk is inherent in the fact that a poorly managed or financially unsound company or product may cause the investment to underperform regardless of its mission. Investment Strategies Formative may use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among other considerations: Illiquid Securities. Formative may, from time to time, assist clients with analyzing investments in securities in the areas of unlisted and/or unregistered debt or equity (commonly referred to as “private placements”), which have no current or anticipated liquidity. Formative will provide investment advice on such securities that have been approved by its due diligence and investment approval processes. When analyzing investments in securities of this type Formative will use the following analysis: fundamental, qualitative, quantitative, and risk.  Long-Term Purchases. Formative may purchase securities with the intention of holding them in the client’s account for a year or longer. Typically, this strategy is employed when: • Formative believes the securities to be currently undervalued, and/or • Formative wants exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, Formative may not take advantage of short-term gains that could be profitable to a client. Moreover, if Formative’s predictions are incorrect, a security may decline sharply in value before the decision is made to sell. Short-Term Purchases. When utilizing this strategy, Formative may purchase securities with the idea of selling them within a relatively short time (typically a year or less). Formative does this in an attempt to take advantage of conditions that it believes will soon result in a price swing in the securities purchased. A short-term purchase strategy poses risks should the anticipated price swing not materialize; Formative is then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy; and may result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short- term capital gains. Risk of Loss Investing involves risk, including loss of principal. Each client of Formative must be prepared to bear the risk of loss with respect to each account established. Proxy Voting Owners of company stock and mutual fund shares have a right to be heard on matters put before shareholders for a vote. Shareholder voting is the primary means by which shareholders can influence a company or mutual fund’s operations, its corporate governance, and other activities that may fall outside of financial considerations. You have provided Formative discretion in managing your accounts, we will vote your proxies consistent with our Proxy Voting Guidelines, except in the circumstances described below or if you instruct us that you do not wish for Formative to vote your proxies. Your Network Advisor or Solicitor/Endorser will direct you to the Formative Proxy Voting Guidelines at the time you open your account with us and annually thereafter. These guidelines are also available on our website at all times and upon request as described below. We believe one of the reasons you have chosen Formative to provide you advisory services is our  commitment to socially responsible investing, which includes voting proxies consistent with this philosophy, as is reflected in our Proxy Voting Guidelines. Therefore, you must notify us in writing and instruct us how you would like us to vote your proxies if you do not want them voted as described in the Proxy Voting Guidelines. To assist with proxy voting, Formative has an arrangement with an independent governance analysis and proxy voting firm to provide research to Formative and to vote proxies based on Formative’s Proxy Voting Guidelines. The independent third-party firm will vote all holdings in which Formative clients have a material interest, defined as all shares held at Schwab, Goldman Sachs, SEI, and Apex. Formative does not vote proxies at any other custodians. As described above, voting of client proxies is based upon social responsibility concerns, as well as financial considerations, as reflected in the Proxy Voting Guidelines which are updated at least annually. The independent third-party proxy voting service discloses to Formative, at least annually, potential conflicts of interest between their research/proxy voting services and their corporate governance consulting services and their procedures for limiting such conflicts. Clients should be aware that they are under no obligation to assign proxy voting duties to Formative. Clients may choose from proxy voting options that are offered by their custodian. For example, accounts held at Goldman Sachs offer a client the right at any time, even if proxy voting has been delegated to Formative, to vote any individual proxy themselves and override any vote that may be cast by the proxy voting service hired by Formative. Our non-fiduciary services are not available on the Apex platform. Clients may obtain a copy of Formative’s Proxy Voting Guidelines by visiting the Formative website (www.firstaffirmative.com), sending an email to service@firstaffirmative.com or proxyvoting@firstaffirmative.com, or by sending a request in writing to the address listed on the cover page of this document. Clients may request information on how proxies for his/her shares were voted and Formative will promptly provide such information to the client. With respect to ERISA accounts, Formative will vote proxies if granted that authority unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. To direct Formative to vote a proxy in a particular manner, clients should send an email to proxyvoting@firstaffirmative.com. Formative does not vote proxies for the following types of accounts: • Accounts held in custody by Schwab that have not granted Formative authority to vote proxies • Accounts held in custody by Goldman Sachs that have not granted Formative authority to vote proxies • Accounts held in custody by Apex that have not granted Formative authority to vote proxies • ERISA accounts that specifically require the plan sponsor to vote the proxies; and  • Accounts that participate in the OPS Wrap Fee Program. In situations where Formative does not vote proxies, proxy documents are accessible by logging into the Goldman Sachs website for advised clients, www.folioinstutional.com. Upon request, Formative and its IARs may provide information about proxy issues to clients who have chosen to vote their own proxies. Clients can instruct Formative to vote proxies according to particular criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called “poison pill” defense against a possible takeover). These requests must be made in writing. Clients can also instruct Formative on how to cast their vote in a particular proxy contest by sending an email to service@firstaffirmative.com. There is a remote possibility that Formative employees or IARs have a relationship with a public corporation which may put their interests at odds with those of clients in the Proxy Voting process. These personnel are required to disclose to the Chief Compliance Officer any such relationships and are required to recuse themselves from participated in votes related to such companies. Item 7: Client Information Provided to Portfolio Managers Formative does not use Third-Party Model Managers in the Apex Wrap Fee Program. Item 8: Client Contact with Portfolio Managers Formative acts as the portfolio manager for accounts in the Apex Wrap Fee Program. As such, clients have access to Formative. Item 9: Additional Information Disciplinary Information Formative is required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of its advisory business or the integrity of its management. Formative, its management personnel and Investment Adviser Representatives have no disciplinary events to disclose. Other Financial Industry Activities and Affiliations Formative may select BDs to provide brokerage services to client accounts. Conflicts may arise during Formative’s selection of BDs. Formative recommends BDs and places orders for the  execution of transactions for its clients according to its best execution policies and procedures and consistent with the client’s investment objectives. In selecting a BD as a custodian Formative may consider a range of factors relevant, including, but not limited to cost of services, timing and speed of execution, responsiveness, creditworthiness and financial stability, likelihood of, and capabilities in, execution, clearance, and settlement, liquidity in or with an execution venue, and other appropriate factors. After this analysis has been performed the client has sole discretion as to any Formative approved custodian for a Managed Mutual Fund Account. However, certain advisory service programs offered by Formative may only be available through a single custodian. Formative receives the same compensation for each of the investment options it offers at other custodians. The client has sole discretion as to any Formative approved custodian for a Managed Mutual Fund Account. However, certain programs offered by Formative may only be available through a single custodian. Any fees or transactions costs collected by custodians are not shared with Formative. Outside Business Activities of Management Personnel and IARs Formative’s Management Personnel do not have Outside Business Activities that are material to their roles within Formative. Several Formative IARs are licensed as insurance agents or as tax preparers. Formative does not supervise these outside activities, nor does it share in any of the revenues from these activities. Selling Agreement, Solicitors/Endorsers Agreement, Formative as Sub- Advisor Agreement, and Custodial Relationships with Formative There are no referral arrangements between Formative and any RIA firm wherein an individual is a member, officer, or employee of Formative and is also a member, officer, or employee of another firm. This includes any other RIA disclosed as required in Section 7.A. on Schedule D of Form ADV, Part I. (Part I of Formative’s Form ADV is available on the SEC’s website at www.adviserinfo.sec.gov where you can search by using CRD number 109036). No Formative client is obligated to use the advisory services of any other RIA, as no other RIA advisory client is obligated to use Formative’s advisory services. Managing Other Potential Conflicts Insider Trading Formative and/or individuals associated with the firm may buy or sell for their personal account securities identical to or different from those recommended to its clients. In addition, any  related person(s) may have an interest or position in a certain security or securities which may also be recommended to a client. Formative has established written policies and procedures for insider trading that prohibit any member, officer, or employee of the firm, from buying, selling, or recommending securities where the decision is substantially derived, in whole or in part, from non- public information, information about other Formative clients or made based on the potential personal gain of the member, officer, or employee. Compensation Conflicts Fees Paid to Network Advisors and Solicitors/Endorsers by Formative relating to Discretionary Investment Management. A portion of the fees for investment advisory services are shared with Network Advisors or Solicitors/Endorsers to compensate them for their services. If the Network Advisor is an IAR, Formative compensates the IAR directly, with the exception of any compensation he or she may earn on the provision of tax preparation services and life insurance sales. For Network Advisor and Solicitors/Endorsers, Formative collects the applicable fee from the client assets and the Network Advisor or Solicitor/Endorsers share of the fee is paid to the BD or RIA firm with whom they are associated, which firm in turn pays a substantial portion of the fee to the Network Advisor and Solicitor/Endorser. The BD or RIA firm typically retains a small portion of the Network Advisor or Solicitor/Endorser share to compensate itself for administration and other overhead. Costs and Compensation for Rollover Recommendations. Rollover recommendations have associated fees payable to Formative and their Network Advisor or Solicitor/Endorser. These fees might be more or less than the fees or commissions charged to the Client by the Plan, other Consultants, or Brokers, as applicable. This creates a conflict of interest. The Network Advisor or Solicitor/Endorser making the recommendation provides full disclosure of the associated costs and their compensation so a client can make an informed decision before accepting the recommendation. This disclosure attempts to mitigate conflicts of interest. Other Compensation Paid to IARs. In addition to receiving a portion of the fee for discretionary investment advice, IARs receive a portion of any fees charged for financial planning, hourly consultation or other services provided under nondiscretionary investment advisory agreements. Other Compensation Earned by Third-Party BD, RIA Network Advisors, and Solicitors/Endorsers. Third-party firms may compensate their advisors for providing other products or services to clients, Neither Formative nor any Network Advisor or Solicitor/ Endorser receives any transactions-related or variable compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds relating to any product or service offered by or on behalf of Formative.  Formative takes the following steps to address compensation conflicts: • Discloses to clients that they are not obligated to purchase recommended investment products from their employees or affiliated companies • Collects, maintains, and documents accurate, complete, and relevant client background information, including the client’s financial goals, objectives, and risk tolerance • The firm’s management conducts regular reviews of client accounts to verify that all recommendations made to a client are suitable for the client’s needs and circumstances • Requires that employees seek prior approval of any outside employment activity so that Formative may ensure that any conflicts of interest in such activities are properly addressed • Periodically monitors these outside employment activities to verify that any conflicts of interest continue to be properly addressed • Educates employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for investment advice provided to clients; and • Requires all IARs to acquire and maintain the Accredited Investment Fiduciary (AIF), or comparable professional designation to provide initial and ongoing training in the duties of investment fiduciaries. Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its members, officers, or employees when making advisory recommendations or when providing non-discretionary investment advisory services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. The Department of Labor’s Rule 3.0, known as the Fiduciary Rule, requires investment fiduciaries to review the costs associated with rolling over ERISA plan assets to another retirement vehicle. A conflict of interest occurs if the advisor earns a new fee or its current compensation increases because of the rollover. Formative offers fee-based compensation which tends to reduce or change the possibility of conflicts of interest but cannot eliminate them entirely. While it is Formative’s intent to always offer advice that is in the best interest of the client, it is the client’s responsibility to evaluate that advice and determine if it is appropriate before acting. No client is obligated to accept any recommendation, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. Indirect Compensation Specific to Custodians. Formative is charged an annual fee per client account to (OAT) for the use of their Astro platform. This technology allows us to design, implement, and reoptimize portfolios. Formative employs this technology for accounts held at each of our approved custodians. The fees charged to the Client are the same for each platform. Code of Ethics, Review of Accounts, Participation or Interest in Client Transactions, Personal Trading Formative has adopted a code of ethics (Code) which sets forth high ethical standards of business conduct that are required of employees and IARs, including compliance with applicable federal securities laws.  Formative has adopted the Code for the purpose of instructing and guiding its personnel in their ethical and fiduciary obligations to clients. The Code also provides rules and requirements regarding the personal securities trading practices of Formative’s IARs and staff. Formative, its personnel, and its IARs owe a duty of loyalty, fairness, and good faith toward all clients and are obligated to adhere not only to the specific provisions of the Code but to the general principles embodied in the Code. The Code is designed to ensure that the personal securities transactions, activities, and interests of Formative employees will not interfere with making decisions in the best interest of advisory clients and implementing such decisions while, at the same time, allowing employees to invest for their own accounts. The Code covers a range of topics that include the following: general ethical principles, reporting of personal securities trading, exceptions to reporting securities transactions, reportable securities, initial public offerings, and amendments to Form ADV and supervisory procedures. A copy of the Code is available to investment advisory clients, and prospective clients. You may request a copy by email sent to Formative’s Chief Compliance Officer, Kathy Lewis at kathylewis@firstaffirmative.com, or by calling 719-660-6157. Review of Accounts Reports to Clients Clients receive monthly account statements detailing deposits, withdrawals, purchases, sales, dividends, interest, fees deducted from the account and any other activity, from the custodian of the account. Clients may also receive trade confirmations of every trade executed in the account(s), which should have saved for tax purposes. Formative or its service providers also will make available quarterly performance reports to all clients. Depending on the custodian and/or the service provider, such performance reports may be made available for an annual fee, which is not included in the discretionary investment advisory fees described in Item 4 above. All clients have online, 24/7 access to their accounts through a Client Portal via the OAT platform. Formative will provide quarterly performance reports through this Client Portal. These performance reports may include graphic representations of your accounts using various data points. Client Account Reviews Network Advisors and Solicitors/Endorsers. Each Network Advisor and Solicitor/Endorser has the ability to view all positions and activities in his/her client account(s) via the internet, and  each Network Advisor and Solicitor/Endorser receives copies of all reports provided to their client(s). Network Advisors and Solicitors/Endorsers are expected to review activity in client accounts on a quarterly basis, to periodically discuss the account with the client, and to ensure the suitability of the investment services provided based on each client’s specific situation. Supervising BD or RIA. Each third-party BD and/or RIA with which Formative maintains a selling or solicitor/endorser’s agreement also is responsible for developing its own, independent procedures to review client accounts and supervise the activities of its representatives. Company Management. Formative’s senior management, including members of the Investment Committee, conduct both periodic reviews and various systematic samplings of accounts to supervise and ensure compliance with investment policy. Formative also monitors the performance of the VADIS portfolio construction workflow. Client Referrals and Other Compensation Client Referrals Formative may pay referral fees to firms (“Solicitors/Endorsers”) for introducing clients. These fees are asset-based. When the solicitor/endorser is associated with a third-party BD or RIA they are paid over the life of the relationship. Whenever Formative pays a referral fee, it requires the Solicitor/Endorser to provide the prospective client with a copy of the Disclosure Brochure and this document, an Investment Advisory Services Agreement (IAS), and a separate disclosure statement that includes the following information: • The Solicitor/Endorser’s name and relationship with Formative; • The fact that the Solicitor/Endorser is being paid a referral fee; • The amount of the fee; and • As a matter of firm policy, a client working with a Solicitor/Endorser will not be charged more than any other client. Other Compensation It is Formative’s policy not to accept or allow its 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 it provides to its clients. Financial Information Under no circumstances does Formative require or solicit payment of fees in excess of $500 per client more than six months in advance of services rendered. Therefore, Formative is not required to include a financial statement in this disclosure document. As an advisory firm that maintains discretionary authority for client accounts and maintains  custody of client assets held for clients at Schwab, SEI, and Apex, granting Formative authorization under a SLOA, Formative is also required to disclose any financial condition that is reasonably likely to impair its ability to meet its contractual obligations. Formative has no additional financial circumstances to report. Formative’s financial statements are audited or reviewed each calendar year by a qualified, independent CPA firm. Formative has never been the subject of a bankruptcy petition. 

