HUMAN INVESTING

FORM ADV PART 2A WEALTH ADVISORY PRIVATE WEALTH ADVISORY ACCESS BY HUMAN INVESTING WORKPL ACE ADVISORY Human Investing 6000 Meadows Rd, Suite 105 Lake Oswego, OR 97035 (503) 905-3100 access.humaninvesting.com  ITEM 1 COVER PAGE HUMAN INVESTING, LLC (DBA HUMAN INVESTING) ACCESS BY HUMAN INVESTING ADVISORY PROGRAM BROCHURE 6000 Meadows Rd, Suite 105 Lake Oswego, OR 97035 Phone: (503) 905-3100 Firm Website: www.humaninvesting.com Access Website: https://access.humaninvesting.com March 13, 2026 This Form ADV Part 2 brochure provides information about the Access by Human Investing advisory program (formerly known as the “Rivermark Community Credit Union Advisory Program”) and the qualifications and business practices of its sponsor, Human Investing, LLC. If you have any questions or to obtain additional information about the contents of this brochure you may contact us by phone at (503) 905-3100 or by email to andrewg@humaninvesting.com. Human Investing is a registered investment advisor with the United States Securities and Exchange Commission (“SEC”). Registration of an investment advisor does not imply any level of skill or training. The information in this brochure has not been approved or verified by the SEC or any state securities authority. Additional information about Human Investing is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for our firm is 133017. ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 1  ITEM 2 MATERIAL CHANGES We have made the following material changes to this brochure since the previous annual amendment dated March 14, 2025: • • • Item 4 has been amended to reflect effective as of 1/31/2026, Peter Fisher is retired from Human Investing. Mr. Fisher remains a minority shareholder and is a promoter for Human Investing, who only receives compensation for referrals to Human Investing in the form of his share of the earnings of the firm. This promoter relationship has been disclosed in Item 14. Item 4 has been amended to reflect the sunsetting of the Charles Schwab Intelligent Institutional Portfolios (“Schwab IIP”) program, removing language referencing this no longer available service. Item 14 has been amended to reflect updates to the terms of our fee-splitting agreement with Rivermark CU. We have also amended Item 14 to reflect changes in our data sharing policy for clients referred to Human Investing from Rivermark CU. In addition to the above material changes, this brochure has been amended throughout for purposes of providing clients with increased clarity and transparency regarding our services, fees, and business practices. These changes are not material. We will update this brochure and summarize in this Item 2 any material changes with respect to our business in accordance with applicable law. All current clients will receive a Summary of Material Changes to this and subsequent brochures within 120 days of the close of our fiscal year and certain additional updates regarding changes with respect to our firm and our business practices as they may occur. Updated information concerning these changes will be provided to you free of charge. A Summary of Material Changes is also included within our brochure found on the SEC’s website at www.adviserinfo.sec.gov. You can obtain additional information about our firm by searching for us on the foregoing website by our firm name or by our unique IARD/CRD number (133017). Currently, our brochure may be requested by contacting Andrew Gladhill at (503) 905-3100 or by email at andrewg@humaninvesting.com. ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 2  ITEM 3 TABLE OF CONTENTS Item 1 — Cover Page ................................................................................................................................1 Item 2 — Material Changes ......................................................................................................................2 Item 3 — Table of Contents .....................................................................................................................3 Item 4 — Advisory Business . ....................................................................................................................4 Item 5 — Fees and Compensation ............................................................................................................6 Item 6 — Performance-Based Fees and Side-By-Side Management ............................................................10 Item 7 — Types of Clients .........................................................................................................................10 Item 8 — Methods of Analysis, Investment Strategies and Risk of Loss .......................................................10 Item 9 — Disciplinary Information .............................................................................................................13 Item 10 — Other Financial Industry Activities and Affiliations .....................................................................13 Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................14 Item 12 — Brokerage Practices ................................................................................................................15 Item 13 — Review of Accounts .................................................................................................................16 Item 14 — Client Referrals and Other Compensation .................................................................................17 Item 15 — Custody ..................................................................................................................................17 Item 16 — Investment Discretion ..............................................................................................................18 Item 17 — Voting Client Securities ............................................................................................................18 Item 18 — Financial Information...............................................................................................................19 ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 3  objectives. You will be required to enter into one or more written investment advisory agreements with us prior to the commencement of an advisor-client relationship and the delivery of any services. The written advisory agreement will set forth the scope of our services, our fees, and our respective rights and obligations to each other. For more information about our fees, please see Item 5 of this brochure. A description of the advisory services available to you under the Access Program is as follows: ITEM 4 ADVISORY BUSINESS A. Our Firm. Human Investing, LLC DBA Human Investing (“Human Investing,” “firm,” “we,” “our,” and “us”) is an Oregon limited liability company registered as an investment advisor with the SEC, which was founded in 2004. Our principal place of business is located in Lake Oswego, Oregon. Andrew Nelson is the CEO. The firm’s Chief Compliance Officer is Andrew Gladhill. Will Kellar and Marc Kadomatsu are also managing partners of the firm. B & C. Our Services. The “Access by Human Investing” advisory program (“Access” or “Access Program”) offers clients the opportunity to engage Human Investing for comprehensive financial planning, ongoing investment management, and tax consulting and compliance services that are tailored to their (“you,” “your,” and “client”) unique financial goals and needs. We utilize third party providers for certain functionalities to best serve you, including but not limited to tools to assist with: financial planning, portfolio rebalancing, AI notetakers, etc. Financial Planning Services: We offer financial planning and financial plans which are tailored to match the unique financial circumstances, goals, and needs of each client. This approach includes a team of credentialed experts to analyze and make financial recommendations customized to your unique financial objectives and needs. We are part of the 5% of advisors that are true fiduciaries, receiving no commissions for our advice. It is from the financial plan where we make saving, investing, and borrowing recommendations to our clients. The plan we provide to you will contain a series of investment recommendations that are designed to accomplish your specific short and long term financial goals and objectives. Our financial planning advice is typically offered exclusively in conjunction with our investment management services as a combined suite of wealth management services intended to help our clients manage their overall financial affairs. Human Investing and Rivermark Community Credit Union (“Rivermark CU”) have entered into an arrangement under which Access Program advisory services are made available to members of Rivermark CU. Rivermark CU receives certain compensation from Human Investing as a result of a member’s independent decision to engage Human Investing for Access Program services (please see Item 14 of this brochure for details). Rivermark CU members are never obligated to participate in the Access Program. Human Investing may enter into similar referral arrangements with additional credit unions, banks, other financial institutions, and third parties in the future. To the extent we should do so, Human Investing will disclose to all referred clients in writing the nature of the referral arrangement and any related conflicts of interest. A goals-based planning process is utilized to address financial concerns including social security and retirement planning, education planning, and various other savings and investment goals. Where applicable and requested by the client, we will provide you with advice relating to your variable annuity sub-accounts. Full details regarding the scope of the financial planning services we will provide to you and the frequency with which we will review and update our recommendations to you are set forth in a written investment advisory agreement you will enter with Human Investing at the inception of our relationship. Prior to forming an investment advisor-client relationship with you, Human Investing may offer you a complimentary general consultation to discuss the nature of its services and to determine how we may best assist you in achieving your financial goals and As described above, we provide these services exclusively in conjunction with our rendering of ongoing investment management services (described ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 4  below) to clients. Accordingly, we will use our investment discretion to implement and monitor the investments we recommend in the financial plan within the client’s designated investment accounts. Where the client’s financial plan includes recommendations related to assets held outside of the accounts designated for our ongoing management and supervision, the client will make all final investment decisions and will be responsible for implementation and monitoring of all such “held away” investments. When engaging us for these services, you will typically be required to grant us ongoing and continuous discretionary authority to execute our investment recommendations within your designated accounts without obtaining your prior approval for each specific transaction. This authority will include the ability to hire (and fire) sub-advisors and third- party money managers (collectively, “Independent