Form ADV Part 2A April 17, 2026 Fo rm ADV Disclosure Brochure for Clients and Prospective Clients of First Affirmative Financial Network, LLC DBA Formative Item 1: Introduction and Overview This Disclosure Brochure provides information about the qualifications and business practices of First Affirmative Financial Network, LLC DBA Formative (“Formative ”). Formative is an independent investment advisor registered (RIA) with the U.S. Securities and Exchange Commission (SEC) with its principal place of business at 5475 Mark Dabbling Boulevard, Suite 320, Colorado Springs, CO 80918. It should be noted that, while Formative is registered with the SEC, such registration does not imply a certain level of skill or training. This Disclosure Brochure is required to be delivered to any prospective client prior to or at the time of entering an investment advisory relationship with Formative . Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov . The fact that Formative is registered with the SEC should not be read as an endorsement of Formative or that Formative has a certain level or training. You can search the SEC’s website for information about an RIA by using the RIA’s unique identifying number known as a “CRD number.” Formative ’s CRD number is 109036. You can also access an electronic copy of this document in a publicly accessible area on the Formative website at www.firstaffirmative.com . If you have any questions about the contents of this Disclosure Brochure, please contact Formative ’s Chief Compliance Officer, Kathy Lewis, at 719 - 660 - 6157 or kathylewis@firstaffirmative.com . While submitted to the SEC, the information in  this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Item 2: Material Changes Consistent with SEC rules, Formative updates this Disclosure Brochure at least annually, within 90 days of the close of its fiscal year, which is December 31. If there are material changes from the prior annual update of this Disclosure Brochure, and you received a prior version of this Discl osure Brochure, such changes will be set forth in the “Summary of Material Changes” accompanying this Disclosure Brochure. Item 4: Advisory Business We incorporate values - alignment analysis into your investing strategy, which allows you to include or exclude companies or industries from your portfolio consistent with your social goals. These values include both value - based and faith - based investing. We primarily use equity securities, mutual funds, exchange traded funds, and in some cases, individual bonds. We do not use proprietary investment vehicles other than proprietary models at certain custodians. Formative provides values - aligned investment advice and faith - based investing. Formative began conducting advisory business in 1999 and believes (as it has from the beginning) that the ways in which people save, spend, and invest can dramatically influence both the values and behaviors of business and society. In advising clients how they can invest in ways consistent with their values, Formative uses commercial research available to it regarding values - based factors. These factors measure the behavior of c orporations and are indicators of the quality of management and the exposure to various risks to operations. Values - based ratings do not generally exclude a corporation from consideration as an investment. That decision is made by clients as part of the in vestment process, which may include mutual funds, exchange - traded funds, or individual securities. Investors can express their beliefs by directing investment capital toward enterprises that contribute to a clean, healthy environment, that treat people fai rly and embrace equal opportunity, that produce safe and useful products, and support efforts to promote world peace. These goals can also be targeted by voting proxies or participating in shareholder  advocacy, both services that are provided by Formative . Clients who choose to invest with Formative make a considered and informed choice to put their money to work for a dual purpose —to achieve desired investment goals, such as providing for a secure retirement, while working for a better, more socially just and environmentally sustainable future for al l. Formative provides two types of services: acting as a fiduciary to client accounts and providing non - fiduciary services as described in detail below. Sustainable Investment Solutions – Fiduciary Through Network Advisors (defined below) Formative provides discretionary investment advisory services to investors, tailored to the individual needs of the client, that integrate values - based criteria into the investment analysis process according to the clients’ preference. Formative can create portfolios, using mutual funds, and/or individual securities such as stocks, bonds, exchange traded funds (ETFs), exchange traded notes (ETNs), real estate investment trusts (REITs), American depository receipts (A DRs), government agency or Treasury securities, corporate or municipal bonds, certificates of deposit (CODs), commercial paper or other securities. The different investment programs offered by Formative may not all offer the ability to invest in all the securities listed above. Formative does not offer discretionary investment advisory services concerning direct ownership of commodities, futures, derivatives, or short selling. We offer several different types of discretionary accounts under the name Sustainable Investment Solutions. They include “Managed Mutual Fund Accounts”, “Multi- Manager Accounts”, “Fixed Income Accounts”, and “Values - Aligned Direct Indexing Solutions (VADIS )”. These services are offered via discretionary accounts at our approved custodian broker - dealers (BDs), Schwab Institutional (Schwab), SEI, Inc. (SEI), Apex Clearing Corporation (Apex), Goldman Sachs Advisor Solutions (Goldman Sachs), and certain third - party platforms such as Orion Portfolio Solutions, (OPS), and Geneos Wealth Management, Inc. (Axiom ). Discretionary accounts in this context allow Formative , as the advisor, to buy and sell securities without your consent for each trade. As always, Formative acts in your best interest, including trading your accounts.  Sustainable Investment Solutions – Other Services In addition to discretionary investment advisory services, Formative also: • Offers financial planning or investment consulting through IARs only. • May provide outsourced chief investment officer (OCIO) services which may include discretionary portfolio management, investment research, financial and impact performance reporting, thought leadership, co - fiduciary, IPS consulting, and asset allocation, (o n an hourly or on a retainer basis) to individuals and their families, trust, estates, retirement plans, foundations, endowments, and companies. • Makes its products available on third - party custodial platforms. • Makes its services available to Network Advisors excluding any assistance in creating an investment portfolio for a client. • May offer investments in illiquid securities on a non - discretionary basis. Please see the Illiquid Securities section below for the types of alternative investment that might be approved by Formative . Discretionary Investment Advisory Services – Sustainable Investment Network Advisors Formative has a nationwide network of qualified investment professionals, known as Network Advisors, who assist clients in achieving their financial goals by providing individualized investment advice, in the capacity of a fiduciary, with respect to securities produ cts. The following relationships are included in the definition of Network Advisor as used in this Disclosure Brochure. Investment Advisory Representatives (IARs) of Formative . IARs supervised by Formative and offer investment advisory services and products approved by Formative . In some instances, IARs also may, as an outside business activity, offer non - securities products such as life insurance and tax preparation services, which are not provided, supervised, recommended, or approved by Formative . Formative does not provide investment advisory services with respect to such non - securities products.  Selling Agreements with Third - Party RIA Firms. Certain individuals who are not supervised by Formative , but who are associated with third - party RIA firms, may include Formative services in the overall package of investment advisory services made available to their clients, provided the third - party RIA that they represent enters into a selling agreement with Formative . Such third - party RIA representatives may also offer products and services that are not provided, recommended, or approved by Formative , which may be more or less expensive than Formative services. The description of compensation to Formative in Item 5 below does not include compensation that such third - party BDs or RIAs and their representatives may earn from services unrelated to Formative services. Sub - Advisory Services Agreements with Third - Party RIA Firms . A third - party RIA firm may retain Formative as a sub - advisor to its clients. Formative will manage a portion of the client’s assets based upon information about the client provided by the Third - Party RIA. Formative does not recommend or approve the other activities of such third - party RIA firms, or the products or services provided by them, and such products and services may be more or less expensive than Formative products and services. The descr iption of compensation to Formative relating to sub - advisory agreements as discussed in Item 5 below does not include the compensation that such third - party RIA may earn on assets not sub - advised by Formative . Solicitor’s/Endorser’s Agreements with BDs or other Third - Party RIA Firms. Pursuant to agreements with third - party BD and RIA firms (previously referred to as solicitors’ agreements), such third - party BD and RIA firms may introduce their clients to Formative for its discretionary investment advisory services (Solicitors/Endorsers). Formative is the sole advisor for the advisory services offered by it for clients introduced to it by a solicitor/endorser. Formative pays the solicitor a fee for referring clie nts to Formative . Solicitors/Endorsers may offer other products and services or introduce their clients to other advice providers besides Formative . Formative does not recommend or approve the other activities of such solicitors/endorsers, or the products or services provided by them, and such products and services may be more or less expensive than Formative ’s products and services. The description of compensation to Formative in Item 5 below does not include compensation received  by such third - party BDs or RIAs and their representatives may earn from services unrelated to Formative services. Independent Sub - Advisors and Third - Party Model Managers. While offering Sustainable Investment Solutions discretionary investment advisory services, Formative may seek the expertise of third - party firms that function as model managers in developing model investment strategies (Third - Party Model Managers) and/or as fiduciary sub - advisors to Formative for separate investment management accounts (Sub - Advisor), if applicable. Discretionary Investment Advice Through its Network Advisors, Formative creates unique relationships with clients by combining discretionary investment advisory services and advanced financial technologies with responsible investment strategies that consider values - based factors or faith - based values. Generally, Formative ’s innovative approach combines: Fiduciary Responsibility. In Formative ’s relationship with clients where Formative is providing discretionary investment advice, Formative acknowledges that it serves and acts in a fiduciary capacity under the Investment Advisers Act of 1940. When we provide investment advice to you regarding your retirement plan account or individual retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code , as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests. Under both rules Formative and the Network Advisors we work with operate in your best interest and do not place their needs ahe ad of yours. As a fiduciary, Formative and its IARs provide advice regarding rollovers of retirement plan assets. Advisors we work with, that aren’t IARs monitor their own programs to comply with fiduciary duty under the Department of Labor rule regarding rollovers. Formative requests documentation from these advisors and notes whether it is provided or not. The types of rollovers include an existing Retirement Plan to an IRA; an existing IRA to a Retirement Plan; an employer Retirement Plan to a new employer  Retirement Plan; an IRA to an IRA; and a change from one retirement account type to another type, including from commission - billing to fee - billing. Individualized Advice. One size does not fit all. Formative offers a variety of fee - based investment options, each designed to best meet the needs of individual clients and/or specific types of clients. The client can place reasonable restrictions on the types of investments to be held in the client account. Objectivity. Network Advisors provide their clients with objective advice. Fees for account management are generally based on assets under management and, as a result, the client’s interests, the interests of the Network Advisor and the interests of Formative are closely aligned. Wrap Fee Program Participation Formative participates in a wrap fee program sponsored by Geneos Wealth Management, Inc. ( Axiom. ) through which Formative offers proprietary investment model portfolios constructed and managed by Formative (Proprietary Models). The Proprietary Models on the Axiom platform are required to meet certain criteria set by Axiom and any models listed are subject to ongoing reviews by philosophy and process as it uses in other Proprietary Models not offered through Axiom. However, the included securities are restricted to securities approved by Axiom and are consistent with Axiom’s asset allocation strategies and model construction gu idelines. Formative exercises no discretion with respect to clients subscribed to the model portfolios but may receive an asset - based fee when a Proprietary Model is used by Axiom or a representative of Axiom in making a recommendation to a client. Formative sponsors discretionary advisory services where advisory fees and other fees are bundled together with other costs which can include the cost of executing trades in your account which are charged to your account as one "wrap fee". Formative also sponsors three wrap fee programs, one providing investment management and model management services on the Goldman Sachs platform, one providing investment management services on the OPS platform, and the other through Apex. These programs are further described in Formative ’s Form ADV Brochure, Part 2A, Appendix 1A (Goldman Sachs Wrap Fee Brochure), Appendix 1B  (OPS Wrap Fee Brochure), and Appendix 1C (Apex Wrap Fee Brochure), (together, Wrap Fee Brochures), which are provided to applicable clients at the initial meeting, when there are material changes, and annually thereafter. Financial Planning Formative provides financial planning services which may include personal financial coaching, budget assistance, tax planning, retirement planning, estate planning, or other specialized services. A financial plan is a comprehensive evaluation of a client’s current a nd future financial state using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analyses are considered as their impact and are imp acted by the financial and life situation of the client. The IARs that prepare financial plans for clients are encouraged to become Accredited Investment Fiduciaries (AIF). The implementation of the recommendations in a financial plan is entirely at the client’s discretion and may be incorporated in Formative discretionary investment advice or implemented on a non - discretionary basis. Fees for financial plans developed and delivered by Network Advisors who are not IARs may have different pricing structures. Financial plans developed and delivered by Network Advisors who are not IARs are not supervised by Formative and as such are not the responsibility of Formative regardless of the source of the financial planning software. Retirement Plan Consulting Service s Formative may offer the services listed below to individuals and charitable organizations who need assistance with pension, profit sharing and 401(k) plans for an hourly or one - time fee. This assistance will be reviewed against the Five Part Test developed by the De partment of Labor to determine if it rises to the status of fiduciary advice. The DOL Fiduciary Rule requirements will be met, if applicable. The services are limited to the following non - discretionary consulting services: • Education about investment vehicles for the plan trustees; and • Provision of educational support and investment workshops to self - directed 401(k) plans participants.  Formative does not provide investment advisory services to participants in retirement plans where it provides services to the plan. Formative is compensated for its retirement plan consulting services either based on an hourly rate as negotiated between Formative and the plan sponsor or a fee charged based upon assets under advisement by the asset custodian. Model Portfolio Management In addition to using independent Third - Party Model Managers, Formative also uses Proprietary Models. Some managed mutual fund models use primarily institutional share class funds or ETFs, whereas other models are constructed with individual securities. Each model portfolio is designed to meet a particular investment or risk tolerance goal. Certain Proprietary Models are also offered to investors on custodial platforms by RIAs other than Formative (such as Axiom and OPS). When making Proprietary Models available to third parties outside of the context of offering discretionary advice, any action, inaction, or decision in following such models is the sole responsibility of the third - party RIA or non - discretionary clients any action, Formative does not act in a fiduciary capacity and the sole responsibility all decisions regarding using the mode l rests with the outside RIA or the non - discretionary client. Illiquid Impact Investments Formative may, from time to time, approve illiquid Impact Investments for clients for whom they are believed to be suitable. Formative performs due diligence on this type of investment. Formative will determine appropriate custody and billing arrangements wherein Formative receives 67% of the set 1.00% fee charged. The IAR receives the other 33%. This opportunity potentially diversifies your portfolio while helping companies grow, create new jobs, and benefit the economy. Depending on the offering, these investments are available to accredited and non - accredited clients in taxable and non - taxable accounts. IARs are authorized to present only those illiquid impact investments that have been approved by Formative to their clients. This type of investment requires written permission from the client.  Network Advisors cannot place trades without the client’s express written permission. Network Advisors working through their own independent RIA firms with clients that are interested in “impact investing” must be authorized by their compliance department to present approved offerings to their clients. Network Advisors that are associated with a third - party RIA cannot offer these securities through Formative unless their BD or RIA has approved the offering and updated their selling or sub - advisory services agreement with Formative . Network Advisors compliance departments are responsible for due diligence on these products. Illiquid impact investment opportunities are most often marketed directly to First Affirmative, their IARs, and Network Advisors. There is additional risk involved in this type of alternative investment. Publication of Periodicals Formative publishes a quarterly newsletter with topics that include but are not limited to values - alignment issues. Periodically, Formative produces other publications that focus on specific issues believed to be of interest to clients such as community impact investing or shareholder advocacy. Formative also publishes a quarterly market commentary and a quarterly economic commentary which provides general information on various topics including, but not limited to, market trends, bond market outlook, etc. No specific investment recommendations are provided in these publications and the information provided does not purport to meet the objectives or needs of any individual. Newsletters, market commentaries, and other such publications are designed for and ar e distributed free of charge to clients. Class Action Litigation Monitoring and Claim Filing Formative has engaged an independent third - party service provider to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of the Firm’s clients. It is necessary to share a client’s personally identifiable informat ion (PII) with the independent third - party service provider. They have strict privacy and security policies in place to protect all PII shared with them. If you would prefer that your information, not be shared with the independent third - party service provider you can opt out of this service in the Investment Advisory  Services Agreement or Opt - Out Letter available from your Network Advisor or at any time thereafter by notifying Formative in writing including by emailing service@firstaffirmative.com . By opting out your information will not be shared, and you will not participate in the service. If Formative chooses to change the third - party provider of this service, clients will be notified and offered the opportunity to opt out. Formative and your Network Advisor do not receive any fees or remuneration from the service provider, nor do they share in any settlement payments awarded. The independent third - party service provider will retain 15% of each claim recovery received. Non - Fiduciary Services The second type of service Formative provides is non - fiduciary services to selling advisors, see below. Upon receipt of authorization signed by the client allowing Formative access to their accounts at the requisite custodian we will: 1. Facilitate the opening of client accounts. 2. Complete a quantitative review of Mutual Funds and Model Managers in Formative ’s Sustainable Investment Universe. 3. Trade accounts on a non - discretionary basis upon instruction from advisors and/or clients under limited circumstances. 4. Collect fees from client accounts based on the schedule agreed upon by the client and the selling agent. 5. Vote client proxies if authorized. 6. Retain an agreed upon amount and distribute the fees to the selling agent and any money manager or sub - advisor managing the account. Formative may function as a money manager for part of the client’s account on Goldman Sachs for which it will also be compensated. Discretionary and Non - Discretionary Assets Under Management As of March 31, 2026 , Formative was actively managing on a discretionary basis $714,724,726 of client assets (referred to as “assets under management”). The firm  also had $ 178,101,747 in non - discretionary assets under administration (referred to as “assets under administration”). Item 5: Fees and Compensation Discretionary Fiduciary Investment Management Fees Formative ’s primary source of compensation is from fees charged for discretionary investment management. These fees are charged based on the amount of assets managed for clients, the types of services provided and Formative ’s arrangements with the custodial BDs, as detailed below. Fees for services provided by Network Advisors or Sub - Advisor Services are in addition to the fees presented below and will be collected along with the Formative fees as described below. Accounts held at Apex Clearing and Goldman Sachs are wrap fee programs. This means that all of the fees collected from the client: Formative , Network Advisors, and custodial fees are “wrapped” together and charged as one fee. Fees for Formative services are charged on a tiered fee schedule. Fees for each of our custodians are presented below. To analyze the fees, you will pay for services look at your accounts as a group if the accounts are in the same investment management program at the same cu stodian. If you have accounts that are not in the same investment management program at the same custodian, the following calculation should be completed for each different program type. For example: If you have $50,000 in a VADIS account at Apex your quarterly wrap fee will be $50,000 x (0.31% + 0.05% + 0.08%) / (365/Number of Days in Quarter) or $50,000 x 0.0044 = $220 / (365/92) = $55.45 per quarter. This calculation does not include the fees you wi ll pay for the services provided by your Network Advisor or Solicitor/Endorser. That fee is determined by your Network Advisor or Solicitor/Endorser based on the services they provide. This fee will be added to the fees described in the tables below. Continuing with this example, if you also have two accounts in VADIS at Schwab Institutional, one worth $2,100,000 and the other worth $500,000 your quarterly fee will be $2,000,000 x (0.31% + 0.05) / (365/Number of Days in Quarter) + $600,000 x (0.26% + 0 .05) / (365/Number of Days in Quarter) or ($2,000,000 x  0.0036) / (365/92) + ($600,000 x 0.0031) / (365/92) or $1,814.79 + $453.70 = $2,268.49. This calculation does not include the fees you will pay for the services provided by your Network Advisor or Solicitor/Endorser. That fee is determined by your Network Advisor or Solicitor/Endorser based on the services they provide. This fee will be added to the fees described in the tables below. Excluding the fees charged by your Network Advisor or Solicitor/Endorser your total fees in the above example would be $2,320 per quarter. This fee will vary based upon the value of your accounts. All fees will be agreed to, in writing, by the Network Advisor, and Formative , in the Formative Investment Advisory Services Agreement and applicable Custodial Fee Addendum. Note: The value of your account(s) is determined by the average daily balance in your account(s) throughout the billing period. For example: On the first day of the billing period your account is worth $51,247. On the second day of the billing period your account is worth $51,322 and so on. The totals for each day in the period are added together and then divided by the number of days in the quarter. This is the average daily balance in your account for that quarter. Your fees are calculated using that amou nt. Wrap Fee Program Assets Custodied at Apex and Goldman Sachs The fee structure shown in the table below represents the maximum fees charged by Formative for managed assets on one of our three wrap fee programs. The table shows Formative ’s fee for discretionary investment advisory services, YourStake Impact Preferences Platform (YourStake), if applicable, Model Manager use at Goldman Sachs, if applicable, and the custody and clearing fees by custodian, whichever is applicable. Custody and clearing fees are for services such as trade execution. See Item 12 below for fu rther information regarding brokerage fees. Fees on assets in these wrap fee programs are charged as a percentage of assets under management, annualized, in arrears, quarterly. Fees are calculated using average daily balance methodology. To the extent that Formative agrees not to automatically deduct fees from a client’s assets, the client will be invoiced for fees incurred.  Tiers Cumulative Formative YourStake Goldman Apex: Goldman (For Internal Discretionary Impact Sachs Custody Sachs: Use) Investment Preferences Model and Custody Advisory Platform Manager clearing and Services Required fees, as clearing for VADIS applicable Accounts at either custodian On 2,000,000 2,000,000 0.31% 0.05% 0.35% 0.08% 0.09% the first On 8,000,000 10,000,000 0.31% 0.05% 0.35% 0.08% 0.09% the next On 10,000,000 20,000,000 0.31% 0.05% 0.35% 0.08% 0.09% the next Above 20,000,000 0.31% 0.05% 0.35% 0.08% 0.09% The Network Advisor will determine the fees for their services. These fees will be agreed to, in writing, by the Client. The total fee will be charged to the clients’ accounts as described above.  New accounts are subject to the following asset minimums: VADIS Accounts: $ 25,000 Managed Mutual Fund Accounts: $50,000 Multi- Manager Accounts (Goldman Sachs): $50,000 The account minimum is negotiable on a case - by- case basis and are dependent on a variety of factors, including but not limited to other accounts in a client household (adults who all live at the same address who have investment accounts with Formative ). Accounts billed for the same program, on the same custodial platform, will be grouped together for breakpoints unless such grouping is prohibited by regulatory rules or Internal Revenue Service (IRS) restrictions. The wrap fee may be more or less than the aggregate fee for services if they were offered separately. Some factors that may contribute to the relative cost differential include, but are not limited to, the brokerage and clearing costs, commissions based on trading frequency or commissions based on type of security (e.g., mutual fund, ETF, or single stock) and the mutual fund share classes available. Assets Custodied with Schwab and TD The fee structure shown in the table below represents the maximum fees charged by Formative for managed assets custodied with Schwab. The fees represent Formative ’s fee for discretionary investment advisory services. In accounts where a separate account manager is used to manage fixed income assets the fee indicated on the table below will be collected with the Formative fee. Formative will collect the fees for the YourStake Impact Preferences Platform (YourStake) for VADIS accounts, as applicable. Schwab m ay charge fees for its services (for example, trade execution, custody and clearing services) that are in addition to the asset - based fees charged by Formative . See Item 12 below for further information regarding brokerage fees. 
  Fees on assets custodied with Schwab are charged as a percentage of assets under management, annualized, in arrears, on a quarterly basis. Fees are calculated using the average daily balance methodology. To the extent that Formative agrees not to automatically deduct fees from a client’s assets, the client will be invoiced for fees incurred. Note that Schwab fees are not wrap fees. Tiers Cumulative Formative : YourStake Schwab: Discretionary Impact Fixed Income Investment Preferences Separate Advisory Platform Account Services (Required for Manager VADIS fees as Accounts applicable only) On the First 2,000,000 2,000,000 0.31% 0.05% 0.35% On the Next 8,000,000 10,000,000 0.26% 0.05% 0.35% On the Next 10,000,000 20,000,000 0.21% 0.05% 0.35% Above 20,000,000 0.21% 0.05% 0.35% The Network Advisor or Solicitor/Endorser will determine the fees for their services. These fees will be agreed to, in writing, by the Client. The total fee will be charged to the clients’ accounts as described above.  New accounts are subject to the following asset minimums: VADIS Accounts: $ 250,000 Managed Mutual Fund Accounts: $ 50,000 Fixed Income Accounts (Schwab): $ 250,000 The account minimums are negotiable on a case - by- case basis and are dependent on a variety of factors, including but not limited to other accounts in a client household (adults who all live at the same address who have investment accounts with Formative ). Accounts billed for the same program, on the same custodial platform, will be grouped together for breakpoints unless such grouping is prohibited by regulatory rules or Internal Revenue Service (IRS) restrictions. Fees paid to Third - Party Model Managers on the Goldman Sachs custodial platform) and Independent Sub - Advisors (Schwab custodial platform) In providing discretionary investment advice to clients, Formative may use investment models developed by Third - Party Model Managers that are compensated based on the dollar value of assets “subscribed” to the model(s) used. These fees are calculated in the aggregate across all subscribed accounts and are paid from Formative ’s discretionary investment management fees, consistent with the fee schedules above. Formative also may recommend independent Sub - Advisors to clients. Under such circumstances, any fee for such Sub - Advisor’s services is included in the discretionary investment management fee paid by the client to Formative , consistent with the fee schedules above. 
  Wrap Fee Program for Assets Custodied with Schwab for Orion (OPS ) The OPS Wrap Fee Program fee includes all costs for trade execution, custody and clearing (which is provided by Schwab unless specifically noted as a separate charge, as well as Formative ’s fee for discretionary investment advisory services. Fees on assets included in this program are charged as a percentage of assets under management, annualized, in arrears, monthly, according to the schedule below. The Wrap Fee shown in the table below i s collected from each client account by OPS on Formative ’s behalf. Tiers Cumulative (For Internal Use) On the first $50,000 1.450% On the next $100,000 1.350% On the next $100,000 1.200% On the next $150,000 1.195% On the next $100,000 1.125% On the next $400,000 1.125% On the next $100,000 1.100% On the next $1,000,000 0.950%  One the next $1,000,000 0.850% On the next $2,000,000 0.750% On the next $5,000,000 0.550% Above $10,000,000 0.450% There is no minimum size for accounts that are advised by Formative on the OPS platform and the Wrap fee is negotiable by clients through their Network Advisor. The wrap fee may be more or less than the aggregate fee for services if they were offered separately. Some factors that may contribute to the relative cost differential include, but are not limited to, the brokerage and clearing costs, commissions based on trading frequency or commissions based on type of security (e.g., mutual fund, ETF, or single stock) and the mutual fund share classes available. Third - Party Model Managers (also referred to as portfolio managers) utilized by Formative when advising clients on the OPS Platform are paid 0% to 0.50%) out of the wrap fee. Formative also receives 14 bps when its Proprietary Models are used by third - party RIAs while providing fiduciary advice to their clients. Some of the models that are available to IARs for the purpose of providing discretionary investment advice to clients on OPS ar e Proprietary Models. When a Proprietary Model is used by an IAR, a cli ent is not charged a separate basis point fee – the wrap fee includes the cost of all Proprietary Models. Please see below for descriptions of incidental and other fees charged by custodians, internal expenses on mutual funds and mutual fund payments to custodians.  Additional Fees Apex Incidental Fees Apex RIA Miscellaneous Services Pricing Term Sheet Pricing Current as of May 1, 2021. Fees are subject to change without notice. Miscellaneous Services fees are amounts due to Apex and do not count towards any minimum charges you may owe to Apex. Customer Charged Miscellaneous Services A. Retirement: • Annual IRA Maintenance Fee See Advisor Agreement • IRA Closing Fee $60 per account B. Banking: • Outgoing Wire Transfers (Domestic Bank) $25.00 per wire • Outgoing Wire Transfers (Foreign Bank) $50.00 per wire • Paper Check Draft (USD) Domestic $5.00 per check • Paper Check Draft (USD) International $10.00 per check • Returned Checks, ACH, Wires and Recalls $30.00 per item (Including amendments/repairs) • ACH Notice of Correction $5.00 per notice • Stop Payments on Apex Issued Checks $30.00 each • Check Copies $15.00 each • Third Party Distribution Notification $2.00 per notification • Third Party Journal (TPJ) $0.05 per journal C. Operations • Electronically Delivered Documents • Confirms No Charge • Statements No Charge • Tax Statements No Charge • Postage and Handling (Paper Only) Confirms $2.00 per confirmation • Statements (monthly and quarterly) $5.00 per statement  • Outgoing ACAT Transfers $75.00 per account • Incoming ACAT Transfers No Charge • Limited Partnerships/Private Placements (IRAs only) $250.00 per investment Goldman Sachs Incidental Fees In addition to the fees above, clients are still responsible for any special fees incurred at the client’s request, such as wire transfer fees, etc., which are charged and disclosed by Goldman Sachs. All fees are subject to change and can be found at: https://www.folioinstitutional.com/resources/service - fees.jsp . Goldman Sachs Transaction - Based Pricing Non - retirement accounts will be charged on a per transaction basis when the security to be bought or sold is ineligible for trading in the Goldman Sachs patented window trade process (see Item 12, “Aggregation of Client Securities” for a description of the window trading process). In such circumstances, your order will be routed and executed as a direct trade and charged the following fees. Telephone $45.00 per trade Internet $3.95 per trade Goldman Sachs also will charge the account transaction fees based on the above schedule if securities are transferred into a non - retirement account and need to be sold to implement a client’s new investment strategy. Goldman Sachs Costs for Third - Party Services Goldman Sachs passes through the costs from third parties, including, but not limited to, the following: • Services provided by BDs other than Goldman Sachs. • SEC and securities exchange fees. • Transfer taxes.  • Fees for odd lot differentials. • Mutual fund short - term redemption fees. • Other similar costs and charges. Schwab Incidental Fees In addition to the fees above, clients are still responsible for any special fees incurred at the client’s request, such as wire transfer fees, etc. which are charged and disclosed by Schwab Institutional. All fees are subject to change and can be found at : Schwab.com/pricing. Note that some of these fees may not reflect the discounted prices that Formative has negotiated with Schwab. Schwab Transaction - Based Pricing The following fees are charged by Schwab per transaction in each client account: Transactions Equities and ETFs $0.00 All Methods: Institutional Class Mutual Fund $15.00 per Trade Shares Bond Transactions Telephone $1.20 per bond, $10 Minimum, $275 Maximum Internet/Electronic $1.00 per bond, $10 Minimum, $250 Maximum Government Bonds $25.00 flat  Municipal Bonds Variable Prime Brokerage/Trade Away $25.00 per transaction Applicable to All Programs Fees Upon Termination of Services. A termination or transfer - out fee on accounts, which may change periodically, may be assessed by the custodian. This fee is determined by the custodian and the monies received are not shared with Formative . Margin. If you choose to trade using margin, your account will be charged the margin interest charges in accordance with the margin interest rates in effect at the time of your margin loan and as disclosed by your Network Advisor or Solicitor/Endorser. Mutual Fund Transaction Commissions Charged to Clients . Some mutual funds that are included in client investment portfolios offer different types of shares, known as “share classes.” Each share class has different shareholder services and/or distribution arrangements with different fees and expenses and, ther efore, different performance results. For example, class A shares, also called “retail shares”, usually have a front - end load or charge (commission) which is paid to the custodial BD when the mutual fun d is purchased. Institutional class shares, in contrast, generally are available only to institutional investors and may have very different fees and expenses from class A shares but generally do not require front - end commissions. See the SEC website, the Financial Industry Regulatory Authority website, or the relevant mutual fund share prospectus for additional information regarding share classes. Formative generally includes only institutional class shares with no front - end loads in the Managed Mutual Fund Accounts and, to the extent it does include a mutual fund that typically has a front - end load, it will do so only if the front - end load is waived. There a re no transaction fees for purchasing mutual fund shares at any of the  Formative approved custodians except for a $15.00 transaction fee for the purchase and sale of institutional class shares at Schwab. Formative generally uses only no - load, or load - waived, no transaction fee funds in its managed mutual fund portfolios custodied with Apex. Formative will not use a mutual fund that has a front - end load if the front - end load is not waived. Mutual Fund Company Payments to Custodians. Custodians are compensated directly by the fund companies, which may increase the internal expense of the mutual fund company and impact on the client’s return on investment. See “Mutual Fund Transaction Commissions Charged to Clients” above. Such compensation is not shared with Formative . Rule 12b - 1 fees are defined as annual marketing or distribution fees on mutual funds. These expenses are included in the funds expense ratio and are in some cases shared with custodians. Formative may place trades in mutual funds that pay compensation to custodians. 12b - 1 fees paid to custodians are not shared with Formative . As part of Formative ’s fiduciary duty, we will evaluate the costs associated with mutual funds to determine which fund, or share class of a fund, is most suitable for client portfolios. If appropriate, Formative will exchange share classes to a less expensive share class. In taxable accounts, these exchanges will be done, when possible, with the fund companies as tax - free exchanges. Additional Expenses to Clients Relating to Mutual Fund Holdings. Mutual funds have internal expenses, such as portfolio management, legal and accounting, printing, marketing, trading costs, and other administrative expenses, including fees paid to custodians. Fund expenses are more fully disclosed in each mutual fund prospectus. They are accounted for and charged internally by the mutual funds and monies collected or retained are not shared with Formative , any affiliate of Formative or any Network Advisor. Any mutual fund sale within a defined period per the mutual fund prospectus after the initial purchase may trigger a contingent deferred sales charge by the mutual fund company on each transaction. These charges vary among the mutual funds that are held in a client account.  Clients also may have assets custodied with one or more of our custodians not advised by Formative (referred to as non - discretionary assets). IARs may assist such clients with non - discretionary assets for a flat fee, which is not asset - based, which is collected quarterly in arrears. Formative ’s fee with respect to such assets is in the range of $40 to $2,400 per annum. This fee is collected directly from the client account when authorized by the client. If a client has not authorized deduction from the acc ount, the client is directly invoiced for payment. Fees for Discretionary Assets not Held by Custodians Above. Any private equity, private debt, or direct investment that is not custodied with one of Formative ’s custodians listed above will be charged a fee of no more than 1.80%. Fees on assets included in this category are charged as a percentage of assets under management, annualized, in arrears, quarterly. Minimum investments for such offerings vary. Such assets are valued at least annually by an independent third party. Formative does not verify asset values. The fee will be deducted from a linked taxable account on the Goldman Sachs or Schwab platform. To the extent that Formative agrees not to automatically deduct fees from a client’s assets, the client will be invoiced directly for fees incurred. Fees for Advisory Services to 401(k) Plans. When providing discretionary investment advice to retirement plans, Formative may be compensated based on an annual percentage of plan assets for services involving ongoing reviews (see Item 13, “Review of Accounts”). Advisory Fees in General. Clients should note that similar advisory services may (or may not) be available from other investment advisers for similar or lower fees. Reasonably Negotiated Custodian Fees and Cost. Through special arrangements with Schwab and other select service providers, Formative clients may receive low cost custodial and transaction services. Such fees, when viewed in aggregate with Formative ’s advisory fee, may be more or less than any wrap fee that Formative offers with respect to the wrap fee programs sponsored by Formative .  Fees for Non - Fiduciary Services Schwab Fee Schedule Tiers Formative Non - Schwab: Custody Fiduciary Fee and Clearing On the first $100,000 0.25% Note On the next $100,000 0.25% Note On the next $1,800,000 0.25% Note On the next $8,000,000 0.20% Note On the next $10,000,000 0.15% Note Above $20,000,000 0.15% Note Schwab does not charge for custody and clearing. There are costs associated with certain types of trades. See Item 5 above for more details. The fees in the table above will be collected, as applicable, on assets under management, annualized, quarterly, in arrears, using the average daily balance methodology. Any fee to be charged by the Network Advisor will be billed separately and will not cr eate a wrap fee participation or sponsorship relationship, as defined by Section 204 - 3(g)(4) of the Advisors Act of 1940.  Goldman Sachs Fee Schedule Tiers Formative Non - Goldman Sachs: Goldman Sachs: Fiduciary Fee Custody and Model Manager Clearing fees On the first $100,000 0.25% 0.09% 0.35% On the next $100,000 0.25% 0.09% 0.35% On the next $1,800,000 0.25% 0.09% 0.35% On the next $8,000,000 0.20% 0.09% 0.35% On the next $10,000,000 0.15% 0.09% 0.35% Above $20,000,000 0.15% 0.09% 0.35% Goldman Sachs charges for custody and clearing as indicated in the above table. There are costs associated with certain types of trades. See Item 5 above for more details. The fees in the table above will be collected, as applicable, on assets under management, annualized, quarterly, in arrears, using the average daily balance methodology. Any fee to be charged by the Network Advisor will be billed separately and will not cr eate a wrap fee participation or sponsorship relationship, as defined by Section 204 - 3(g)(4) of the Advisors Act of 1940.  Limited Negotiability of Advisory Fee s The fees above represent the maximum fees charged by Formative for investment advisory services, YourStake Impact Preferences Platform for VADIS accounts, as applicable, custody and clearing, and model managers and/or separate account managers, as applicable. Our Network Advisors or Solicitors/Endorsers set their own fees which will be in addition to the fees above and those fees may be negotiable on a client - by- client basis. The annual fee schedule specific to the client and their account(s) will be provided to each client as part of the quarterly invoice and will be included with the Investment Advisory Services Agreement (IAS) signed by each client. Clients with accounts where Formative acts as a sub - advisor will receive a notice upon account set - up confirming the fee schedule assigned to their accounts. Formative ’s fees for accounts using sub - advisor services may be collected by the platform being used to manage the accounts. Formative ’s investment management fees may be aggregated over the combined accounts the client establishes with Formative under the same fee schedule and within the same management style or program for the purposes of achieving breakpoints and/or simplified fee collection. Accounts using Formative ’s non - fiduciary services will not be aggregated with accounts using fiduciary investment management services. Discounts not generally available to all advisory clients may be offered to family members and friends of advisors, employees, and other associated persons. Formative may also discount fees for non - profit organizations. All fees and expenses will affect the performance of your account, which will fluctuate in value and will provide, upon redemption, more or less than your original investment. Past performance is no guarantee of future results. Model Portfolio Management Fees Proprietary Models may be used as part of the Sustainable Investment Solutions process as well as being made available to third - party RIAs directly or through a variety of third - party platforms.  Where a Proprietary Model is used in the provision of investment advice by Formative , the client pays only the advisory fee to Formative , which includes a model manager fee. The portion of the advisory fee for the model manager is retained by Formative . If Formative makes the model available to a third party outside the context of providing discretionary investment advice directly to a client, Formative ’s fees are negotiated with the third party and range from 10 to 40 basis points (0.10% to 0.40%) of assets that are subscribe d to Formative ’s model. Retirement Plan Consulting Fees Compensation may take the form of an hourly fee or fixed fee. Alternatively, Formative may charge a hybrid of fees to include a percentage of plan assets for services in addition to a fixed fee or hourly rate, depending on the services requested by the client. For standard hourly and fixed fee rates see the Financial Planning Fees section be low. Financial Planning Fees or other Consulting Services Fees for financial plans developed and delivered by IARs are determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon before entering into a contract with any client. The financial planning fees charged by Formative may be calculated and charged on an hourly basis, ranging from $90 to $295 per hour. The financial planning fees charged by Formative also may be charged on a fixed fee basis, ranging from $250 to $5,000, depending on the specific arrangement agreed to in advance with the client. Formative may request a retainer upon completion of our initial fact - finding session with the client; however, advance payment will not exceed $500 for work that will not be completed within six months. Fees Upon Termination of Formative Services With respect to the termination of investment advisory services, Formative will create a final invoice that is pro - rated from the point of the last invoice to the date of  the termination and will be collected from the client account, if Formative still has authorization to do so. If not, Formative will send the invoice to the client for direct payment. The custodian of the client’s account(s) may charge a termination or transfer - out fee, which may change. This fee is determined by the custodian and the monies received are not shared with Formative . With respect to fees that are fixed (not a percentage of assets) and prepaid, Formative will refund the entire fee if the client terminates the agreement within five business days. In addition, if a client decides to terminate the agreement prior to the completion of the engagement for financial planning a partial refund will be provided base d upon the scope of the work already completed. For example, if the IAR has completed one quarter of the work required, three quarters of the fee will be refunded. Item 6: Performance - Based Fees Formative does not charge performance - based fees. Item 7: Types of Clients Formative provides discretionary investment advisory services to the following types of clients: • Individuals (including high net worth individuals) • Trusts, estates, or charitable organizations • Nonprofit organizations and other non - governmental organizations, corporations or other businesses not listed above New accounts are subject to the following asset minimums: VADIS Accounts (Apex and Goldman Sachs): $ 25,000 VADIS Accounts (Schwab and TD): $250,000 Managed Mutual Fund Accounts All Custodians: $ 50,000  Multi- Manager Accounts (Goldman Sachs): $ 50,000 Fixed Income Accounts (Schwab): $250,000 These minimums are negotiable on a case - by- case basis and are dependent on a variety of factors, including but not limited to other accounts in a client household (adults who all live at the same address that have investment accounts with Formative ). Accounts billed for the same program, on the same custodial platform, will be grouped together for breakpoints unless such grouping is prohibited by regulatory rules or Internal Revenue Service (IRS) restrictions. Formative does not accept clients under any restriction relating to the USA Patriot Act or Bank Secrecy Act or comparable legislation. Item 8: Methods of Analysis, Investment Strategies, Risk of Loss Investment Philosophy Formative follows an established investment management process consistent with standards of fiduciary care and with a long - term orientation. Formative ’s experience suggests that the financial planning and investment needs of most socially conscious investors can be met while providing competitive investment returns without a material increase in risk. For most clients, Formative believes that a long - term, diversified approach is the most appropriate investment strategy. Formative supports strategic asset allocation and more active portfolio management strategies. Formative does not offer recommendations concerning direct ownership of commodities , futures, derivatives, or short selling but does offer tactical investment strategies appropriate for some investors. Formative uses the following types of investment vehicles to achieve client goals and objectives, but not all such investment vehicles may be used for a client.  • American depository receipts (ADRs) • Certificates of deposit • Commercial paper • Corporate bonds • Exchange traded funds (ETFs) • Exchange traded notes (ETNs) • Government agency securities • Individual stocks • Municipal bonds • Mutual funds • Options on equities • OTC securities • Other exchange traded securities • Private placements • Real estate investment trusts (REITs) • Warrants Methods of Analysis Formative may use the following methods of analysis in formulating investment advice and/or managing client assets: Asset Allocation. Rather than focusing primarily on securities selection, Formative attempts to identify an appropriate ratio of equities and fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector if it is not included in their allocation. Another risk is that the ratio of equities and fixed income, and cash, will change over time due to stoc k and market movements and, if not corrected, may no longer be appropriate for the client’s goals. Charting. In this type of technical analysis, charts of market and security activity are reviewed in an attempt to identify when the market is moving up or down, to predict how long the trend may last, and when that trend might reverse. While this is a  common method of analysis, there is always the risk that past performance is not representative of future results or that the assumptions made prove to be incorrect. Cyclical Analysis. In this type of technical analysis, the movements of a particular stock against the overall market are analyzed to predict the price movement of the security. There always is the risk that past performance is not representative of future results or that t he assumptions made prove to be incorrect. Values - based Integration. Our approach to sustainable, responsible, and impact investing includes both quantitative and qualitative analysis. Our investment process integrates analysis of environmental, social, and corporate governance factors in portfolio design. Management of en vironment, social, and governance issues and impacts can have a material influence (either positive or negative) on company profitability, value, and share price. Risk is inherent in the fact that a poorly managed or financially un sound company or product may cause the investment to underperform regardless of its mission. Fundamental Analysis. The intrinsic value of a security is analyzed by reviewing economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (su ggesting it may be a good time to buy) or overpriced (suggesting it may be a good time to sell). Fundamental analysis does not attempt to anticipate market movements or changes in value. There is a risk in the fact that the price of a security can rise or fall along with the overall market, regardless of the economic and financial factors considered in evaluating the stock. Mutual Fund, Model, and/or ETF Due Diligence. Formative ’s Mutual Fund and Multi - Manager Model formation process incorporates the objectivity of quantitative analysis and the insights of fundamental research. This two - pronged approach begins with our proprietary Mutual and Model Fund Scores, which encompass bo th financial and sustainability factors. Formative utilizes these Scores as the foundation for in - depth manager reviews. In one - on- one conversations, we assess individual managers to ensure their investments are aligned with our and our clients’ personal values, social priorities, and mission. We do this b y analyzing the firm, portfolio management and research  teams, investment process, and values - aligned integration methodology, as well as proxy voting, corporate actions, and engagement. Finally, we construct well - diversified portfolios designed to deliver risk - adjusted returns to enable investors to achieve their financial goals. We diversify – across asset classes, geographies, sectors, styles, and market capitalizations – to mitigate risk. Well - diversified and structurally sound, our values - aligned Sustainable Investment Solutions are constructed with the probability of enabling our clients to achieve their investment objectives. Fiduciary duty is at the heart of our investment philosoph y. Qualitative Analysis. This type of analysis describes the process of evaluating difficult to quantify factors , such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Quantitative Analysis. Mathematical modeling is used in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share - price or earnings - per - share and predict changes to that data. A risk in using quantitative analysis is that th e models used may be based on assumptions that prove to be incorrect. Risks for all Forms of Analysis and Due Diligence. Formative ’s securities analysis methods rely on the assumption that the companies whose securities Formative purchases and sells, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While Formative is alert to indications that data may be incorrect, there is always a risk that analysis may be compromised by inaccurate or misleading information . Technical Analysis. Historical market movements are analyzed, and that analysis is applied to the present to recognize recurring patterns of investor behavior and predict future price movement. Technical analysis does not consider the underlying financial condition of a comp any. Risk is inherent in a poorly managed or financially unsound company underperforming regardless of market movement.  Third - Party Model Manager and/or Sub - Advisor Due Diligence . Formative examines the experience, expertise, investment philosophies, and past performance of independent Third - Party Model Managers and/or Sub - Advisors in an attempt to determine if there has been demonstrated ability to invest over a period of time and in differ ent economic conditions. Formative monitors the Third - Party Model Manager’s model holdings, strategies, concentrations, and leverage as part of its overall periodic risk assessment. Addi tionally, as part of Formative ’s due diligence process, it surveys a Third - Party Model Manager’s or Sub - Advisor’s compliance and business enterprise risks. The risk of investing using Third - Party Model Manager and/or Sub - Advisors who have been successful in the past is that they may not be able to replicate that success in the future. In addition, as Formative does not control the underlying investments in a Third - Party Model Manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for clients. Moreo ver, as Formative does not control the manager’s daily business and compliance operations, Formative may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Values - Aligned Direct Index Solution (VADIS). VADIS attempts to replicate the performance of an index by purchasing underlying individual equities instead of using an ETF or mutual fund in an investor’s portfolio. Formative ’s portfolio construction expertise and discretionary investment advisory services is implemented in combination with YourStake’s values - aligned client assessment, data collection and organization, analytics, and reporting capabilities for investors who se ek alignment of personal values a nd/or valued - aligned investment portfolios that attempt to replicate the performance of a chosen benchmark in our Values - Aligned Direct Index Solutions. Our VADIS Portfolios are constructed on the Orion Astro platform using client - specific input provided by the investment advisor. These inputs include but are not limited to: • Impact Preferences, which may include individual or lists of companies chosen by the client for exclusion or inclusion in the portfolio  • Benchmarks, which are a combination of the ACWI/AGG aligned with one of our seven risk levels. We may offer custom benchmarks at the request of the Network Advisor for accounts greater than $1,000,000. • Investment strategy constraints and client preferences, such as: o Maximum number of securities o Desired tracking error, security count, and security exposure o Turnover, and trade thresholds, size, and number o Existing legacy positions, specific - company inclusions/exclusions • Tax considerations Investment Strategies Formative uses the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among other considerations: Illiquid Securities. Formative may, from time to time, assist clients with analyzing investments in securities in the areas of unlisted and/or unregistered debt or equity (commonly referred to as “private placements”), which may have no current or anticipated liquidity. Formative will provide investment advice only on such securities that have been passed through and been approved by its due diligence and investment approval processes. When analyzing investments in securities of this type, Formative will us e the following analysis: fundamental, qualitative, quantitative and risk. Long - Term Purchases. Formative purchases securities with the intention of holding them in the client’s account for a year or longer. Typically, this strategy is employed when: Formative believes the securities to be currently undervalued, and/or Formative wants exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long - term purchase strategy is that by holding the security for this length of time, Formative may not take advantage of short - term gains that could be  profitable to a client. Moreover, if Formative ’s predictions are incorrect, a security may decline sharply in value before the decision is made to sell. Short - Term Purchases. When utilizing this strategy, Formative purchases securities with the idea of selling them within a relatively brief period (typically a year or less). Formative does this to take advantage of conditions that it believes will soon result in a price swing in the securities purchased. A short - term purchase strategy poses risks should the anticipated price swing not materialize; Formative is then left with the option of having a long - term investment in a security that was designed to be a short - term purchase or potentially taking a loss. In addition, this strategy involves more frequent trading than a longer - term strategy and could result in increased brokerage and other transaction - related costs, as well as less favorable tax treatment of short - term capital gains. Risk of Loss Investing involves risk, including loss of principal. Each client of Formative must be prepared to bear the risk of loss with respect to each account established. Item 9: Disciplinary Information Formative must disclose any legal or disciplinary events material to a client’s or prospective client’s evaluation of its advisory business or the integrity of its management. Formative and its management personnel and IARs have no disciplinary events, that occurred in the previous ten years, to disclose. Item 10: Other Financial Industry Activities and Affiliations Formative may select Custodian BDs to provide brokerage services to client accounts. Conflicts may arise in the course of Formative ’s selection of Custodian Broker - Dealers. Formative recommends BDs and places orders for the execution of transactions for its clients according to its best execution policies and procedures and consistent with the client’s investment objectives. In selecting a BD as a custodian, Formative may consider a range of factors it deems relevant, including, but not limited to cost of services; timing and speed of execution; responsiveness; creditworthiness and financial stability; likelihood of, and capabilities  in, execution, clearance, and settlement; liquidity in or with an execution venue; and other appropriate factors. After this analysis, the client has sole discretion as to any Formative approved custodian for a Managed Mutual Fund Accounts. For VADIS Accounts Formative provides information on the fees and account minimums for each custodian. Clients should be aware that certain advisory service programs offered by Formative may only be available through a single custodian. Formative receives the same compensation for each of the investment options it offers. There is a financial benefit to Formative when accounts are opened on the Apex platform as disclosed below . This creates a conflict of interest that is mitigated by disclosure. The custodial costs to the client will vary based on the custodian used. Any fees or transaction costs collected by custodians are not shared with Formative . Outside Business Activities of Management Personnel and IARs Formative ’s Management Personnel do not have Outside Business Activities that are material to their roles within Formative . Several Formative IARs are licensed as insurance agents or as tax preparers. Formative does not supervise these outside business activities, nor does it share in any of the revenues from these activities. Selling Agreement, Solicitors/Endorsers Agreement, Sub - Advisor Agreements and Custodial Relationships with Formative There are no referral arrangements between our firm and any RIA firm wherein an individual is an owner, member, officer, or employee of our firm and is also an owner, member, officer or employee of another firm. This includes any other RIA disclosed as required in Section 7.A. on Schedule D of Form ADV, Part I. (Part I of our Form ADV is available on the SEC’s website at www.adviserinfo.sec.gov where you can search by using CRD number 109036). No Formative client is obligated to use the advisory services of any other RIA, as no other RIA advisory client is obligated to use Formative ’s advisory services.  