Managers”) to manage some or all of your account, to reallocate your assets among the selected Independent Managers, and to select the specific investment models or strategies to be implemented within your account managed by any Independent Managers. For more information on the scope of our discretionary authority, please see Item 16 of this brochure. You are always able to place reasonable restrictions on the management of your accounts by Human Investing and any Independent Managers. For example, you may restrict our ability to invest in certain specific securities or industries. Investment Management Services: We focus on developing, managing, and supervising disciplined investment portfolios prescribed to our clients based on their unique financial circumstances, investment objectives, goals, and needs. Most clients who engage us for these services will receive financial planning services recommendations on a complimentary basis as part of their engagement. The nature of our financial planning services is described above. For individual clients, the basis for our investment management advice is their financial plan recommendations. For institutional clients, the recommended portfolios are a derivative of their investment policy statement (“IPS”). We either help the client build an IPS or we manage the investments to an existing IPS, depending on the client’s circumstances. In general, we manage client accounts within the program by implementing certain proprietary model portfolios (“HI Investment Models”) that have been designed by our firm to align with varying degrees of client risk tolerance, ranging from a more aggressive investment strategy to a more conservative approach. The particular HI Investment Model(s) utilized to manage your account will typically incorporate a broadly diversified mix of low-cost index funds and/or individual stock and bond strategies and will depend on the client’s financial plan, IPS, risk tolerance, and/or stated investment preferences and restrictions. We will consult with you periodically under the program to determine if there have been any material changes to your investment goals or needs and adjust your investment portfolio accordingly, as appropriate. We have partnered with Betterment, LLC (“Betterment”), an independent SEC registered investment advisor, to leverage their web-based investment platform to implement our HI Investment Models within client accounts in a secure digital environment offering real time portfolio access to clients. As part of the onboarding process, we will recommend that you enter into a separate sub- advisory agreement and brokerage relationship agreement with Betterment and its affiliated SEC registered broker-dealer, MTG, LLC doing business as Betterment Securities (“Betterment Securities”), Member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investors Protection Corporation (“SIPC”). Upon establishment of the sub-advisory and brokerage relationships with Betterment, we will instruct Betterment as to the specific HI Investment Models to be implemented within your account via their digital platform. Betterment, acting as a discretionary Independent Manager and sub-advisor to your account, will be responsible for all trading decisions and will only invest your account in strict accordance with the parameters we have set for the HI Investment Model(s) to be implemented within your account. Following the initial implementation of the desired portfolio of investments, we will monitor the status of your accounts at Betterment on an ongoing basis ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 5  and implement changes to your account as we believe to be necessary and appropriate based on your unique investment objectives and needs and our fiduciary duty to you. Fee Program are described in a separate Betterment Wrap Fee Brochure available at https://www.betterment.com/legal/form-adv-part-2. A copy of the Betterment Wrap Fee Brochure shall be provided to you by Betterment prior to or at the time of your enrollment in the program. Human Investing may recommend other wrap fee programs to clients in the future. Tax Consulting and Compliance Services: We are licensed with the State of Oregon’s Board of Tax Practitioners. Tax preparation and consulting services (collectively, “Tax Services”) include the preparation of client tax returns and/or consulting regarding the client’s specific tax circumstances and needs. Some tax planning, within the context of a financial plan, is included within our service offering. Tax compliance services (e.g., filing tax returns) as well as tax consulting projects are billed separately and like our financial planning services, will require gathering all necessary documents and information from you. You are never required to engage the firm or any of its associated persons for Tax Services and may seek tax preparation and consulting advice from any provider of your choice. Depending upon the cost of Betterment’s wrap fee, the amount of portfolio activity in your account, and the overall value of the services you receive from Human Investing and Betterment under the program, the wrap fee you will incur may or may not exceed the aggregate costs of advisory, custodial, and brokerage execution services if they were to be provided and charged to you separately (i.e., an unbundled fee arrangement). As a general matter, wrap fees are relatively less expensive for actively traded accounts. However, they may result in higher overall costs for client accounts that experience little trading activity. Clients are advised that unbundled fee arrangements are available from other providers. E. Assets Under Management. Human Investing manages approximately $964,226,219 of client assets on a discretionary basis and $1,259,935,556 client assets on a non-discretionary basis. Of the total assets reflected above, approximately $771,550,280 of non-discretionary assets can be attributed to retirement plans where Human Investing serves as a fiduciary under section 3(38) of ERISA, and $486,643,978 of non-discretionary assets can be attributed to retirement plans where Human Investing serves as a fiduciary under section 3(21) of ERISA. The total amount of regulatory assets under management for Human Investing is approximately $2,224,161,775. These amounts were calculated as of December 31, 2025. D. Wrap Fee Programs. A wrap fee program generally involves an investment account where you are charged a single bundled or “wrap” fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. Our investment management services under the Access Program are typically offered through the “Betterment Wrap Fee Program” sponsored by Betterment. Under this program, a portion of the Account Fees you will incur will consist of a “wrap fee” payable to Betterment. The wrap fee covers the costs of Betterment’s investment advisory services to the account (as sub-advisor), together with the customary custodial fees and trade execution costs incurred within your account. The costs of Betterment’s wrap fee are included within the Account Fees the client pays to Human Investing for these services as described in Item 5 of this brochure. ITEM 5 FEES AND COMPENSATION A. Our Fees.We are a “fee-only” investment advisor and neither our firm, nor any of our associated persons, accept commissions or any other form of remuneration for the sale of any securities or insurance products to clients. We act as your Clients should note that Human Investing and Betterment are independent of, not affiliated with, sponsored, endorsed, or supervised by each other. Human Investing’s ongoing role in managing client accounts under the Betterment Wrap Fee Program is described above in this Item 4. Additional terms and conditions of participation in the Betterment Wrap ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 6  balance of the client’s account, excluding the value of any cash balances. The wrap fee charged by Betterment is typically offset by an adjustment to our portion of the overall advisory fee. Account Fees for accounts managed via our arrangement with Betterment are calculated and paid as follows: fiduciary and will only recommend investments to you when we believe them to be in your best interests. The fees we charge for our services are set forth in a written advisory agreement entered with the client at the inception of our relationship. We may negotiate fees with clients in certain circumstances. Our fees may be amended prospectively from time to time upon thirty (30) days’ prior written notice to the client. • Account Fees are assessed and paid quarterly in arrears and pro-rated for partial periods. • Account Fees accrue for the period beginning one day before the end of the prior quarter and ending two days prior to the end of the current quarter. • Account Fees are calculated pursuant to this formula: [sum of the following for each day in the preceding quarter: (the balance in the Account at the end of the day, excluding cash balances) x (advisory fee applicable on that day)] • Account Fees will be paid first from cash or cash equivalents, or if not available, by selling a portion of the client’s holdings on the last business day of the quarter to cover the accrued fee amount. • Account Fees will be deducted from the client Fees For Combined Financial Planning and Investment Management Services: As reflected above in Item 4, clients typically receive financial planning services in conjunction with our rendering of ongoing investment management services. In these circumstances, we will charge you an annual asset-based “Account Fee” which consists of (i) an “Advisory Fee” payable to Human Investing which covers the costs of our investment management services to your account and (ii) for accounts managed via our arrangement with Betterment, a “Wrap Fee” (sometimes referred to as a platform fee) payable to Betterment which covers the costs of Betterment’s investment advice and the customary custodial and trade execution costs incurred within your account under the Betterment Wrap Fee Program. The costs of any financial planning services we provide you as an investment management client are included within our Account Fees unless we otherwise agree. Our standard Account Fee schedule is reflected below. account by Betterment three business days after the transaction date, following settlement of the resulting trade(s). The wrap fee portion of the Account Fees will be retained by Betterment and the balance (i.e., the Advisory Fee portion owed to Human Investing) will be remitted to Human Investing 2-3 weeks after the end of the quarter. ANNUAL ACCOUNT FEE VALUE OF ASSETS MANAGED BY HUMAN INVESTING Up to $500,000 1.25% (125 basis points) $500,001-$2,000,000 1.00% (100 basis points) $2,000,001-$5,000,000 0.85% (85 basis points) You may add or withdraw assets to or from your account with Betterment at any time, however, you should consider that some or all of the investments held for your account may be intended as long- term investments, and unexpected or premature liquidation of these holdings may impair the achievement of your investment goals and objectives. $5,000,001+ 0.80% (80 basis points) For avoidance of doubt, Betterment’s wrap fee is separate and distinct from the Advisory Fee paid to Human Investing, is absorbed within the Account Fee, and is retained wholly by Betterment. As of the date of this Brochure, Betterment charges clients