Managing Other Potential Conflicts Insider Trading Our firm and/or individuals associated with our firm may buy or sell for their personal accounts, securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security or securities which may also be recommended to a client. Formative has established written policies and procedures for insider trading that prohibit any owner, member, officer, or employee of our firm from buying, selling, or recommending securitie s where the decision is substantially derived, in whole or in part, from non - public information, information about other Formative Clients. or made based on the potential personal gain of the owner, member, officer or employee. Compensation Conflicts Costs and Compensation for Rollover Recommendations. Rollover recommendations have associated fees payable to Formative and their Network Advisor. These fees might be more or less than the fees or commissions charged to the Client by the Plan, other Consultants, or Brokers, as applicable. This creates a conflict of interest. The Network Advisor making the recommendation pro vides full disclosure of the associated costs and their compensation so a client can make an informed decision before accepting the reco mmendation. This disclosure attempts to mitigate the conflict of interest. Fees Paid to Network Advisors by Formative relating to Discretionary Investment Management . A portion of the fees collected by Formative are shared with Network Advisors and Solicitors to compensate them for their services. If the Network Advisor is an IAR, Formative compensates the IAR directly, except for any compensation he or she may earn on the provision of tax preparation services and life insurance sales. If the Network Advisor is associated with a third - party RIA firm with a selling or solicitor’s agreement, a third - party RIA firm with a sub - advisor’s agreement, or a third - party BD with a solicitor’s agreement, with Formative , Formative collects the  applicable fee from the client assets and the Network Advisor’s share of the fee is paid to the BD or RIA firm, which in turn pays a substantial portion of the fee to the Network Advisor. The BD or RIA firm typically retains a small portion of the Network Advisor share to compensate itself for administration and other overhead. Costs and Compensation for Rollover Recommendations. Rollover recommendations have associated fees payable to Formative and their Network Advisor. These fees might be more or less than the fees or commissions charged to the Client by the Plan, other Consultants, or Brokers, as applicable. This creates a conflict of interest. The Network Advisor making the recommendation pro vides full disclosure of the associated costs and their compensation so a client can make an informed decision before accepting the reco mmendation. This disclosure attempts to mitigate the conflict of interest. Other Compensation Earned by Third - Party BD and RIA Network Advisors. Third - party firms compensate their advisors for providing other products or services to clients, neither Formative nor any Network Advisor receives any transactions - related or variable compensation for the sale of securities or other investment products, including asset - based sales charges or service fees from the sale of mutual funds relating to any product or service offered by or on behalf of Formative . Formative takes the following steps to address compensation conflicts: • Collects, maintains and documents accurate, complete, and relevant client background • information, including the client’s financial goals, objectives, and risk tolerance. • The firm’s management conducts regular reviews of client accounts to evaluate whether the recommendations made to a client are in the client’s best interests. • Requires that employees seek prior approval of any outside employment activity so that Formative may determine if any conflicts of interest in such activities are properly addressed. • Periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed.  • Educates employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for investment advice provided to clients. • Requires all IARs to acquire and maintain the Accredited Investment Fiduciary (AIF), or comparable professional designation to provide initial and ongoing training in the duties of investment fiduciaries. Other Compensation for use of Proprietary Models. Formative recommends multi - manager models that are proprietary. Formative retains the portion of the revenues allocated for compensation to model managers. Formative ’s models are reviewed against similar non - proprietary models and are included only if the model is suitable for the client portfolio. Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its owners, members, officers, or employees when making advisory recommendations or when providing non - discretionary investment management services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. The Department of Labor’s Rule 3.0, known as the Fiduciary Rule, requires investment fiduciaries to review the costs associated with rolling ove r ERISA plan assets to another retirement vehicle. A conflict of interest occurs if the advisor will earn a new fee or increases her/his current compensation as a result of the rollover. There also is the possibility of conflicts of interest between client s and any Network Advisor if the service is provided for variable compensation. Formative offers fee - based compensation which tends to reduce, or change mitigate the possibility of conflicts of interest but cannot eliminate them entirely. While Formative ’s intent to always offer advice that is in the best interest of the client, it is the client’s responsibility to evaluate that advice and determine if it is appropriate before acting. No client is obligated to accept any recommendation, including recommenda tions regarding rollovers, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. If an advisor uses Formative ’s non - fiduciary services the fees for administration and, if applicable, model management, are disclosed above.  Other Compensation Paid to IARs. In addition to receiving a portion of the fee for discretionary investment management, IARs receive a portion of any fees charged for financial planning, hourly consultation or other services provided under nondiscretionary investment management agreement s. One IAR is a member of Formative senior management and the Investment Committee. In his role, he provides investment advisory services to individual clients, while also working on developing Proprietary Models. Proprietary Models developed by this IAR are subject to the same selection and review process as other Third - Party Models and other Proprietary Models. Further, he does not receive compensation relating to his development of Proprietary Models. Cybersecurity. Risks included in the use of electronic systems include the fact that as the technologies continue to grow so do the varied methods used by cyber criminals. The risks include costs and consequences of business interruptions, lost revenue, ransom payments, remediation costs, liabilities to affected parties, cybersecurity protection costs, lost assets, litigation risks, reputational damage, and rapid monetization of cyberattacks. Formative works closely with third party providers for informatio n technology services that include protection of information and ongoing security awareness training. Item 11: Code of Ethics, Participation, or Interest in Client Transactions, Personal Trading Formative has adopted a code of ethics (the Code) which sets forth high ethical standards of business conduct that are required of employees and IARs, including compliance with applicable federal securities laws. Formative has adopted the Code to instruct and guide its personnel in their ethical and fiduciary obligations to clients. The Code also provides rules and requirements regarding the personal securities trading practices of Formative ’s IARs and staff. Formative , its personnel, and its IARs owe a duty of loyalty, fairness, and good faith toward all clients and are obligated to adhere not only to the specific provisions of the Code but to the general principles  embodied in the Code. The Code is designed to ensure that the personal securities transactions, activities, and interests of Formative employees will not interfere with making decisions in the best interest of advisory clients and implementing such decisions while, at the same time, allowing employees to invest in their own accounts. The Code covers a range of topics that include the following: general ethical principles, reporting of personal securities trading, exceptions to reporting securities transactions, reportable securities, initial public offerings, and amendments to Form ADV and supervisory procedures. A copy of the Code is available to investment advisory clients and prospective clients. You may request a copy by email sent to our Chief Compliance Officer, Kathy Lewis at compliance@firstaffirmative.com , or by calling 719 - 660 - 6157. Item 12: Brokerage Practices Factors Considered When Recommending a BD Custodian For clients in need of brokerage or custodial services, and depending on client circumstances and needs, Formative may recommend the use of one of several brokers (including, but not limited to Schwab, Apex, Goldman Sachs, and SEI). Although Formative requires that clients establish accounts at one of these brokerage firms, it is the client’s decision whether to have accounts under management or accounts sub - advised by Formative , and thus, custodied by one of the recommended custodians. Formative ’s use of o ne of these brokerage firms to custody client accounts is not contingent upon the firm committing to any specific amount of business (assets in custody or trading commissions). Formative ’s clients or RIA firms retaining Formative to act as a sub - advisor must evaluate these custodial broker - dealers before opening an account. The factors Formative consider a BD’s ability to provide professional services, Formative ’s own experience with the firm, the BD’s reputation, their quality of execution services, their ability to trade fractional shares, as applicable, and costs of such services, among other factors.  Formative uses the Astro module on the Orion Advisor Technology (OAT) platform. Formative uses the Astro platform for all client accounts not just those on the Apex custodial platform. Brokerage for Client Referrals Formative does not have referral arrangements with any of its custodian Broker - Dealers. Directed Brokerage Formative accepts investment management accounts only when a client authorizes discretionary trading authority to Formative . Clients do not conduct brokerage transactions themselves, but rather only through communication with Network Advisors. Clients do not conduct brokerage transactions themselves but only through communication with Network Advisors. However, certain programs offered by Formative are only offered through a single BD custodian and in choosing that program the client agrees and instructs us to send their orders for execution to that BD custodian. In such situations, clients cannot direct Formative to execute transactions through a specified BD other than the BD custodian. Aggregation of Client Securities Transactions Our firm does not aggregate purchase and sale orders from various client accounts. However, orders can be aggregated by the Custodian. Such orders, if combined or “batched,” to obtain better execution, to negotiate more favorable commission rates, if appli cable, or to allocate executions equitably, could provide clients with better prices or transaction costs than if the trades were placed independently. Neither Formative nor any Custodian is obligated to combine or batch any such orders. If orders are sent to Folio for execution as part of its patented “Window Trade” process, instead of being executed immediately, the order will be aggregated with other orders received for execution in one of its Trading Windows, which occur generally around 11 a.m. ET and 2 p.m. ET. In the Window Trade process, for each Window, Folio aggregates orders designated for the next trading Window based on the ticker symbol of each security and whether it is a buy or sell order. An aggregated order may include any combination of or ders from your accounts and other customer  accounts. Folio generally routes aggregated orders to a market maker for execution or to a mutual fund company for fulfillment. All Folio customers receive the same execution price for any given Window trade. Additional information on the Window Trading pr ocess can be found at Goldman Sachs’ website: https://www.folioinstitutional.com/footer/disclosures.jsp . Orders may be aggregated by a third - party separate third - party account manager executing transactions at Schwab for accounts custodied at Schwab. Trade placement at any of our approved custodians is on a best - efforts basis. We will attempt to place trades on the day funds are received or trade requests are made. However, in certain circumstances that may not be possible. In that case trades will be placed on the next business day or when the circumstances delaying the trading are resolved. Item 13: Review of Accounts Reports to Clients Clients receive account statements at least quarterly detailing deposits, withdrawals, purchases, sales, dividends, interest, fees deducted from the account and any other activity, from the custodian of the account. Clients may also receive confirmation of every trade executed in their account(s), which should be saved for tax purposes. Formative and its service providers will also make quarterly performance reports available to all clients. Depending on the custodian and/or the service provider, such performance reports may be made available for an annual fee, which is not included in the discretionary investment management fees described in Item 5 above. Most clients have access to their accounts via the internet, but Formative also provides quarterly reports and 24/7 access to clients through a Client Portal via the OAT platform. These reports may include a performance comparison utilizing historical data and may propose an alternative optimal portfolio design. Formative can also provide reports on the social and ethical issues associated with a portfolio of specific common stocks.  Client Account Reviews Network Advisors and Solicitors. Each Network Advisor can view all positions and activities in his/her client account(s) via the internet, and each Network Advisor has access to all reports provided to their client(s) through the Advisor Portal via the OAT platform. Network Advisors are e xpected to review activity in client accounts quarterly, to periodically discuss the account with the client, and to ensure the suitability of the investment services provided based on each client’s specific situation. Network Advisors need to specifically monitor client accounts for which they are using non - fiduciary services. The sole fiduciary duty to the client rests with the Network Advisor and their supervising BD or RIA firm, if applicable. Formative will include the OAT platform in its services to advisors using non - fiduciary services. Information on non - fiduciary accounts will be available for maintenance by Formative and review by the Fiduciary Advisor. Supervising BD or RIA Firms. Each third - party BD and/or RIA with which Formative maintains a selling or solicitor’s agreement also is responsible for developing its own independent procedures to review client accounts and supervise the activities of its representatives. Sub - Advisors. Third - Party Model Managers who are responsible for managing portions of Formative client accounts are also responsible for ongoing review and supervision of transactions in the client accounts they manage. Third - Party Model Managers responsible for managing portions of Formative client accounts are also responsible for ongoing review and supervision of transactions in the client accounts they manage. Company Management. Formative ’s senior management, including members of the Investment Committee, conduct both periodic reviews and various systematic samplings of accounts to supervise and ensure compliance with investment policy. Formative also monitors the performance of the VADIS portfolio construction workflow.  Item 14: Client Referrals and Other Compensation Other Compensation It is Formative ’s policy not to accept or allow its 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 it provides to our clients. Client Referrals Formative may pay referral fees to firms (“Solicitors”) for introducing clients. These fees are asset - based. When the solicitor is associated with a third - party BD or RIA, they are paid over the relationship's life. Whenever Formative pays a referral fee, it requires the Solicitor to provide the prospective client with a copy of this document, the wrap fee document if applicable, an Investment Advisory Services Agreement (IAS), and a separate disclosure statement that includes the follo wing information: 1. The Solicitor’s name and relationship with Formative . 2. The fact that the Solicitor is being paid a referral fee. 3. The amount of the fee. As a matter of firm policy, a client working with a Solicitor will not be charged more than any other client. Item 15: Custody Client funds and securities are held by one of the BD custodians identified in Item 12, for safekeeping. Clients will receive account statements directly from their custodian and should carefully review those statements. In addition, Formative provides access to performance reports on a quarterly basis as well as continual access to their account and the ability to run their own reports through the OAT platform. Formative urges clients to carefully compare the information provided on these reports to ensure that all account transactions, holdings, and values are correct and current. Additionally, Formative is deemed to have “custody” of client assets, as that term is defined under the Investment Advisers Act of 1940, as amended, (Act) for accounts held at Schwab and Apex for which Formative has been granted the limited power to initiate distribution instructions via a signed standing letter of authorization (SLOA).  All firms that are deemed to have custody because of SLOAs, must undergo an annual surprise audit by a third - party audit firm unless the custodian of the client funds and securities meets seven requirements set by the SEC. Schwab and Apex meets those requ irements and, therefore, Formative is not required to have a surprise annual audit. Item 16: Investment Discretion Clients may hire Formative to provide discretionary investment management services, in which case Formative places trades in a client’s account without contacting the client prior to each trade to obtain the client’s permission. Formative ’s discretionary authority includes the ability to do the following without contacting the client: • Determine the security to buy or sell; and/or • Determine the amount of the security to buy or sell; and/or • Determine when to add or replace a Third - Party Model Manager and/or Sub - Advisor Clients give Formative discretionary authority when they sign an Investment Advisory Services Agreement. Formative ’s ability to manage client accounts is dependent upon having the above discretionary authority granted by the client. The client can place reasonable restrictions on certain securities but cannot limit Formative ’s ability to act upon the instructions given to the firm in the Investment Policy Statement (IPS). Clients of firms using Formative as a sub - advisor will grant discretion to Formative on the paperwork required by the custodian(s). However, clients must expressly authorize advisors, in writing, to p lace trades for them for illiquid securities on the VIA Folio platform. Client accounts under Formative ’s non - fiduciary services do not give Formative discretion over their accounts. Formative ’s authorizations on non - fiduciary client accounts are limited to access to client accounts for viewing and billing and non - discretionary trading.  Item 17: Voting Client Securities Proxy Voting Owners of company stock and mutual fund shares have a right to be heard on matters put before shareholders for a vote. Shareholder voting is the primary means by which shareholders can influence a company or mutual fund’s operations, its corporate governan ce, and other activities that may fall outside of financial considerations. You have provided Formative discretion in managing your accounts, we will vote your proxies consistent with our Proxy Voting Guidelines, except in the circumstances described below or if you instruct us that you do not wish for Formative to vote your proxies. You are provided with a copy of Formative ’s Proxy Voting Guidelines at the time you open your account with us and annually thereafter. These guidelines are also available on our website and upon request as described below. We believe one of the reasons you have chosen Formative to provide you with advisory services is our commitment to socially responsible investing, which includes voting proxies consistent with this philosophy, as is reflected in our Proxy Voting Guidelines. Therefore, you must notify us in writing and instruct us how you would li ke us to vote for your proxies if you do not want them voted as described in the Proxy Voting Guidelines. To assist with proxy voting, Formative has an arrangement with an independent governance analysis and proxy voting firm to provide research to Formative and to vote proxies based on Formative ’s Proxy Voting Guidelines. The independent third - party firm will vote on all holdings in which Formative clients have a material interest, defined as all shares held at Schwab, Goldman Sachs, SEI, and Apex. Formative does not vote proxies at any other custodians. As described above, voting of client proxies is based upon social responsibility concerns, as well as financial considerations, as reflected in the Proxy Voting Guidelines which are updated at least annually. As described above, client proxies voting is ba sed on social responsibility concerns and financial considerations, as  reflected in the Proxy Voting Guidelines, updated at least annually. The independent third - party proxy voting service discloses to Formative , at least annually, potential conflicts of interest between their research/proxy voting services and their corporate governance consulting services and their procedures for limiting such conflicts. Clients should be aware that they are under no obligation to assign proxy voting duties to Formative . Clients may choose from proxy voting options that are offered by their custodian. For example, accounts held at Goldman Sachs offer a client the right at any time, even if proxy voting has been delegated to Formative , to vote any individual proxy themselves and override any vote that may be cast by the proxy voting service hired by Formative . This is not possible at Schwab. In that case the client must with draw the authorization for Formative to vote proxies to avoid voting in accordance with the Formative guidelines. If the client does not authorize Formative to vote their proxies according to our Proxy Voting Guidelines at Schwab, they should not check the box on the account application authorizing such votes. If the client does not authorize Formative to vote their proxies at Goldman Sachs, they must vote their own proxies by logging into their Goldman Sachs account. Any proxies voted by Formative can be overridden by the client. When Formative acts as a sub - advisor at SEI clients can authorize Formative to vote their proxies. The sub - advisor, the advisor, or the client must be the assignee on the record date to vote proxies. If the client does not authorize Formative to vote their proxies at Apex, they must vote their own proxies which they will receive via US Mail. Clients may obtain a copy of Formative ’s Proxy Voting Guidelines by visiting the Formative website ( www.firstaffirmative.com ), sending an email to service@firstaffirmative.com or proxyvoting@firstaffirmative.com , or by sending a request in writing to the address listed on the cover page of this document. Clients may request information on how proxies for his/her shares were voted and Formative will promptly provide such information to the client. With respect to ERISA accounts, Formative will vote proxies if granted that authority unless the plan documents specifically reserve the plan sponsor’s right to vote  proxies. To direct Formative to vote a proxy in a particular manner, clients should send an email to proxyvoting@firstaffirmative.com . Formative does not vote proxies for the following types of accounts: • Accounts held in custody by Schwab that have not granted Formative authority to vote proxies . • ERISA accounts that specifically require the plan sponsor to vote the proxies; and, • Accounts that participate in the OPS Wrap Fee Program. In situations where Formative does not vote proxies, proxy documents are delivered via U.S. Mail for Schwab accounts and are accessible by logging into the Goldman Sachs website for advised clients, www.folioinstitutional.com . Clients may choose from proxy voting options that are offered by SEI, and Apex. Upon request, Formative and its IARs may provide information about proxy issues to clients who have chosen to vote on their own proxies. Clients can instruct Formative to vote proxies according to criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so - called “poison pill” defense against a possible takeover). These requests must be made in writing. Clients can also instr uct Formative on how to cast their vote in a particular proxy contest by sending an email to proxyvoting@firstaffirmative.com . There is a remote possibility that Formative employees or IARs have a relationship with a public corporation which may put their interests at odds with those of clients in the Proxy Voting process. These personnel are required to disclose to the Chief Compliance Officer any such relationships and are required to recuse themselves from participating in votes related to such companies. Advisors with Clients using our non - fiduciary services can opt - in to our proxy voting services by requesting such authorization form allowing access to Formative . Item 18: Financial Information Under no circumstances does Formative require or solicit payment of fees in excess of $500 per client more than six months in advance of services rendered. Therefore, Formative is not required to include a financial statement in this disclosure document.  As an advisory firm that maintains discretionary authority for client accounts and maintains custody of client assets held for clients at Schwab, SEI, and Apex, granting Formative authorization under a SLOA, Formative is also required to disclose any financial condition that is reasonably likely to impair its ability to meet its contractual obligations. Formative has no additional financial circumstances to report. Formative ’s financial statements are audited or reviewed each calendar year by a qualified, independent CPA firm. 

Summary of Material Changes to the ADV Disclosure Brochure Consistent with SEC rules, annual updates that are material in nature are required to be provided to all clients of First Affirmative Financial Network, LLC DBA Formative (“Formative”) through a “Material Changes” document within 120 days of the close of the firm’s fiscal year, which is the calendar year. Throughout the year, all clients will be provided with additional information about material changes, as necessary. This summary of the material changes to the Disclosure Brochure (Summary of Material Changes) is intended to provide you with sufficient information to determine whether you would like to review the Disclosure Brochure in its entirety. You can obtain an electronic copy of the current Disclosure Brochure and this Summary of Material Changes in a publicly accessible area on the Formative website at www.firstaffirmative.com or by contacting Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov. You can search the SEC’s website for information about a registered investment advisor (RIA) by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. First Affirmative Financial Network, LLC’s doing business as (DBA) name, is Formative. 

April 17, 2026 Item 1: Introduction First Affirmative Financial Network, LLC DBA Formative (“Formative ”) is registered with the Securities & Exchange Commission (“SEC”) as an investment advisor. Our services and fees are different than the services provided by a brokerage firm. It is important to us that you understand the differences. At Investor.gov/CRS , research firms and financial professionals can access free and simple tools and educational materials about broker - dealers, investment advisors, and investing. Item 2: Relationships and Services ➡️ What Investment services and advice can you provide me? For more information about our services, please see our ADV Disclosure Brochure . We can provide you (a retail investor) with investment advice on a discretionary basis. You can access our services either through Formative by establishing a relationship with one of our investment advisor representatives or in conjunction with a relationship you establish with another investment advisor or broker - dealer, who are independent of Formative , but who offer access to our services. We also offer non - discretionary administrative services to independent investment advisors or broker - dealers. We will ask you about your investing goals, your risk tolerance, and other information to develop an Investment Policy Statement (IPS), which is your investment strategy. However, it is necessary to implement your strategy. We will not make changes to your investment strategy without your written approval although we do allow changes either up or down one risk level without a signature. As a part of our standard services, we monitor investor accou nts and review accounts quarterly on a best - efforts basis. Pl ease see our ADV Disclosure Brochure under Client Account Reviews for more information. Some of our investment programs are available through wrap fee programs, whereas others are not. See our ADV Disclosure Brochure for a description of the investment programs and their availability. Minimum investments vary by program and custodian based on services available with the lowest minimum being $25,000, which is negotiable under certain circumstances. We incorporate values - alignment analysis into your investing strategy, which allows you to include or exclude companies or industries from your portfolio consistent with your social goals. These values include sustainable, responsible, impact investing (SR I), environmental, sustainability, and governance investing (ESG), and faith - based investing. We primarily use equity securities, mutual funds, exchange traded funds and in some cases, individual bonds. We do not use proprietary investment vehicles other t han proprietary models at certain custodians. We also offer financial planning services through some of our investment advisor representatives. Financial planning services are not included as part of our investment advisory services and you must pay separate fees for the financial planning service, wh ich are charged based on a flat fee or an hourly basis. Conversation Starters: Given my financial situation, should I choose an investment advisory service? Why or why not? How will you choose investments to recommend to me? What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean? Item 3: Fees, Costs, Conflicts, and Standard of Conduct ➡️ What fees will I pay? We will charge you fees based on a percentage of the average daily balance of your assets under management with us over the previous calendar quarter. The percentage will differ depending on the investment strategy you choose,  including whether the strategy is available through a wrap fee program. Wrap fees include the charges for our advice, the fees for custody of your assets, the cost to execute your trades, and, if requested, the fees charged by your investment advisor. The wrap fee does not include incidental charges such as wire fees. If you choose an investment program not offered through a wrap fee program, the asset - based fee will cover our advisory services, but not the cost of custody or trade execution. Because wrap f ees include the cost for advice, custody and trade execution, the fee you pay may be more than if you were to pay for these services individually and are more than fees just for advisory services. Please see our Apex Wrap Fee Brochure , Goldman Sachs Wrap Fee Brochure , and our Orion Wrap Fee Brochure for more information about wrap fee costs, and our ADV Disclosure Brochure , Item 5.E. for a schedule of fees by investment strategy. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Conversation Starter: Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go toward fees and costs, and how much will be invested for me? ➡️ What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have? When we act as your investment advisor, we must act as a fiduciary and put our best interests after your best interests. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these confli cts because they can affect the investment advice we provide you. Here is an example to help you understand what this means. As your account grows, we will make more and therefore have an incentive to increase the assets in your account(s). For more information about conflicts of interest please see our ADV Disclosure Brochure . Conversation starter: How might your conflicts of interest affect me, and how will you address them? ➡️ How do your financial professionals make money? Our financial professionals receive a portion of the asset - based fees that you pay us to manage your account, which can provide them with an incentive to increase assets in your account. Item 4: Disciplinary History ➡️ Do you or your financial professionals have any legal or disciplinary history? Yes, a control person of Formative had a disciplinary action in 1989 prior to their employment with Formative . In addition, one of Formative’s IARs had a charge against them in 2009 that was dismissed. No other disciplinary or legal event has occurred regarding Formative , its staff, or its Investment Advisor Representatives (IARs). You should visit investor.gov for a free and easy search tool to research Formative and your financial professional. Conversation starter: As a financial professional, do you have any disciplinary history? For what type of conduct? Item 5: Additional Information You can find more information on us and our services at www.firstaffirmative.com . Under the About tab, Disclosures, you can find our ADV Disclosure Brochure , Goldman Sachs Wrap Fee Brochure , Apex Wrap Fee Brochure , and Orion Wrap Fee Brochure , and a copy of this Client Relationship Summary. We can also be reached at 719- 478 - 7036. Conversation Starter: Who is my primary contact person? Is he or she a representative of an investment advisor or a broker - dealer? Who can I talk to if I have concerns about how this person is treating me? 

Summary of Material Changes to Form CRS Consistent with SEC rules, annual updates that are material in nature are required to be provided to all clients of First Affirmative Financial Network, LLC DBA Formative (“Formative”) through a “Material Changes” document within 120 days of the close of the firm’s fiscal year, which is the calendar year. Throughout the year, all clients will be provided with additional information about material changes, as necessary. This summary of the material changes to the Form CRS (Summary of Material Changes) is intended to provide you with sufficient information to determine whether you would like to review the Form CRS and ADV Disclosure Brochure in their entirety. You can obtain an electronic copy of the current Form CRS and ADV Disclosure Brochure and this Summary of Material Changes in a publicly accessible area on the Formative website at www.firstaffirmative.com or by contacting Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov. You can search the SEC’s website for information about a registered investment advisor (RIA) by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. First Affirmative Financial Network, LLC’s doing business as (DBA) name, is Formative. 

Form ADV Part 2A – Appendix 1A April 17, 2026 Goldman Sachs Advisor Solutions Wrap Fee Brochure for Clients and Prospective Clients of First Affirmative Financial Network, LLC DBA Formative Item 1: Introduction and Overview This Wrap Fee Brochure provides information about the qualifications and business practices of First Affirmative Financial Network, LLC DBA Formative (“Formative”). Capitalized terms not defined in this Wrap Fee Brochure are defined in Formative’s Form ADV Part 2A (Disclosure Brochure). Formative is an independent, employee-owned, and managed investment advisor registered (RIA) with the U.S. Securities and Exchange Commission (SEC) with its principal place of business at 5475 Mark Dabling Boulevard, Suite 320, Colorado Springs, CO 80918. The fact that Formative is registered with the SEC should not be read as an endorsement of Formative or that Formative has a certain level or training. This Wrap Fee Brochure is required to be delivered to any prospective client of the Formative sponsored wrap fee program involving Goldman Sachs Advisor Solutions (Goldman Sachs) prior to or at the time of entering into an investment advisory relationship with Formative that includes participation in the Goldman Sachs Wrap Fee Program.) Formative also sponsors a wrap fee program involving Orion Portfolio Solutions, (OPS) (OPS Wrap Fee Program) and Apex Clearing, Inc. (Apex) (Apex Wrap Fee Program.) A separate Wrap Fee Brochure is available for clients whose investment advisory relationship with Formative includes participation in the OPS Wrap Fee Program and/or the Apex Wrap Fee Program. An electronic copy is available on a publicly accessible area on the Formative website www.firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov. You can search the SEC’s website for information about an RIA by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. You can also access an electronic copy of this document in a publicly accessible area on the Formative website www.firstaffirmative.com. If you have any questions about the contents of this Wrap Fee Brochure, please contact Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. While submitted to the SEC, the information in this Wrap Fee Brochure has not been approved or verified by the SEC or by any state securities authority.  Item 2: Material Changes Consistent with SEC rules, Formative updates this Wrap Fee Brochure at least annually, within 90 days of the close of its fiscal year, which is December 31. If there are material changes from the prior annual update of this Wrap Fee Brochure (and you received a prior version of this Wrap Fee Brochure), such changes will be set forth in the “Summary of Material Changes” accompanying this Wrap Fee Brochure. Item 4: Services, Fees, and Compensation Description of the Goldman Sachs Wrap Fee Program Goldman Sachs Advisor Solutions (Goldman Sachs) and Folio Investments, Inc. (Folio) are Goldman Sachs Companies. The Goldman Sachs Wrap Fee Program applies to discretionary investment advisory services offered by Formative, through its Network Advisors or Solicitors/Endorsers (as defined in the Disclosure Brochure), consistent with its Sustainable Investment Solutions advisory offering (as described in the Disclosure Brochure). Formative serves as a Multi-Manager Account Manager (MLT) a Managed Mutual Fund (MMF) Account Manager, and the Account Manager for Values Aligned Direct Index Solutions (VADIS) accounts described below. As a MLT Account Manager, Formative may use proprietary investment model portfolios constructed and managed by Formative (Proprietary Models) as well as models selected by Formative that are constructed and managed by third- party unaffiliated investment advisors (Third-Party Models). As a MMF Account Manager with respect to accounts custodied at Goldman Sachs, Formative only recommends Proprietary Models to clients. An example of our billing method can be found in the Disclosure Brochure. Wrap Fee for the Goldman Sachs Wrap Fee Program - Fiduciary The Goldman Sachs Wrap Fee Program fee includes all costs for investment management, trade execution, and custody and clearing, unless specifically noted as a separate charge below. Fees on assets included in the Wrap Fee Program are charged as a percentage of assets under management, annualized, in arrears, using the average daily balance calculation method. Fees are charged quarterly according to the schedule below. Fees for services provided by Network Advisors or Solicitors/Endorsers are in addition to the fees presented below and will be collected along with the Formative fees as described below as part of the wrap fee. Tiers Cumulative (For Internal Use) Formative: Discretionary Investment YourStake: Impact Preferences Goldman Sachs: Custody Goldman Sachs: Model  Advisory Services & Clearing 2,000,000 2,000,000 0.31% Platform (Required for VADIS) 0.05% 0.09% Manager fees as applicable 0.35% 8,000,000 10,000,000 0.26% 0.05% 0.09% 0.35% 10,000,000 20,000,000 0.21% 0.05% 0.09% 0.35% On the First On the Next On the Next Above 20,000,000 0.21% 0.05% 0.09% 0.35% Third-Party Model Managers (also referred to as portfolio managers) utilized by Formative when advising a Multi-Manager Account are paid a portion of the maximum fee shown above. Proprietary Models are also available to Network Advisors and Solicitors/Endorsers to provide discretionary investment advice to clients on the Goldman Sachs platform. When a Proprietary Model is used in a Multi-Manager Account by a Network Advisor or Solicitor/Endorser, Formative is paid as the Model Manager. The same methodology for determining which Model Manager to use for any client account is not influenced by, or biased toward, Proprietary Models. New accounts are subject to the following minimums: Managed Mutual Fund Accounts: Multi-Manager Accounts: $ 50,000 $ 50,000 The account minimums are negotiable on a case-by-case basis and are dependent on a variety of factors, including but not limited to other accounts in a client household (adults who all live at the same address who have investment accounts with Formative). Accounts billed for the same program at Goldman Sachs will be grouped together for breakpoints unless such grouping is prohibited by regulatory rule or Internal Revenue Service (IRS) restrictions. The Wrap Fee may be more or less than the aggregate fee for services if they were offered separately. Some factors that may contribute to the relative cost differential include, but are not limited to, the brokerage and clearing costs, commissions based on trading frequency or commissions based on type of security (e.g., mutual fund or ETF versus single stock), and the mutual fund share classes that may be available. Additional information regarding the billing process is available in the Disclosure Brochure. Mutual Fund Expenses  Mutual funds have internal expenses, such as portfolio management, legal and accounting, printing, marketing, trading costs and other administrative expenses, including fees paid to custodians. Fund expenses are more fully disclosed in each mutual fund prospectus. They are accounted for and charged internally by the mutual funds and monies collected or retained are not shared with Formative, any affiliate of Formative or any Network Advisor or Solicitor/Endorser. Any mutual fund sale within a defined period of time may, per the mutual fund prospectus, after the initial purchase may trigger a contingent deferred sales charge by the mutual fund company on the transaction. These charges vary among the mutual funds that are held in a client account. Compensation for Accounts Under Title I of the Employee Retirement Income Security Act (ERISA) Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its owners, officers, investment advisor representatives, or employees when providing advisory services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. The Department of Labor’s Rule 3.0, known as the Fiduciary Rule, requires investment fiduciaries to review the costs associated with rolling over ERISA plan assets to another retirement vehicle. A conflict of interest occurs if the advisor earns a new fee or increases its current compensation as a result of the rollover. There also is the possibility of conflicts of interest between clients and any Network Advisor if the service is provided for variable compensation. Formative offers fee-based compensation which tends to reduce or change the possibility of conflicts of interest but cannot eliminate them entirely. Formative always offers advice that is in the best interest of the client. It is the client’s responsibility to evaluate that advice and determine if it is appropriate before acting. No client is obligated to accept any recommendation, including recommendations regarding rollovers, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. Mutual Fund Company Payments to Custodians Rule 12b-1 fees are defined as annual marketing or distribution fees on mutual funds. These expenses are included in the fund’s expense ratio and are in some cases shared with custodians. Formative may place trades in mutual funds that pay compensation to custodians. 12b-1 fees paid to custodians are not shared with Formative. As part of Formative’s fiduciary duty, we will evaluate the costs associated with mutual funds to determine which fund, or share class of a fund, is most suitable for client portfolios. If appropriate, Formative will exchange share classes to a less expensive share class. In taxable accounts, these exchanges will be done, when possible, with the fund companies as tax-free exchanges.  Additional Goldman Sachs Fees Transaction-Based Pricing Non-retirement accounts will be charged on a per transaction basis when the security to be bought or sold is ineligible for trading in Folio’s patented window trade process. In such circumstances, your order will be routed and executed as a direct trade and charged the following fees. Telephone Internet $45.00 per trade $3.95 per trade Goldman Sachs also will charge the account transaction fees based on the above schedule if securities are transferred into a non-retirement account and need to be sold to implement a client’s new investment strategy. Fees Upon Termination of Services Goldman Sachs may charge a termination or transfer-out fee, that may change from time to time. This fee is determined by Goldman Sachs and the monies received are not shared with Formative. Mutual Fund Transaction Commissions Charged to Clients Some mutual funds that are included in client investment portfolios offer different types of shares, known as “share classes.” Each share class has different shareholder services and/or distribution arrangements with different fees and expenses and, therefore, different performance results. For example, class A shares, also called “retail shares”, usually have a front-end load or charge (commission) which is paid to the custodial BD when the mutual fund is purchased. Institutional class shares, in contrast, generally are available only to institutional investors and may have very different fees and expenses from class A shares, but generally do not require front-end commissions. See the SEC website, the Financial Industry Regulatory Authority website or the relevant mutual fund share prospectus for additional information regarding share classes. Formative generally uses only institutional class shares with no front-end loads in the Managed Mutual Fund Accounts custodied with Goldman Sachs and, to the extent it does use a mutual fund that typically has a front-end load, Formative will do so only if the front-end load is waived. There is no transaction fee charged to clients for purchasing mutual fund shares at Goldman Sachs. Incidental Fees  In addition to the fees above, clients are still responsible for any special fees incurred at the client’s request, such as wire transfer fees, or account maintenance fees, which are charged and disclosed by Goldman Sachs. Such fees are subject to change and can be found at: https://www.folioinstitutional.com/resources/service-fees.jsp Margin Goldman Sachs margin accounts are not available. Costs for Third-Party Services Goldman Sachs passes through the costs from third parties, including, but not limited to, the following: • Services provided by broker dealers other than Goldman Sachs • SEC and securities exchange fees • Transfer taxes • Fees for odd lot differentials • Mutual fund short-term redemption fees; and • Other similar costs and charges. Compensation to Network Advisors and Solicitors/Endorsers relating to Client Participation in the Goldman Sachs Wrap Fee Program Network Advisors and Solicitors/Endorsers are compensated from the Wrap Fee. The amount of this compensation may be more or less than the compensation the Network Advisor or Solicitors/Endorsers may receive if not recommending, or introducing the client to, the Goldman Sachs Wrap Fee Program. This may create a conflict of interest in that the Network Advisor or Solicitor/Endorser may have a financial incentive to recommend the Goldman Sachs Wrap Fee Program over other programs and services. Indirect Compensation Specific to Custodians. Formative is charged an annual fee per client account to Orion Advisor Technology (OAT) for their Astro platform. This technology allows us to design, implement, and reoptimize portfolios. Formative employs this technology for accounts held at each of our approved custodians. Apex Clearing pays OAT a fee for each account opened on their platform. The fees charged to the Client for Formative services are the same for each platform except OPS. Item 5: Account Requirements and Types of Clients  Formative does not accept clients under any restriction relating to the USA Patriot Act or Bank Secrecy Act or comparable legislation. The minimums for wrap fee accounts at Goldman Sachs are: Managed Mutual Fund Accounts: Multi-Manager Accounts: $ 50,000 $ 50,000 These minimums are negotiable on a case-by-case basis and are dependent on a variety of factors, including but not limited to other accounts in a client household (adults who all live at the same address who have investment accounts with Formative). The following types of clients may participate in the Goldman Sachs Wrap Fee Program: Individuals (to include high net worth individuals) • • Trusts, estates, and charitable organizations • Nonprofit organizations and other non-governmental organizations • Corporations or other businesses not listed above Item 6: Portfolio Manager Selection and Evaluation Selection of Models Use of Proprietary Models As noted above, Formative makes available Proprietary Models on the Goldman Sachs Platform that may be used by Network Advisors and Solicitors/Endorsers in the process of providing investment advisory services in the Goldman Sachs Wrap Fee Program. Formative retains the portion of the revenues allocated for compensation to model managers. Formative’s models are reviewed in the same manner as outside models and are included only if the model is suitable for the client portfolio. In some cases, the Formative models are the only models available for a particular asset class or, in the case of fossil fuel free models. One IAR is a member of Formative senior management and the Investment Committee. In his role, he provides investment advisory services to individual clients, while also working on developing Proprietary Models. Proprietary Models developed by this IAR are subject to the same selection and review process as other Third- Party Models and other Proprietary Models. Further, he does not receive compensation relating to the Proprietary Model’s development. Formative’s Advisory Business - Fiduciary Formative provides investment advice consistent with the philosophies of values-aligned investing. Clients who choose to invest with Formative make a conscious choice to put their  money to work for a dual purpose—to provide for a secure retirement, for example, while working for a better, more socially just, and environmentally sustainable future for all. Through Network Advisors and Solicitors/Endorsers (as defined in the Disclosure Brochure) Formative provides discretionary investment advisory services to investors, tailored to the individual needs of the client, that integrate values-based criteria into the investment analysis process according to the clients’ preference. Formative can create portfolios, using mutual funds, and/or individual securities such as stocks, bonds, exchange traded funds (ETFs), exchange traded notes (ETNs), real estate investment trusts (REITs), American depository receipts (ADRs), government agency or Treasury securities, corporate or municipal bonds, certificates of deposit (CODs), commercial paper or other securities. The different investment programs offered by Formative may not all offer the ability to invest in all the securities listed above. Formative does not offer discretionary investment advisory services concerning direct ownership of commodities, futures, derivatives, or short selling. Discretionary Investment Advisory Services – Sustainable Investment Solutions in Practice Discretionary Investment Advice Through its Network Advisors and Solicitors/Endorsers, Formative creates unique relationships with clients by combining discretionary investment advisory services and advanced financial technologies with responsible investment strategies that consider a client’s values. Generally, Formative’s innovative approach combines: Fiduciary Responsibility. In Formative’s relationship with clients where Formative is providing discretionary investment advice, Formative acknowledges that it serves and acts in a fiduciary capacity under the Investment Advisers Act of 1940. When we provide investment advice to you regarding your retirement plan account or a type of individual retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We also act as fiduciaries when recommending a rollover of retirement plans. For more information, please see the ADV Disclosure Brochure. The way we make money creates some conflicts with your interests. Under both rules Formative and the Network Advisors and Solicitors/Endorsers that we work with operate in your best interest and do not place their needs ahead of yours. The types of rollovers include an existing Retirement Plan to an IRA; an existing IRA to a Retirement Plan; an employer Retirement Plan to a new employer Retirement Plan; an IRA to an IRA; and a change from one retirement account type to another type, including from commission billing to fees.  Individualized Advice. One size does not fit all. Formative offers a variety of fee-based investment options, each designed to best meet the needs of individual clients and/or specific types of clients. The client can place reasonable restrictions on the types of investments to be held in the client account. Objectivity. Network Advisors and Solicitors/Endorsers provide their clients with objective advice. Fees for account management are generally based on assets under management and, as a result, the client’s interests, the interests of the Network Advisor, Solicitor/Endorser, and the interests of Formative are closely aligned. Wrap Fee Program Participation Formative sponsors discretionary advisory services where advisory fees and other fees are bundled together with other costs whcih can include the cost of executing trades in your account which are charged to your account as one "wrap fee". Formative participates in a wrap fee program – sponsored by Geneos Wealth Management, Inc., (Axiom) by making its Proprietary Models available on the platform. The Proprietary Models on the Axiom platform are required to meet certain criteria set by Axiom and any models listed are subject to ongoing reviews. Formative constructs such models with the same investment philosophy and process as it uses in other Proprietary Models. However, the included securities are restricted to securities approved by Axiom and consistent with Axiom’s asset allocation strategies and model construction guidelines. Formative exercises no discretion with respect to clients subscribed to the model portfolios but may receive an asset-based fee when a model constructed by Formative is used by Axiom or a representative of Axiom in making a recommendation to a client. Retirement Plan Consulting Services Formative may offer the services listed below to individuals and charitable organizations who need assistance with pension, profit sharing, and 401(k) plans for an hourly or one-time fee. This assistance will be reviewed against the Five Part Test developed by the Department of Labor to determine if it rises to the status of fiduciary advice. The DOL Fiduciary Rule requirements will be met, if applicable. The services are limited to the following non- discretionary consulting services: • Education about investment vehicles for the plan trustees; and • Provision of educational support and investment workshops to self-directed 401(k) plans participants. Formative does not provide investment advisory services to participants in retirement plans where it provides services to the plan.  Formative is compensated for its retirement plan consulting services either based on an hourly rate as negotiated between Formative and the plan sponsor or a fee charged based upon assets under advisement by the asset custodian. Formative’s Advisory Business – Non-Fiduciary Formative provides non-fiduciary services to selling, see below. Upon receipt of authorization signed by the client allowing Formative access to their accounts at the requisite custodian we will: 1. Facilitate the opening of client accounts 2. Complete a quantitative review of Mutual Funds and Model Managers in Formative’s Sustainable Investment Universe 3. Trade accounts on a non-discretionary basis upon instruction from advisors and/or clients under limited circumstances 4. Collect fees from client accounts based on the schedule agreed upon by the client and the selling agent 5. Vote client proxies if authorized; and, 6. Retain an agreed upon amount and distribute the fees to the selling agent and any money manager or sub-advisor managing the account. Formative may act as a money manager for part of the client’s account on Goldman Sachs for which it will also be compensated. Non-Fiduciary Fee Schedule Tiers Formative Non- Fiduciary Fee $100,000 0.25% Goldman Sachs Custody and Clearing 0.09% Goldman Sachs Model Manager fees as applicable 0.35% $100,000 0.25% 0.09% 0.35% $1,800,000 0.25% 0.09% 0.35% $8,000,000 0.20% 0.09% 0.35% $10,000,000 0.15% 0.09% 0.35% On the first On the next On the next On the next On the next Above $20,000,000 0.15% 0.09% 0.35% Performance-Based Fees Formative does not charge performance-based fees.  Methods of Analysis, Investment Strategies, Risk of Loss Investment Philosophy Formative follows an established investment management process consistent with standards of fiduciary care and with long-term orientation. Formative’s experience suggests that the financial planning and investment needs of most socially conscious investors can be met while providing competitive investment returns without a material increase in risk. For most clients, Formative believes that a long-term, diversified approach is the most appropriate investment strategy. First, Affirmative supports strategic asset allocation and more active portfolio management strategies. Formative does not offer recommendations concerning direct ownership of commodities, futures, derivatives, or short selling, but does offer tactical investment strategies appropriate for some investors. Formative may use the following types of investment vehicles in the service of achieving client goals and objectives. • American depository receipts (ADRs) • Certificates of deposit • Commercial paper • Corporate bonds • Exchange traded funds (ETFs) • Exchange traded notes (ETNs) • Government agency securities • Individual stocks • Municipal bonds • Mutual funds • Options on equities • OTC securities • Other exchange traded securities • Private placements • Real estate investment trusts (REITs) • Warrants Methods of Analysis Formative may use the following forms of analysis in formulating investment advice and/or managing client assets: Asset Allocation. Rather than focusing primarily on securities selection, Formative attempts to identify an appropriate ratio of equities and fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector if it is not  included in their allocation. Another risk is that the ratio of equities and fixed income, and cash, will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Charting. In this type of technical analysis, charts of market and security activity are reviewed in an attempt to identify when the market is moving up or down, to predict how long the trend may last, and when that trend might reverse. While this is a common method of analysis, there is always the risk that past performance is not representative of future results or that the assumptions made prove to be incorrect. Cyclical Analysis. In this type of technical analysis, the movements of a particular stock against the overall market are analyzed to predict the price movement of the security. There always is the risk that past performance is not representative of future results or that the assumptions made prove to be incorrect. Fundamental Analysis. The intrinsic value of a security is analyzed by reviewing economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (suggesting it may be a good time to buy) or overpriced (suggesting it may be a good time to sell). Fundamental analysis does not attempt to anticipate market movements or changes in value. There is risk in the fact that the price of a security can rise or fall along with the overall market, regardless of the economic and financial factors considered in evaluating the stock. Mutual Fund and/or ETF Due Diligence. Formative’s Mutual Fund and Multi-Manager Model formation process incorporates the objectivity of quantitative analysis and the insights of fundamental research. This two-pronged approach begins with our proprietary Mutual and Model Fund Scores, which encompass both financial and sustainability factors. Formative utilizes these Scores as the foundation for in-depth manager reviews. In one-on-one conversations, we assess individual managers to ensure their investments are aligned with our and our clients’ personal values, social priorities, and mission. We do this by analyzing the firm, portfolio management and research teams, investment process, and our values-based integration methodology, as well as proxy voting, corporate actions, and engagement. Finally, we construct well-diversified portfolios designed to deliver risk-adjusted returns to enable investors to achieve their financial goals. We diversify – across asset classes, geographies, sectors, styles, and market capitalizations – to mitigate risk. Well-diversified and structurally sound, our values-aligned Sustainable Investment Solutions are constructed with the probability of enabling our clients to achieve their investment objectives. Fiduciary duty is at the heart of our investment philosophy. Qualitative Analysis. This type of analysis describes the process of evaluating difficult to quantify factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price  based on that data. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Quantitative Analysis. Mathematical modeling is used in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Risks for all Forms of Analysis and Due Diligence. Formative’s securities analysis methods rely on the assumption that the companies whose securities Formative purchases and sells, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While Formative is alert to indications that data may be incorrect, there is always a risk that analysis may be compromised by inaccurate or misleading information. Technical Analysis. Historical market movements are analyzed, and that analysis is applied to the present to recognize recurring patterns of investor behavior and predict future price movement. Technical analysis does not consider the underlying financial condition of a company. Risk is inherent in a poorly managed or financially unsound company underperforming regardless of market movement. Third-Party Model Manager and/or Sub-Advisor Due Diligence. Formative examines the experience, expertise, investment philosophies, and past performance of independent Third- Party Model Managers and/or Sub-Advisors in an attempt to determine if there has been demonstrated ability to invest over a period of time and in different economic conditions. Formative monitors the Third-Party Model Manager’s model holdings, strategies, concentrations, and leverage as part of its overall periodic risk assessment. Additionally, as part of Formative’s due-diligence process, it surveys a Third-Party Model Manager’s or Sub-Advisor’s compliance and business enterprise risks. A risk of investing using Third-Party Model Manager and/or Sub-Advisors who have been successful in the past is that they may not be able to replicate that success in the future. In addition, as Formative does not control the underlying investments in a Third-Party Model Manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for clients. Moreover, as Formative does not control the manager’s daily business and compliance operations, Formative may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Values-Aligned Direct Index Solution (VADIS). VADIS attempts to replicate the performance of an index by purchasing the underlying individual equities instead of using an ETF or mutual fund in an investor’s portfolio. Formative’s portfolio construction expertise and discretionary investment advisory services may be implemented using our carefully vetted Impact Preferences, or combined with YourStake’s values-aligned client assessment, data collection and organization, analytics, and reporting capabilities for investors who seek alignment of  personal values factors into investment portfolios that attempt to replicate the performance of a chosen benchmark in our Values Aligned Direct Index Solution. Our VADIS Portfolios are constructed on the Orion Astro platform using client-specific inputs provided by the investment advisor. These inputs include but are not limited to: • Impact Preferences, which may include individual or lists of companies chosen by the client for exclusion or inclusion in the portfolio Investment strategy constraints and client preferences, such as: • A desired benchmark, which may be a standard index or combination thereof • • Maximum number of securities • Desired tracking error, security count, and security exposure • Turnover, and trade thresholds, size, and number • Existing legacy positions, specific-company inclusions/exclusions; and • Tax considerations Values-Aligned Integration. A sustainable and responsible approach to investing includes both quantitative and qualitative analysis. Our investment process integrates analysis of in the client’s values into the portfolio design. Management values factors can have a material influence (either positive or negative) on company profitability, value, and share price. Risk is inherent in the fact that a poorly managed or financially unsound company or product may cause the investment to underperform regardless of its mission. Investment Strategies Formative may use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among other considerations: Illiquid Securities. Formative may, from time to time, assist clients with analyzing investments in securities in the areas of unlisted and/or unregistered debt or equity (commonly referred to as “private placements”), which have no current or anticipated liquidity. Formative will provide investment advice on such securities that have been approved by its due diligence and investment approval processes. When analyzing investments in securities of this type, Formative will use the following analysis: fundamental, qualitative, quantitative and risk. Long-Term Purchases. Formative may purchase securities with the intention of holding them in the client’s account for a year or longer. Typically, this strategy is employed when: • Formative believes the securities to be currently undervalued, and/or • Formative wants exposure to a particular asset class over time, regardless of the current projection for this class.  A risk in a long-term purchase strategy is that by holding the security for this length of time, Formative may not take advantage of short-term gains that could be profitable to a client. Moreover, if Formative’s predictions are incorrect, a security may decline sharply in value before the decision is made to sell. Short-Term Purchases. When utilizing this strategy, Formative may purchase securities with the idea of selling them within a relatively short time (typically a year or less). Formative does this to take advantage of conditions it believes will soon result in a price swing in the securities purchased. A short-term purchase strategy poses risks should the anticipated price swing not materialize; Formative is then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy; and may result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short- term capital gains. Risk of Loss Investing involves risk, including loss of principal. Each client of Formative must be prepared to bear the risk of loss with respect to each account established. Proxy Voting Owners of company stock and mutual fund shares have a right to be heard on matters put before shareholders for a vote. Shareholder voting is the primary means by which shareholders can influence a company or mutual fund’s operations, its corporate governance, and other activities that may fall outside of financial considerations. You have provided Formative discretion in managing your accounts, we will vote your proxies consistent with our Proxy Voting Guidelines, except in the circumstances described below or if you instruct us that you do not wish for Formative to vote your proxies. You are provided with a copy of Formative’s Proxy Voting Guidelines at the time you open your account with us and annually thereafter. These guidelines also are always available on our website and upon request as described below. We believe one of the reasons you have chosen Formative to provide you advisory services is our commitment to socially responsible investing, which includes voting proxies consistent with this philosophy, as is reflected in our Proxy Voting Guidelines. Therefore, you must notify us in writing and instruct us how you would like us to vote your proxies if you do not want them voted as described in the Proxy Voting Guidelines. To assist with proxy voting, Formative has an arrangement with an independent governance analysis and proxy voting firm to provide research to Formative and to vote proxies based on Formative’s Proxy Voting Guidelines The independent third-party firm will vote all holdings in  which Formative clients have a material interest, defined as all shares held at Schwab, Goldman Sachs, SEI, and Apex. Formative does not vote proxies at any other custodians. As described above, client proxies voting is based on social responsibility concerns and financial considerations, as reflected in the Proxy Voting Guidelines, updated at least annually. The independent third-party proxy voting service discloses to Formative, at least annually, potential conflicts of interest between their research/proxy voting services and their corporate governance consulting services and their procedures for limiting such conflicts. Clients should be aware that they are under no obligation to assign proxy voting duties to Formative. Clients may choose from proxy voting options that are offered by their custodian. For example, accounts held at Goldman Sachs offer a client has the right at any time, even if proxy voting has been delegated to Formative, to vote any individual proxy themselves and override any vote that may be cast by the proxy voting service hired by Formative. Clients of advisors using our non-fiduciary services can opt-in to our proxy voting services by requesting such on the authorization form allowing access to Formative. If the client does not authorize Formative to vote their proxies at Goldman Sachs, they must vote their own proxies by logging into their Goldman Sachs account. Any proxies voted by Formative can be overridden by the client. Clients may obtain a copy of Formative’s Proxy Voting Guidelines by visiting the Formative website (www.firstaffirmative.com), sending an email to service@firstaffirmative.com or proxyvoting@firstaffirmative.com, or by sending a request in writing to the address listed on the cover page of this document. Clients may request information on how proxies for his/her shares were voted and Formative will promptly provide such information to the client. With respect to ERISA accounts, Formative will vote proxies if granted that authority unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. To direct Formative to vote a proxy in a particular manner, clients should send an email to proxyvoting@firstaffirmative.com. Formative does not vote proxies for the following types of accounts: • Accounts held in custody by Schwab that have not granted Formative authority to vote proxies • ERISA accounts that specifically require the plan sponsor to vote the proxies • Accounts that participate in the OPS Wrap Fee Program; and In situations where Formative does not vote proxies, proxy documents are accessible by logging into the Goldman Sachs website for advised clients, www.folioinstutional.com. Upon request, Formative and its IARs may provide information about proxy issues to clients who have chosen to vote their own proxies. Clients can instruct Formative to vote proxies according to particular criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called “poison  pill” defense against a possible takeover). These requests must be made in writing. Clients can also instruct Formative on how to cast their vote in a particular proxy contest by sending an email to service@firstaffirmative.com. There is a remote possibility that Formative employees or IARs have a relationship with a public corporation which may put their interests at odds with those of clients in the Proxy Voting process. These personnel are required to disclose to the Chief Compliance Officer any such relationships and are required to recuse themselves from participated in votes related to such companies. Clients of advisors using our non-fiduciary services can opt-in to our proxy voting services by requesting such on the authorization form allowing access to Formative. If the client does not authorize Formative to vote their proxies according to our Proxy Voting Guidelines at Schwab Institutional, they should not check the box on the account application authorizing such votes. If the client does not authorize Formative to vote their proxies at Goldman Sachs, they must vote their own proxies by logging into their Goldman Sachs account. Any proxies voted by Formative can be overridden by the client. Item 7: Client Information Provided to Portfolio Managers Third-Party Model Managers are investment managers who provide no individualized investment advice to a client, do not place, or execute transactions on behalf of a client and merely license proprietary information about the composition of a hypothetical portfolio to other investment advisors. Accordingly, as a general matter, Third- Party Model Managers on the Goldman Sachs platform receive no client information. It should be noted, however, that, when a Network Advisor or Solicitor/Endorser uses a Proprietary Model on the Goldman Sachs platform, Formative is both the investment manager of the model (or portfolio manager) as well as the investment advisor to the client. In its capacity as an investment advisor, Formative provides individualized investment advice and has client information. Item 8: Client Contact with Portfolio Managers A Third-Party Model Manager generally has no contact of any type with a client, does not accept investor funds or pool those funds with other investors and does not offer its model portfolio services to anyone other than other investment advisors. Except as noted below, clients do not have access to Third-Party Model Managers. Again, it should be noted, that, when a Network Advisor or Solicitor/Endorser uses a Proprietary Model on the Goldman Sachs platform, Formative is both the investment manager of the model (or portfolio manager) as well as the investment advisor to the client. As an investment advisor to the client, Formative (through the Network Advisor or Solicitor/Endorser) has regular contact with the client.  Item 9: Additional Information Disciplinary Information Formative must disclose any legal or disciplinary events material to a client’s or prospective client’s evaluation of its advisory business or the integrity of its management. Formative, its management personnel and Investment Adviser Representatives have no disciplinary events to disclose. Other Financial Industry Activities and Affiliations Formative may select BDs to provide brokerage services to client accounts. Conflicts may arise in the course of Formative’s selection of broker-dealers. Formative recommends BDs and places orders for the execution of transactions for its clients according to its best execution policies and procedures and consistent with the client’s investment objectives. In selecting a BD as a custodian Formative may consider a range of factors it deems relevant, including, but not limited to cost of services; timing and speed of execution; responsiveness; creditworthiness and financial stability; likelihood of, and capabilities in, execution, clearance, and settlement; liquidity in or with an execution venue; and other appropriate factors. After this analysis, the client has sole discretion as to any Formative approved custodian for a Managed Mutual Fund Account. However, certain advisory service programs offered by Formative may only be available through a single custodian. Formative receives the same compensation for each of the investment options it offers at other custodians except OPS. Any fees or transaction costs collected by custodians are not shared with Formative. Outside Business Activities of Management Personnel and IARs Formative’s Management Personnel do not have Outside Business Activities that are material to their roles within Formative. Several Formative IARs are licensed as insurance agents or as tax preparers. Formative does not supervise these outside business activities, nor does it share in any of the revenues from these activities. Selling Agreement, Solicitors/Endorsers Agreement, and Custodial Relationships with Formative There are no referral arrangements between Formative and any RIA firm wherein an individual is a member, officer, or employee of Formative and is also a member, officer, or employee of  another firm. This includes any other RIA disclosed as required in Section 7.A. on Schedule D of Form ADV, Part I. (Part I of Formative’s Form ADV is available on the SEC’s website at www.adviserinfo.sec.gov where you can search by using CRD number 109036). No Formative client is obligated to use the advisory services of any other RIA, as no other RIA advisory client is obligated to use Formative’s advisory services. Managing Other Potential Conflicts Insider Trading Formative and/or individuals associated with the firm may buy or sell for their personal accounts’ securities identical to or different from those recommended to its clients. In addition, any related person(s) may have an interest or position in a certain security or securities which may also be recommended to a client. Formative has established written policies and procedures for insider trading that prohibit any member, officer, or employee of the firm from buying, selling, or recommending securities where the decision is substantially derived, in whole or in part, from non-public information, information about other Formative clients or made based on the potential personal gain of the member, officer or employee. Compensation Conflicts Fees Paid to Network Advisors and Solicitors/Endorsers by Formative relating to Discretionary Investment Management. A portion of the fees for investment advisory services are shared with Network Advisors or Solicitors/Endorsers to compensate them for their services. If the Network Advisor is an IAR, Formative compensates the IAR directly, except for any compensation he or she may earn on the provision of tax preparation services and life insurance sales. For Network Advisor and Solicitors/Endorsers, Formative collects the applicable fee from the client assets and the Network Advisor or Solicitor/Endorsers share of the fee is paid to the BD or RIA firm with whom they are associated, which firm in turn pays a substantial portion of the fee to the Network Advisor and Solicitor/Endorser. The BD or RIA firm typically retains a small portion of the Network Advisor or Solicitor/Endorser share to compensate itself for administration and other overhead. Costs and Compensation for Rollover Recommendations. Rollover recommendations have associated fees payable to Formative and their Network Advisor or Solicitor/Endorser. These fees might be more or less than the fees or commissions charged to the Client by the Plan, other Consultants, or Brokers, as applicable. This creates a conflict of interest. The Network Advisor or Solicitor/Endorser making the recommendation provides full disclosure of the associated costs and their compensation so a client can make an informed decision before accepting the recommendation. This disclosure attempts to mitigate the conflict of interest.  Other Compensation Paid to IARs. In addition to receiving a portion of the fee for discretionary investment advice, IARs receive a portion of any fees charged for financial planning, hourly consultation or other services provided under nondiscretionary investment advisory agreements. Other Compensation Earned by Third-Party BD, RIA Network Advisors, and Solicitors/Endorsers. Third-party firms may compensate their advisors for providing other products or services to clients, Neither Formative nor any Network Advisor or Solicitor/Endorser receives any transactions-related or variable compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds relating to any product or service offered by or on behalf of Formative. Formative takes the following steps to address compensation conflicts: • Discloses to clients that they are not obligated to purchase recommended investment products from their employees or affiliated companies • Collects, maintains, and documents accurate, complete, and relevant client background information, including the client’s financial goals, objectives, and risk tolerance • The firm’s management conducts regular reviews of client accounts to verify that all recommendations made to a client are suitable to the client’s needs and circumstances • Requires that employees seek prior approval of any outside employment activity so that Formative may ensure that any conflicts of interest in such activities are properly addressed • Periodically monitors these outside employment activities to verify that any conflicts of interest continue to be properly addressed • Educates employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for investment advice provided to clients; and • Requires all IARs to acquire and maintain the Accredited Investment Fiduciary (AIF), or comparable professional designation to provide initial and ongoing training in the duties of investment fiduciaries. Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its members, officers, or employees when making advisory recommendations or when providing non-discretionary investment advisory services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. The Department of Labor’s Rule 3.0, known as the Fiduciary Rule, requires investment fiduciaries to review the costs associated with rolling over ERISA plan assets to another retirement vehicle. A conflict of interest occurs if the advisor earns a new fee or increases its current compensation because of the rollover. Formative offers fee-based compensation which tends to reduce or change the possibility of conflicts of interest but cannot eliminate them entirely. While it is Formative’s intent to always offer advice that is in the best interest of the client, it is the client’s responsibility to evaluate that advice and determine if it is appropriate  before acting. No client is obligated to accept any recommendation, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. Other Compensation for use of Proprietary Models. Formative recommends multi-manager models that are proprietary. Formative retains the portion of the revenues allocated for compensation to model managers. Formative’s models are reviewed against similar non- proprietary models and are included only if the model is suitable for the client portfolio. Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its members, officers, or employees when making advisory recommendations or when providing non-discretionary investment advisory services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. A conflict of interest occurs if the advisor earns a new fee or increases its current compensation because of the rollover. There also is the possibility of conflicts of interest between clients and any Network Advisor or Solicitor/Endorser, if the service is provided for variable compensation. Formative offers fee-based compensation which tends to reduce or change the possibility of conflicts of interest but cannot eliminate them entirely. While it is Formative’s intent to always offer advice that is in the best interest of the client, it is the client’s responsibility to evaluate that advice and determine if it is appropriate before acting. No client is obligated to accept any recommendation, including recommendations regarding rollovers, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. Indirect Compensation Specific to Custodians. Formative is charged an annual fee per client account to OAT for the use of their Astro platform. This technology allows us to design, implement, and reoptimize portfolios. Formative employs this technology for accounts held at each of our approved custodians. The fees charged to the Client are the same for each platform. Code of Ethics, Review of Accounts, Participation or Interest in Client Transactions, Personal Trading Formative has adopted a code of ethics (Code) which sets forth high ethical standards of business conduct that are required of employees and IARs, including compliance with applicable federal securities laws. Formative has adopted the Code to instruct and guide its personnel in their ethical and fiduciary obligations to clients. The Code also provides rules and requirements regarding the personal securities trading practices of Formative’s IARs and staff. Formative, its personnel, and its IARs owe a duty of loyalty, fairness, and good faith toward all clients and are obligated to adhere not only to the specific provisions of the Code but to the general principles embodied in the Code. The Code is designed to ensure that the personal securities transactions, activities,  and interests of Formative employees will not interfere with making decisions in the best interest of advisory clients and implementing such decisions while, at the same time, allowing employees to invest for their own accounts. The Code covers a range of topics that include the following: general ethical principles, reporting of personal securities trading, exceptions to reporting securities transactions, reportable securities, initial public offerings, and amendments to Form ADV and supervisory procedures. A copy of the Code is available to investment advisory clients and prospective clients. You may request a copy by email sent to Formative’s Chief Compliance Officer, Kathy Lewis at kathylewis@firstaffirmative.com, or by calling 719-660-6157. Review of Accounts Reports to Clients Clients receive monthly account statements detailing deposits, withdrawals, purchases, sales, dividends, interest, fees deducted from the account and any other activity, from the custodian of the account. Clients may also receive trade confirmation of every trade executed in their account(s), which should be saved for tax purposes. Formative and its service providers also will make available quarterly performance reports to all clients. Depending on the custodian and/or the service provider, such performance reports may be made available for an annual fee, which is not included in the discretionary investment advisory fees described in Item 4 above. All clients have online, 24/7 access to their accounts through a Client Portal via the OAT platform. Formative will provide quarterly performance reports through this Client Portal. These performance reports may include graphic representations of your accounts using various data points. Client Account Reviews Network Advisors and Solicitors/Endorsers. Each Network Advisor and Solicitor/Endorser can view all positions and activities in his/her client account(s) via the internet, and each Network Advisor and Solicitor/Endorser receives copies of all reports provided to their client(s). Network Advisors and Solicitors/Endorsers are expected to review activity in client accounts on a quarterly basis, to periodically discuss the account with the client, and to ensure the suitability of the investment services provided based on each client’s specific situation. Supervising BD or RIA. Each third-party BD and/or RIA with which Formative maintains a selling or solicitor/endorser’s agreement also is responsible for developing its own, independent procedures to review client accounts and supervise the activities of its representatives.  Sub-Advisors. Third-Party Model Managers responsible for managing portions of Formative client accounts are also responsible for ongoing review and supervision of transactions in the client accounts they manage. Company Management. Formative’s senior management, including members of the Investment Committee, conduct both periodic reviews and various systematic samplings of accounts to supervise and ensure compliance with investment policy. Formative also monitors the performance of the VADIS portfolio construction workflow. Client Referrals and Other Compensation Client Referrals Formative may pay referral fees to firms (“Solicitors/Endorsers”) for introducing clients. These fees are asset-based. When the solicitor/endorser is associated with a third-party BD or RIA, they are paid over the relationship's life. Whenever Formative pays a referral fee, it requires the Solicitor/Endorser to provide the prospective client with a copy of the Disclosure Brochure and this document, an Investment Advisory Services Agreement (IAS), and a separate disclosure statement that includes the following information: • The Solicitor/Endorser’s name and relationship with Formative • The fact that the Solicitor/Endorser is being paid a referral fee • The amount of the fee; and • As a matter of firm policy, a client working with a Solicitor/Endorser will not be charged more than any other client. Other Compensation It is Formative’s policy not to accept or allow its 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 it provides to its clients. Financial Information Under no circumstances does Formative require or solicit payment of fees in excess of $500 per client more than six months in advance of services rendered. Therefore, Formative is not required to include a financial statement in this disclosure document. As an advisory firm that maintains discretionary authority for client accounts and maintains custody of client assets held for clients at Schwab, SEI, and Apex, granting Formative  authorization under a SLOA, Formative is also required to disclose any financial condition that is reasonably likely to impair its ability to meet its contractual obligations. Formative has no additional financial circumstances to report. Formative’s financial statements are audited or reviewed each calendar year by a qualified, independent CPA firm. Formative has never been the subject of a bankruptcy petition. 

Summary of Material Changes to the Goldman Sachs Wrap Fee Brochure, Appendix 1A Consistent with SEC rules, annual updates that are material in nature are required to be provided to all clients of First Affirmative Financial Network, LLC DBA Formative (“Formative”) through a “Material Changes” document within 120 days of the close of the firm’s fiscal year, which is the calendar year. Throughout the year, all clients will be provided with additional information about material changes, as necessary. This summary of the material changes to the Goldman Sachs Wrap Fee Brochure, Appendix 1A and ADV Disclosure Brochure (Summary of Material Changes) is intended to provide you with sufficient information to determine whether you would like to review the Goldman Sachs Wrap Fee Brochure, Appendix 1A and ADV Disclosure Brochure in their entirety. You can obtain an electronic copy of the current Goldman Sachs Wrap Fee Brochure, Appendix 1A and ADV Disclosure Brochure and this Summary of Material Changes in a publicly accessible area on the Formative website at www.firstaffirmative.com or by contacting Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov. You can search the SEC’s website for information about a registered investment advisor (RIA) by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. First Affirmative Financial Network, LLC’s doing business as (DBA) name, is Formative. 

Summary of Material Changes to the Orion OPS Wrap Fee Brochure, Appendix 1B Consistent with SEC rules, annual updates that are material in nature are required to be provided to all clients of First Affirmative Financial Network, LLC DBA Formative (“Formative”) through a “Material Changes” document within 120 days of the close of the firm’s fiscal year, which is the calendar year. Throughout the year, all clients will be provided with additional information about material changes, as necessary. This summary of the material changes to the OPS Wrap Fee Brochure, Appendix 1B and ADV Disclosure Brochure (Summary of Material Changes) is intended to provide you with sufficient information to determine whether you would like to review the OPS Wrap Fee Brochure, Appendix 1B and ADV Disclosure Brochure in their entirety. You can obtain an electronic copy of the current OPS Wrap Fee Brochure, Appendix 1B and ADV Disclosure Brochure and this Summary of Material Changes in a publicly accessible area on the Formative website at www.firstaffirmative.com or by contacting Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov. You can search the SEC’s website for information about a registered investment advisor (RIA) by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. First Affirmative Financial Network, LLC’s doing business as (DBA) name, is Formative. 

Form ADV Part 2A – Appendix 1B April 17, 2026 Orion Portfolio Services (OPS) Wrap Fee Brochure for Clients and Prospective Clients of First Affirmative Financial Network, LLC DBA Formative Item 1: Introduction and Overview This Wrap Fee Brochure provides information about the qualifications and business practices of First Affirmative Financial Network, LLC DBA Formative (“Formative”). Capitalized terms not defined in this Wrap Fee Brochure are defined in Formative’s Form ADV Part 2A (Disclosure Brochure). Formative is an investment advisor registered (RIA) with the U.S. Securities and Exchange Commission (SEC) with its principal place of business at 5475 Mark Dabling Boulevard, Suite 320, Colorado Springs, CO 80918. The fact that Formative is registered with the SEC should not be read as an endorsement of Formative or that Formative has a certain level or training. This Wrap Fee Brochure is required to be delivered to any prospective client of the Formative sponsored wrap fee program involving Orion Portfolio Solutions, LLC (OPS) (OPS Wrap Fee Program) prior to or at the time of entering into an investment advisory relationship with Formative that includes participation in the OPS Wrap Fee Program. Formative also sponsors a wrap fee program involving Folio Investments, Inc., which also conducts business under the name Folio Institutional, Inc., both subsidiaries of Folio Financial, Inc., a Goldman Sachs Company (Folio) (Goldman Sachs Wrap Fee Program) and Apex Clearing (Apex) (Apex Wrap Fee Program). A separate Wrap Fee Brochure is available for clients whose investment advisory relationship with Formative includes participation in the Goldman Sachs Wrap Fee Program and/or the Apex Wrap Fee Program. An electronic copy of both brochures are available on a publicly accessible area on the Formative website at www.firstaffirmative.com. Additional information about Formative is available on the SEC’s website at www.adviserinfo.sec.gov. You can search the SEC’s website for information about a RIA by using the RIA’s unique identifying number known as a “CRD number.” Formative’s CRD number is 109036. You can also access an electronic copy of this document in a publicly accessible area on the Formative website at www.firstaffirmative.com. If you have any questions about the contents of this Wrap Fee Brochure, please contact Formative’s Chief Compliance Officer, Kathy Lewis, at 719-660-6157 or kathylewis@firstaffirmative.com. While submitted to the SEC, the information in this Wrap Fee Brochure has not been approved or verified by the SEC or by any state securities authority.  Item 2: Material Changes Consistent with SEC rules, Formative updates this Wrap Fee Brochure at least annually, within 90 days of the close of its fiscal year, which is December 31. If there are material changes from the prior annual update of this Wrap Fee Brochure, and you received a prior version of this Wrap Fee Brochure, such changes will be set forth in the “Summary of Material Changes” accompanying this Wrap Fee Brochure. Item 4: Services, Fees, and Compensation Description of the OPS Wrap Fee Program The OPS Wrap Fee Program applies to discretionary investment advisory services offered by Formative, through its investment advisor representatives (IARs), (as defined in the Disclosure Brochure), consistent with its Sustainable Investment Solutions advisory offering (as described in the Disclosure Brochure) using proprietary investment model portfolios constructed and managed by Formative (Proprietary Models), as well as models selected by Formative that are constructed and managed by third-party unaffiliated investment advisors (Third-Party Models). Wrap Fee for the OPS Wrap Fee Program The OPS Wrap Fee Program fee (Wrap Fee) includes all costs for investment management, trade execution, and custody and clearing (which is provided by Schwab Advisory Services (Schwab), unless specifically noted as a separate charge below. Fees on assets included in the Wrap Fee Program are charged as a percentage of assets under management, annualized, in arrears, on a monthly basis according to the schedule below. The Wrap Fee shown in the table below is collected from each client account by OPS on Formative’s behalf. Tier Fee per annum On the first On the next On the next On the next On the next On the next On the next On the next On the next On the next On the next Above Dollar Value of Assets under Management $50,000 $100,000 $100,000 $150,000 $100,000 $400,000 $100,000 $1,000,000 $1,000,000 $2,000,000 $5,000,000 $10,000,000 1.450% 1.350% 1.200% 1.195% 1.125% 1.125% 1.100% 0.950% 0.850% 0.750% 0.550% 0.450%  Third-Party Model Managers (also referred to as portfolio managers) utilized by Formative when advising clients on the OPS platform are paid 0 to 10 basis points (bps) (0.10%) out of the Wrap Fee. Formative also receives 14 bps (0.14%) when its Proprietary Models are used by third-party RIAs while providing fiduciary advice to their clients. Some of the models that are available to IARs for purposes of providing discretionary investment advice to clients on the OPS Platform are Proprietary Models. When a Proprietary Model is used by an IAR, a client is not charged a separate basis point fee – the Wrap Fee includes the cost of all Proprietary Models. There is no minimum size for accounts that are advised by Formative on the OPS platform and the Wrap fee is negotiable by clients through their IAR. The Wrap Fee may be more or less than the aggregate fee for services if they were offered separately. Some factors that may contribute to the relative cost differential include, but are not limited to, the brokerage and clearing costs, commissions based on trading frequency or commissions based on type of security (e.g., mutual fund versus single stock) and Formative uses institutional class shares of mutual fund share classes in managed mutual fund models. Mutual Fund Expenses Mutual funds have internal expenses, such as portfolio management, legal and accounting, printing, marketing, trading costs, and other administrative expenses, including fees paid to custodians. Fund expenses are more fully disclosed in each mutual fund prospectus. They are accounted for and charged internally by the mutual funds and monies collected or retained are not shared with Formative. Any mutual fund sale within a defined period time per the mutual fund prospectus after the initial purchase will trigger a contingent deferred sales charge by the mutual fund company on the transaction. These charges vary among the mutual funds that are held in a client account. Incidental Fees from Schwab as Custodian In addition to the fees above, clients are still responsible for any special fees incurred at the client’s request, such as wire transfer fees, etc. which are charged and disclosed by Schwab Institutional. All fees are subject to change and can be found at: Schwab.com/pricing. Note that some of these fees may not reflect the discounted prices that Formative has negotiated with Schwab.  Schwab Transaction-Based Pricing The following fees are charged by Schwab per transaction in each client account: Transactions Equities and ETFs $0.00 All Methods: Institutional Class Mutual Fund Shares $15.00 per Trade Bond Transactions Telephone $1.20 per bond, $10 Minimum, $275 Maximum Internet/Electronic $1.00 per bond, $10 Minimum, $250 Maximum Government Bonds $25.00 flat Municipal Bonds Variable Prime Brokerage/Trade Away $25.00 per transaction Compensation to IARs relating to Client Participation in the OPS Wrap Fee Program IARs are compensated from the Wrap Fee. The amount of this compensation may be more or less than the compensation an IAR would receive if not recommending the OPS Wrap Fee Program. This may create a conflict of interest in that the IAR may have a financial incentive to recommend the OPS Wrap Fee Program over other programs and services. See section below addressing compensation conflicts for a discussion as to how Formative mitigates this conflict.  Compensation for Accounts Under Title I of the Employee Retirement Income Security Act (ERISA) Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its owners, officers, investment advisor representatives, or employees when providing advisory services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. The Department of Labor’s Rule 3.0, known as the Fiduciary Rule, requires investment fiduciaries to review the costs associated with rolling over ERISA plan assets to another retirement vehicle. A conflict of interest occurs if the advisor earns a new fee or increases its current compensation because of the rollover. There also is the possibility of conflicts of interest between clients and an IAR if the service is provided for variable compensation. Formative offers fee-based compensation which tends to reduce or change the possibility of conflicts of interest but cannot eliminate them entirely. While it is Formative’s intent to always offer advice that is in the best interest of the client, it is the client’s responsibility to evaluate that advice and determine if it is appropriate before acting. No client is obligated to accept any recommendation, including recommendations regarding rollovers, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. Item 5: Account Requirements and Types of Clients Formative does not accept clients that are under any restriction as it relates to the USA Patriot Act or Bank Secrecy Act or comparable legislation. There is no minimum size for accounts that participate in the OPS Wrap Fee Program and there is no minimum asset balance to be invested in any Third-Party Model or any Proprietary Model. The following types of clients may participate in the OPS Wrap Fee Program: Individuals (to include high net worth individuals) • • Trusts, estates, and charitable organizations • Nonprofit organizations and other non-governmental organizations • Corporations or other businesses not listed above Item 6: Portfolio Manager Selection and Evaluation Selection of Models IARs provide investment advisory services in the OPS Wrap Fee Program consistent with Formative’s Sustainable Investment Solutions advisory offering (as described in the Disclosure Brochure). They may use Proprietary Models as well as Third-Party Models. Formative provides investment advice with the philosophies of values-based investing. All investment portfolios are constructed by integrating particular values factors in order to reflect a client’s values and  preferences, as well as aligning with the client’s investment goals and risk profile as established in the Investment Policy Statement by the client and the IAR. In considering all of the models available on the OPS Platform (Proprietary Models and Third- Party Models), IARs begin by reviewing the models available on the platform through discussions with wholesalers and reading fact sheets on each Third-Party Model Manager. The IARs then review the risk and return ratios on each model as well as the performance to determine which models are likely to continue to meet the client’s needs. Generally, models with ongoing substandard performance (as reported on the OPS Platform, which has been represented as being consistent with the performance standards of the CFA Institute) are eliminated along with models that may be considered “alternative strategies” (e.g., currency strategies). Further, IARs typically exclude exchanged traded fund (ETF) models on the OPS Platform due to the high minimum initial purchase amount of $50,000. An IAR also may consider information about the model that comes to light, management changes, or change of investment philosophy. Ultimately, the decision to make a change is based on a number of factors, including a change in the client’s circumstances, investment philosophy, risk tolerance or market concerns. Formative does not review, nor engage a third party to review, performance information relating to models shown on the OPS Platform for compliance with the CFA Institute standards or to verify accuracy. Accordingly, the performance information with respect to any models used may not be calculated on a uniform and consistent basis. Use of Proprietary Models As noted above, Formative makes available Proprietary Models on the OPS Platform that may be used by IARs in the process or providing investment advisory services in the OPS Wrap Fee Program. Proprietary Models are subject to the same selection and review process as Third- Party Models that participate in the program. One IAR is a member of Formative senior management and the Investment Committee. In his role, he provides investment advisory services to individual clients, while also assisting with the development of Proprietary Models managed at another custodian. Proprietary Models developed by this IAR are subject to the same selection and review process as other Third-Party Models and other Proprietary Models. Further, he does not receive compensation relating to his development of Proprietary Models. Formative’s Advisory Business – Fiduciary Formative provides investment advice consistent with values-based philosophies investing. Clients who choose to invest with Formative make a conscious choice to put their money to work for a dual purpose—to provide for a secure retirement, for example, while working for a better, socially just, and environmentally sustainable future for all.  Formative and its IARs (as defined in the Disclosure Brochure) provide, in the capacity of a fiduciary, discretionary investment advisory services to investors. These services are tailored to the individual needs of the client that seek integration of personal values in the construction and management of mutual fund portfolios. Formative does not offer discretionary advice concerning direct ownership of non-mutual fund securities, commodities, futures, derivatives or short selling. Discretionary Investment Advisory Services – Sustainable Investment Solutions in Practice Discretionary Investment Advice Through its IARs, Formative creates unique relationships with clients by combining discretionary investment advisory services and advanced financial technologies with responsible investment strategies that consider values-based factors. Generally, Formative’s innovative approach combines: Fiduciary Responsibility. In Formative’s relationship with clients where Formative is providing discretionary investment advice, Formative acknowledges that it serves and acts in a fiduciary capacity under the Investment Advisers Act of 1940. When we provide investment advice to you regarding your retirement plan account or individual retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests. Under both rules Formative and the Network Advisors we work with operate in your best interest and do not place their needs ahead of yours. The types of rollovers include an existing Retirement Plan to an IRA; an existing IRA to a Retirement Plan; an employer Retirement Plan to a new employer Retirement Plan; an IRA to an IRA; and a change from one retirement account type to another type, including from commission billing to fees. Individualized Advice. One size does not fit all. Formative offers a variety of fee-based investment options, each designed to best meet the needs of individual clients and/or specific types of clients. The client has the opportunity to place reasonable restrictions on the types of investments to be held in the client account. Objectivity. IARs provide their clients with objective advice. Fees for account management are generally based on assets under management and, as a result, the client’s interests, the interests of the IAR, and the interests of Formative are closely aligned.  Wrap Fee Program Participation Formative participates in a wrap fee program sponsored by Geneos Wealth Management, Inc., (Axiom) by making its Proprietary Models available on the platform. The Proprietary Models on the Axiom platform are required to meet certain criteria set by Axiom and any models listed are subject to ongoing reviews. Formative constructs such models with the same investment philosophy and process as it uses in other Proprietary Models. However, the included securities are restricted to securities that are approved by Geneos/Axiom and are consistent with Axiom’s asset allocation strategies and model construction guidelines. Formative exercises no discretion with respect to clients subscribed to the model portfolios but may receive an asset-based fee when a model constructed by Formative is used by Axiom or a representative of Axiom in making a recommendation to a client. Retirement Plan Consulting Services Formative offers the services listed below to individuals and charitable organizations who need assistance with pension, profit sharing and 401(k) plans. The services are comprised of the following non-discretionary consulting services: Identification of investment vehicles for the plan trustees; and • • Provisions of educational support and investment workshops to self-directed 401(k) plans participants. Formative may offer the services listed below to individuals and charitable organizations who need assistance with pension, profit sharing, and 401(k) plans for an hourly or one-time fee. This assistance will be reviewed against the Five Part Test developed by the Department of Labor to determine if it rises to the status of fiduciary advice. The DOL Fiduciary Rule requirements will be met, if applicable. The services are comprised of the following non- discretionary consulting services: • Education about investment vehicles for the plan trustees; and • Provision of educational support and investment workshops to self-directed 401(k) plans participants. Formative does not provide investment advisory services to participants in retirement plans where it provides services to the plan. Formative is compensated for its retirement plan consulting services either based on an hourly rate as negotiated between Formative and the plan sponsor or a fee charged based upon assets under advisement by the asset custodian. Formative’s Advisory Business – Non-Fiduciary Formative provides non-fiduciary services to Network Advisors on a limited basis. These services are not available on the OPS platform.  Performance-Based Fees Formative does not charge performance-based fees. Methods of Analysis, Investment Strategies, Risk of Loss Investment Philosophy Formative follows an established investment management process consistent with standards of fiduciary care and with long-term orientation. Formative’s experience suggests that the financial planning and investment needs of most socially conscious investors can be met while providing competitive investment returns without a material increase in risk. For most clients, Formative believes that a long-term, diversified approach is the most appropriate investment strategy. Formative supports strategic asset allocation as well as more active portfolio management strategies. Formative does not offer recommendations concerning direct ownership of commodities, futures, derivatives, or short selling, but does offer tactical investment strategies appropriate for some investors. Formative may use the following types of investment vehicles in service of achieving client goals and objectives. • American depository receipts (ADRs) • Certificates of deposit • Commercial paper • Corporate bonds • Exchange traded funds (ETFs) • Exchange traded notes (ETNs) • Government agency securities • Individual stocks • Municipal bonds • Mutual funds • Options on equities • OTC securities • Other exchange traded securities • Private placements • Real estate investment trusts (REITs) • Warrants  Formative may use the following methods of analysis in formulating investment advice and/or managing client assets: Asset Allocation. Rather than focusing primarily on securities selection, Formative attempts to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector is not included in their allocation. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Charting. In this type of technical analysis, charts of market and security activity are reviewed to identify when the market is moving up or down, to predict how long the trend may last, and when that trend might reverse. While this is a common method of analysis, there is always the risk that past performance is not representative of future results or that the assumptions made prove to be incorrect. Cyclical Analysis. In this type of technical analysis, the movements of a particular stock against the overall market are analyzed in an attempt to predict the price movement of the security. There always is the risk that past performance is not representative of future results or that the assumptions made prove to be incorrect. Fundamental Analysis. The intrinsic value of a security is analyzed by reviewing economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (suggesting it may be a good time to buy) or overpriced (suggesting it may be a good time to sell). Fundamental analysis does not attempt to anticipate market movements or changes in value. There is risk in the fact that the price of a security can rise or fall along with the overall market, regardless of the economic and financial factors considered in evaluating the stock. Mutual Fund and/or ETF Due Diligence. Formative looks at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. Formative also looks at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund or funds in the client’s portfolio. Formative also monitors the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful one year may not be successful in the future. In addition, as Formative does not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio.  Qualitative Analysis. This type of analysis describes the process of evaluating difficult to quantify factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. A risk in using qualitative analysis is that our subjective judgment may prove to be incorrect. Quantitative Analysis. Mathematical modeling is used in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Risks for all Forms of Analysis and Due Diligence. Formative’s securities analysis methods rely on the assumption that the companies whose securities Formative purchases and sells, the rating agencies that review these securities, and other publicly- available sources of information about these securities, are providing accurate and unbiased data. While Formative is alert to indications that data may be incorrect, there is always a risk that analysis may be compromised by inaccurate or misleading information. Technical Analysis. Historical market movements are analyzed, and that analysis is applied to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. Risk is inherent in the fact that a poorly managed or financially unsound company may underperform regardless of market movement. Third-Party Model Manager and/or Sub-Advisor Due Diligence. Formative examines the experience, expertise, investment philosophies, and past performance of independent Third- Party Model Managers and/or Sub-Advisors in an attempt to determine if there has been demonstrated ability to invest over a period of time and in different economic conditions. Formative monitors the Third-Party Model Manager’s model holdings, strategies, concentrations and leverage as part of its overall periodic risk assessment. Additionally, as part of Formative’s due-diligence process, it surveys a Third-Party Model Manager’s or Sub-Advisor’s compliance and business enterprise risks. A risk of investing using Third-Party Model Manager and/or Sub-Advisors who have been successful in the past is that they may not be able to replicate that success in the future. In addition, as Formative does not control the underlying investments in a Third-Party Model Manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for clients. Moreover, as Formative does not control the manager’s daily business and compliance operations, Formative may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Values-Aligned Direct Index Solution (VADIS). VADIS indexing attempts to replicate the performance of an index by purchasing the underlying individual equities instead of using an  ETF or mutual fund in an investor’s portfolio. Formative’s portfolio construction expertise and discretionary investment advisory services may be implemented using our carefully vetted Impact Preferences, or combined with YourStake’s values-aligned client assessment, data collection and organization, analytics, and reporting capabilities for investors who seek alignment of personal values factors into investment portfolios that attempt to replicate the performance of a chosen benchmark in our Values Aligned Direct Index Solution. Our Direct Index Portfolios are constructed using the Orion Astro platform or the YourStake platform using client-specific inputs provided by the investment advisor. These inputs include but are not limited to: • Impact Preferences, which may include individual or lists of companies chosen by the client for exclusion or inclusion in the portfolio Investment strategy constraints and client preferences, such as: • A desired benchmark, which may be a standard index or combination thereof • • Maximum number of securities • Desired tracking error, security count, and security exposure • Turnover, and trade thresholds, size, and number • Existing legacy positions, specific-company inclusions/exclusions • Tax considerations Values-Aligned Integration. A sustainable and responsible approach to investing includes both quantitative and qualitative analysis. Our investment process integrates analysis of environmental, social, and corporate governance factors in portfolio design. Management of environment, social and governance issues and impacts can have a material influence (either positive or negative) on company profitability, value, and share price. Risk is inherent in the fact that a poorly managed or financially unsound company or product may cause the investment to underperform regardless of its mission. Investment Strategies Formative uses the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among other considerations: Illiquid Securities. Formative may, from time to time, assist clients with analyzing investments in securities in the areas of unlisted and/or unregistered debt or equity, which may have no current or anticipated liquidity. Formative will provide investment advice on such securities that have been approved in accordance with its due diligence and investment approval processes. When analyzing investments in securities of this type Formative will use the following analysis: fundamental, qualitative, quantitative, and risk. Long-Term Purchases. Formative purchases securities with the intention of holding them in the client’s account for a year or longer. Typically, this strategy is employed when:  • Formative believes the securities to be currently undervalued, and/or • Formative wants exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, Formative may not take advantage of short-term gains that could be profitable to a client. Moreover, if Formative’s predictions are incorrect, a security may decline sharply in value before the decision is made to sell. Short-Term Purchases. When utilizing this strategy, Formative purchases securities with the idea of selling them within a relatively short time (typically a year or less). Formative does this in an attempt to take advantage of conditions that it believes will soon result in a price swing in the securities purchased. A short-term purchase strategy poses risks should the anticipated price swing not materialize; Formative is then left with the option of having a long-term investment in a security that was designed to be a short-term purchase or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy; and could result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short- term capital gains. Risk of Loss Investing involves risk, including loss of principal. Each client of Formative must be prepared to bear the risk of loss with respect to each account established. Proxy Voting Owners of company stock and mutual fund shares have a right to be heard on matters put before shareholders for a vote. Shareholder voting is the primary means by which shareholders can influence a company or mutual fund’s operations, its corporate governance, and other activities that may fall outside of financial considerations. Clients may choose from proxy voting options that are offered by Schwab. Formative does not vote proxies for clients in the OPS Wrap Fee Program. Formative and its IARs may provide clients with consulting assistance regarding proxy issues if they contact Formative with questions. Item 7: Client Information Provided to Portfolio Managers Third-Party Model Managers are investment managers who provide no individualized investment advice to a client, do not place, or execute transactions on behalf of a client and merely license proprietary information about the composition of a hypothetical portfolio to  other investment advisors. Accordingly, as a general matter, Third-Party Model Managers on the OPS Platform receive no client information. It should be noted, however, that, when an IAR uses a Proprietary Model on the OPS platform, Formative is both the investment manager of the model (or portfolio manager) as well as the investment advisor to the client. In its capacity as an investment advisor, Formative provides individualized investment advice and has client information. Item 8: Client Contact with Portfolio Managers A Third-Party Model Manager generally has no contact of any type with a client, does not accept investor funds or pool those funds with other investors and does not offer its model portfolio services to anyone other than other investment advisors. Except as noted below, clients do not have access to Third-Party Model Managers. Again, it should be noted that, when an IAR uses a Proprietary Model on the OPS Platform, Formative is both the investment manager of the model (or portfolio manager) as well as the investment advisor to the client. As an investment advisor to the client, Formative (through the IAR) has regular contact with the client. Item 9: Additional Information Disciplinary Information Formative is required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of its advisory business or the integrity of its management. Formative and its management personnel have no disciplinary events to disclose. Other Financial Industry Activities and Affiliations Formative may select BDs to provide brokerage services to client accounts. Conflicts may arise during Formative’s selection of BDs. Formative recommends BDs and places orders for the execution of transactions for its clients according to its best execution policies and procedures and consistent with the client’s investment objectives. In selecting a BD as a custodian Formative may consider a range of factors it deems relevant, including, but not limited to cost of services; timing and speed of execution; responsiveness; creditworthiness and financial stability; likelihood of, and capabilities in, execution, clearance and settlement; liquidity in or with an execution venue; and other appropriate factors. After this analysis has been carried out the client has sole discretion as to any Formative approved custodian for a Managed Mutual Fund Account. However, certain advisory service programs offered by Formative may only be available through a single custodian.  Formative receives the same compensation for each of the investment options it offers at other custodians. The compensation structure for OPS accounts is as above. The client has sole discretion as to any Formative approved custodian for a Managed Mutual Fund Account. Any fees or transaction costs collected by custodians are not shared with Formative. Outside Business Activities of Management Personnel and IARs Formative’s Management Personnel do not have Outside Business Activities that are material to their roles within Formative. Several Formative IARs are licensed as insurance agents or as tax preparers. Formative does not supervise these outside business activities, nor does it share any of the revenues from these activities. Managing Other Potential Conflicts Insider Trading Formative and/or individuals associated with the firm (including IARs) may buy or sell for their personal accounts’ securities identical to or different from those recommended to its clients. In addition, any related person(s) may have an interest or position in a certain security or securities which may also be recommended to a client. Formative has established written policies and procedures for insider trading that prohibit any member, officer, or employee of the firm from buying, selling, or recommending securities where the decision is substantially derived, in whole or in part, from non-public information, information about other Formative clients or made based on the potential personal gain of the member, officer or employee. Compensation Conflicts Fees Paid to IARs by Formative relating to Discretionary Investment Management. A portion of the fees for investment advisory services are shared with IARs to compensate them for their services. Other Compensation Paid to IARs. In addition to receiving a portion of the fee for discretionary investment advice, IARs receive a portion of any fees charged for financial planning, hourly consultation or other services provided under nondiscretionary investment advisory agreements.  Formative takes the following steps to address compensation conflicts: • Discloses the potential for the firm and its employees to earn compensation from advisory clients in addition to the firm’s advisory fees • Discloses to clients that they are not obligated to purchase recommended investment products from their employees or affiliated companies • Collects, maintains, and documents accurate, complete and relevant client background information, including the client’s financial goals, objectives, and risk tolerance • The firm’s management conducts regular reviews of client accounts to verify that all recommendations made to a client are suitable to the client’s needs and circumstances • Requires that employees seek prior approval of any outside employment activity so that Formative may ensure that any conflicts of interest in such activities are properly addressed • Periodically monitors these outside employment activities to verify that any conflicts of interest continue to be properly addressed • Educates employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for investment advice provided to clients; and • Requires all IARs to acquire and maintain the Accredited Investment Fiduciary (AIF), or comparable professional designation to provide initial and ongoing training in the duties of investment fiduciaries. Clients should be aware that conflicts of interest surrounding compensation may impair the objectivity of Formative and its members, officers, or employees when making advisory recommendations or when providing non-discretionary investment advisory services. This includes a recommendation to rollover retirement assets to an account managed by the advisor. The Department of Labor’s Rule 3.0, known as the Fiduciary Rule, requires investment fiduciaries to review the costs associated with rolling over ERISA plan assets to another retirement vehicle. A conflict of interest occurs if the advisor earns a new fee or increases its current compensation because of the rollover. Formative offers fee-based compensation which tends to reduce or change the possibility of conflicts of interest but cannot eliminate them entirely. While it is Formative’s intent to always offer advice that is in the best interest of the client, it is the client’s responsibility to evaluate that advice and determine if it is appropriate before acting. No client is obligated to accept any recommendation, and all clients are free to implement any recommendation with the broker, planner, or advisor of their choice. Indirect Compensation Specific to Custodians. Formative is charged an annual fee per client account to Orion Advisor Technology (OAT) for the use of their Astro platform. This technology allows us to design, implement, and reoptimize portfolios The fees charged to the Client for Formative services are the same for each platform.  Code of Ethics, Review of Accounts, Participation or Interest in Client Transactions, Personal Trading Formative has adopted a code of ethics (Code) which sets forth high ethical standards of business conduct that are required of employees and IARs, including compliance with applicable federal securities laws. Formative has adopted the Code for the purpose of instructing and guiding its personnel in their ethical and fiduciary obligations to clients. The Code also provides rules and requirements regarding the personal securities trading practices of IARs and staff. Formative, its personnel, and its IARs owe a duty of loyalty, fairness, and good faith toward all clients and are obligated to adhere not only to the specific provisions of the Code but to the general principles embodied in the Code. The Code is designed to ensure that the personal securities transactions, activities, and interests of Formative employees will not interfere with making decisions in the best interest of advisory clients and implementing such decisions while, at the same time, allowing employees to invest for their own accounts. The Code covers a range of topics that include the following: general ethical principles, reporting of personal securities trading, exceptions to reporting securities transactions, reportable securities, initial public offerings, and amendments to Form ADV and supervisory procedures. A copy of the Code is available to investment advisory clients, and prospective clients. You may request a copy by email sent to Formative’s Chief Compliance Officer, Kathy Lewis at kathylewis@firstaffirmative.com, or by calling 719-478-7036. Review of Accounts Reports to Clients Clients receive monthly account statements detailing deposits, withdrawals, purchases, sales, dividends, interest, fees deducted from the account, and any other activity, from the custodian of the account. Clients may also receive trade confirmation of every trade executed in their account(s), which should be saved for tax purposes. Formative or its service providers also will make available quarterly performance reports to all clients. Depending on the custodian and/or the service provider, such performance reports may be made available for an annual fee, which is not included in the discretionary investment advisory fees described in Item 4 above. All clients have online, 24/7 access to their accounts through a Client Portal via the OAT platform. Formative will provide quarterly performance reports through this Client Portal. These performance reports may include graphic representations of your accounts using various data points.  Client Account Reviews IARs. Each IAR has the ability to view all positions and activities in his/her client account(s) via the internet, and each IAR receives copies of all reports provided to their client(s). IARs are expected to review activity in client accounts on a quarterly basis, to periodically discuss the account with the client, and to ensure the suitability of the investment services provided based on each client’s specific situation. Third-Party Model Managers. Third-Party Model Managers who are responsible for managing portions of Formative client accounts are also responsible for ongoing review, supervision, and transactions in the client accounts they manage. Company Management. Formative’s senior management, including members of the Investment Committee, conduct both periodic reviews and various systematic samplings of accounts to supervise and ensure compliance with investment policy. Formative also monitors the performance of the VADIS portfolio construction workflow. Client Referrals and Other Compensation Client Referrals Formative may pay referral fees to firms (“Solicitors/Endorsers”) for introducing clients. These fees are asset-based. When the solicitor/endorser is associated with a third-party BD or RIA they are paid over the life of the relationship. Whenever Formative pays a referral fee, it requires the Solicitor/Endorser to provide the prospective client with a copy of the Disclosure Brochure, this document, an Investment Advisory Services Agreement (IAS), and a separate disclosure statement that includes the following information: • The Solicitor/Endorser’s name and relationship with Formative • The fact that the Solicitor/Endorser is being paid a referral fee • The amount of the fee; and • As a matter of firm policy, a client working with a Solicitor/Endorser will not be charged more than any other client. Other Compensation It is Formative’s policy not to accept or allow its 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 it provides to its clients.  Financial Information Under no circumstances does Formative require or solicit payment of fees in excess of $500 per client more than six months in advance of services rendered. Therefore, Formative is not required to include a financial statement in this disclosure document. As an advisory firm that maintains discretionary authority for client accounts through OPS at Schwab. Formative does not have custody of client assets. Formative is required to disclose any financial condition that is reasonably likely to impair its ability to meet its contractual obligations. Formative has no additional financial circumstances to report. Formative’s financial statements are audited or reviewed each calendar year by a qualified, independent CPA firm. Formative has never been the subject of a bankruptcy petition.  (Page Intentionally Left Blank)