a wrap fee of 0.14% per annum of the average daily Account fees at accounts not custodied at Betterment (e.g., at Charles Schwab & Co, Inc. or Fidelity Brokerage Services, LLC) are typically billed quarterly in advance and are paid to Human Investing via direct fee deduction from the client’s account at the qualified custodian. Unless otherwise agreed, we will rely on the market value of your account as determined by the custodian of your ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 7  assets in calculating our advisory fees. Fees for the initial period of services are based on the market value of the client’s assets as of the date of the deposit. Thereafter, such fees will be calculated based upon the market value of your assets as of the end of the prior quarter. We will pro-rate our asset- based fees for any partial billing periods (based on the number of days services were provided) and for mid-period additions and withdrawals of capital to or from your account (based on the transaction date). Your custodian will independently send you an account statement, typically monthly, but no less than quarterly, identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any fees directly deducted from your account. Your custodian is not responsible for verifying the accuracy of our fee calculations. Therefore, we encourage you to review the custodian’s account statements carefully upon receipt. If you believe our fees have been miscalculated or if there is any other issue with your account, you should contact us immediately at the phone number listed on the cover page of this brochure. Fees for stand-alone financial planning and Tax Services are billed via traditional invoicing as described above. In some instances, and only with your prior written consent, Human Investing may charge you hourly fees of up to $300 per hour for certain projects, as authorized in the IAA. These fees will be invoiced to you and paid by check, wire transfer or ACH, or debited directly from your nonqualified account at the qualified custodian of your assets with 30 days prior written notice or your approval. Hourly fees, if any, are separate and distinct from the asset based charges described above. Fees for Tax Services: When you engage us for Tax Services, fees will be determined based on a combination of assets under management for the client and the expected complexity of the Tax Services. In the event we go over the expected hours to complete a tax return, we will alert that we will start billing an hourly rate for additional work. We will typically charge you hourly fees at a rate of $300 per hour. All fees will be set forth in a written agreement executed by the client and Human Investing prior to our performance of any Tax Services. All fees are due upon presentation of our invoices and are payable to us via check or other mutually agreed upon payment method. C. Additional Fees and Expenses. Separate and in addition to the advisory fees payable to Human Investing, you shall be solely responsible to bear the costs of all internal management fees, advisory fees, and other costs and expenses that may be charged by mutual funds, ETFs, and other pooled investment vehicles to their shareholders. Except for accounts subject to wrap fees, you will also pay all usual and customary transaction-based fees (brokerage fees and commissions), custodial charges, wire transfer fees, and other fees and taxes associated with activity and holdings in your accounts. We do not share in any portion of the foregoing additional fees and expenses. To fully understand the total cost you will incur when engaging our services, you should review the prospectus of each mutual fund, ETF, and/or other pooled investment vehicle in which you participate and the contractual arrangement entered with your Independent Manager(s) and custodian (e.g., Betterment). B. Direct Fee Deduction. Where authorized by the client in writing, we will directly deduct our advisory fees from your account at the qualified custodian. Betterment will also direct deduct its portion of the Account Fee from your account. Your written authorization for direct fee deduction will be contained in our written advisory agreement and/ or the account opening documentation of your custodian (e.g., Betterment Securities). Payment of these fees via direct fee deduction may result in the liquidation of the client’s securities if there is insufficient cash in the account. D. Terminating Our Services. In the event we fail to provide you with a copy of this brochure at least forty-eight (48) hours in advance of your execution of written investment advisory agreement with our firm, you may terminate our services without penalty within five (5) business days of entering into the investment advisory agreement. Thereafter, either ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 8  receipt of additional fee-based compensation). You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in your best interests and not put our interests ahead of yours. party may terminate an advisory relationship on fifteen (15) days’ written notice. For asset-based fee engagements, clients will pay Human Investing a pro- rated fee based on the number of days services were provided through the date of termination. Human Investing will rebate clients on a pro-rata basis for any unearned fees that were billed in advance as of the date of termination. For hourly fee engagements, clients will pay Human Investing for all earned but unpaid hourly fees through the date of termination. All such fees are due immediately upon termination. Under this special rule’s provisions, we must: • meet a professional standard of care when making investment recommendations (give prudent advice); Termination policies related to the Betterment Wrap Program are described in a separate Betterment Wrap Fee Brochure available at https://www. betterment.com/legal/form-adv-part-2. • never put our financial interests ahead of yours when making recommendations (give loyal advice); • avoid misleading statements about conflicts of interest, fees, and investments; • follow policies and procedures designed to ensure that we give advice that is in your best interests; • charge no more than a reasonable fee for our E. Sale of Securities and/or Insurance Products. Neither the firm, nor any of its associated persons, accept any commissions for the sale of any securities or insurance products. We act as a fiduciary and will only recommend investments to you when we believe them to be in your best interests. services; and • give you basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in your employer’s (former employer’s) plan; Rollover Recommendations. As part of our investment advisory services to you, we may recommend that you roll assets from your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I of the ERISA and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset- based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e., Each of these options has positives and negatives. Because of that, along with the importance of ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 9  understanding the differences between these types of accounts, we will provide you with a written explanation of the advantages and disadvantages of both account types and the basis for our belief that the rollover transaction we recommend is in your best interests. A. Methods of Analysis and Investment Strategies. We construct portfolios based upon the client’s financial plan, IPS (if applicable), and/or risk tolerance. Client portfolios are typically constructed using a diversified mix of some or all of the following instruments: mutual funds, ETFs, individual stocks and bonds, cash, and cash equivalents. We may also advise clients on any assets held in their portfolio at the time of our engagement and other investments not listed above at the client’s specific request. We may use some or all of the following methods of analysis in providing investment advice to you: ITEM 6 PERFORMANCE-BASED FEES AND SIDE- BY-SIDE MANAGEMENT We do not charge any performance-based fees for our services or engage in side-by-side management of accounts. Accordingly, this item is not applicable to our firm. ITEM 7 TYPES OF CLIENTS Under the Access Program, we provide investment advice to the following types of clients: Fundamental Analysis: In using fundamental analysis, we attempt to determine the intrinsic value of target securities through a review of, among other things, company specific financial disclosures, the strength and track record of management personnel, industry sector financial health, and at a macro level, the overall direction of the economy at large. We use this information as a basis to determine if such securities are underpriced or overpriced relative to current market prices and then to make a buy or sell recommendation to you. • Individuals, including high-net worth individuals; • Trusts, estates, and charitable organizations; and • Corporations and other business entities. Because each client is unique, we encourage involvement in the planning and processes involved in the management of their accounts. Such involvement does not have to be time consuming, however it is our goal that clients remain informed and have a sense of security about their investments. Relying on this type of analysis leaves open the risk that the price of a security may move along with the overall direction of the market, irrespective of the economic and financial factors which may have indicated that an opposite movement would have been expected. The main sources of information we rely upon when researching and analyzing securities using fundamental analysis include research materials prepared by others, annual reports, corporate rating services, prospectuses, and company press releases. As a firm, we value having a diverse client base and ensuring that professional financial advice remains reasonably accessible to clients from all walks of life. For this reason, we do not impose any minimum annual fee requirements or account size requirements to open or maintain an advisory relationship with our firm under the Access Program. ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Asset Allocation: Rather than focusing on selecting the particular securities or other assets to invest for your account, we attempt to identify an appropriate ratio of various types of investments (for example, stocks, fixed income, and cash) suitable to your investment goals, time horizon, and risk tolerance. A risk of asset allocation is that you may not participate in sharp increases in a particular security, industry, or market sector. 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 ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 10  corrected, will no longer be appropriate to meet with your investment goals. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the recommendation to sell. Short-term purchases: When utilizing this strategy, we may suggest the purchase of securities with the idea of selling them within one year of purchase. We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we recommend for purchase. Mutual Fund and ETF Selection and Analysis: We evaluate and select mutual funds and ETFs based on several factors which may include, without limitation, (1) the experience and track record of the underlying portfolio manager(s), (2) the performance of the fund over time and through various market conditions; (3) expected market conditions that might impact the underlying holdings of the fund or applicable market sector; and (4) whether and to what extent the underlying holdings of the fund overlap with other assets held in your account. We also monitor the fund in an attempt to determine if it is continuing to follow its stated investment strategy. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are 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 will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short term capital gains. A risk of this form of analysis is that, as in all securities investments, past performance does not guarantee future results. A fund manager’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of the fund are determined by independent fund managers and may change overtime without advance warning, creating the potential for overlap with other investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund, which could make the holding(s) less suitable for the client’s portfolio. We typically use the following investment strategies in managing client accounts: B. We will use our best judgment and good faith efforts in rendering services to each client. We cannot guarantee any level of investment performance or that any investment will be profitable over time. Not every investment decision or recommendation made by us will be profitable. Investing in securities involves risk of loss that clients should be prepared to bear. Clients assume all market risk involved in the investment of their account and understand that investment decisions made for their account are subject to market, currency, economic, political, and business risks. It is the responsibility of each client to provide us with complete, accurate information and to notify us in a timely manner of any changes in the client’s financial circumstances or goals. Long-term Purchases: We may recommend a long term “buy and hold” approach to investing client assets. In this type of investment strategy, we suggest the purchase of securities with the idea of holding them in a portfolio for a year or longer. Typically, we employ this strategy when (1) we believe the securities to be currently undervalued, and/or (2) we want the portfolio to have exposure to a particular asset class over time, regardless of the current projection for this class. C. Summary of Investment Risks. While all investing involves risks and losses can and will occur, we generally recommend a broad and diversified allocation of securities and other investments intended to reduce the specific risks associated with a concentrated or undiversified portfolio. ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 11  Nonetheless, you should consider the following high-level summary of investment risks. This list is not intended to be an exhaustive description of all risks you may encounter in engaging our firm for advisory services. We encourage you to inquire with us frequently about the risks related to any investments in your account. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g., earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. Risk of Loss: Securities investments are not guaranteed, and you may lose money on your investments. As with any investment manager that invests in common stocks and other equity securities, our investment recommendations are subject to market risk—the possibility that securities prices will decline over short or extended periods of time. As a result, the value of your account(s) will fluctuate with the market, and you could lose money over short or long periods of time. You should recognize whenever you determine to invest in the securities markets your entire investment is at risk. Clients should not invest money if they are unable to bear the risk of total loss of their investments. Risks Related to Analysis Methods: Our analysis of securities relies in part on the assumption that the issuers whose securities we recommend for purchase and sale, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Economic Risk: The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the “dot com” companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Cybersecurity Risk: We rely on the use of various electronic technologies to conduct our investment advisory business and are therefore susceptible to operational, information security, and related risks, including risks of unintentional cyber incidents and deliberate cyber-attacks. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of corrupting data, or causing operational disruption, as well as denial- of-service attacks on websites. Cyber incidents may cause disruptions and impact on our business operations, potentially resulting in financial losses, interference with a client’s ability to value their investments, impediments to trading, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 12  other compensation costs, or additional compliance costs. While the firm and its most significant counterparties and vendors have established business continuity plans and risk management systems to help mitigate cyber incidents, there are inherent limitations in such plans and systems that are inherently outside of our control. ITEM 9 DISCIPLINARY INFORMATION We are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm or the integrity of our management. We have no information to disclose applicable to this item. ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Human Investing and its associated persons are not registered and do not have any application(s) pending to register as a broker-dealer or as a registered representative of any broker-dealer. Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and macroeconomic factors may negatively impact investment returns. B. Human Investing and its associated persons are not registered and do not have any application(s) pending to register as a future commissions merchant, commodity pool operator, commodity trading advisor, or as a representative of any of the foregoing. C. Human Investing and its associated persons do not receive any commissions or any other forms of compensation in connection with the sale of any securities or insurance products to clients. Securities Transactions at the Direction of Clients: All assets are held at an independent qualified custodian in your name. You will typically maintain the concurrent ability to self-direct transactions within your account. We are not responsible for the consequences, costs, and fees generated by your self-directed investment transactions or transactions you instruct us to implement on your behalf where we have advised you that such transactions are not in your best interests. Rivermark CU refers its members to Human Investing for investment advisory services under the Access Program. Relative to other advisory clients of Human Investing, Rivermark CU members do not pay any increased fees or costs to Human Investing as a result of their referral by Rivermark CU to the Access Program. Additional details regarding the revenue sharing agreement between our firm and Rivermark CU are disclosed in Item 14 of this brochure. Human Investing has a relationship with DPL Financial Partners, LLC (“DPL”), a third-party insurance platform sponsor, through which Human Investing advises on and makes available to its clients certain fee-based insurance and securities products, including variable annuity sub-accounts. Under this arrangement, DPL Partners pays advisory Interim Changes in Client Risk Tolerance and Financial Outlook: The particular investments recommended by our firm are based solely upon the investment objectives and financial circumstances disclosed to us by the client. While we strive to meet with clients at regular intervals (at least annually, unless otherwise agreed, either in person, telephonically, or by electronic means) to discuss any changes in the client’s financial circumstances, the lack of constant and continuous communication presents a risk insofar as your liquidity, net worth, risk tolerance and/or investment goals could change abruptly, with no advance notice to our firm, resulting in a mis-aligned investment portfolio and the potential for losses or other negative financial consequences. ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 13  fees to Human Investing on account of the advisory services Human Investing provides to its advisory clients. The fees paid to Human Investing under this arrangement consist of asset-based fees in line with its standard Account Fee schedule set forth in Item 5 of this brochure. For the avoidance of doubt, Human Investing and its associated persons do not receive commissions on the sale of any insurance products or securities products. trades for proprietary accounts along with trades for our clients’ accounts. Alternatively, we may process trades in proprietary accounts after completing all trades in those securities in client accounts. In some cases, we may buy or sell securities for our own accounts for reasons not related to the strategies deployed on behalf of our clients. Notwithstanding the foregoing, clients should note that our firm does not have the ability to exercise any influence over the timing of orders processed through Betterment. In summary, our practice of buying and selling for Proprietary Accounts the same securities that we buy or sell for client accounts is restricted by the following controls: • We are always required to uphold our fiduciary duty to our clients; • We are prohibited from misusing information about our clients’ securities holdings or transactions to gain any undue advantage for ourselves or others; ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING A. Our Code of Ethics. Human Investing has adopted a Code of Ethics which all employees are required to follow. The Code of Ethics outlines proper conduct related to all services provided to our clients. Prompt reporting of internal violations is mandatory. Our Chief Compliance Officer periodically evaluates employee performance to ensure compliance with the Code of Ethics. A copy of the Code of Ethics is available to any client upon request. • We are prohibited from buying or selling any security that we are currently recommending for client accounts, unless we participate in an aggregated trade with clients or place our orders after client orders have been executed; and • We are required to periodically report our securities holdings and transactions to the firm’s Chief Compliance Officer, who must review those reports for improper trades. B-D. Material/Proprietary Interests in Securities Recommended to Clients. Our firm and our associated persons do not have any proprietary or material interests in or any role in the management of any companies or investments that we recommend to our clients. We will disclose to clients material conflicts which could reasonably be expected to impair the rendering of unbiased and objective advice. Personal Trading; Participation or Interest in Client Transactions. Human Investing and/or its associated persons may manage accounts which belong either to themselves, individually, or to their family or their affiliates (collectively, “Proprietary Accounts”) while simultaneously managing client accounts. Proprietary Accounts may buy and sell some the same securities as we buy or sell for client accounts. This practice creates an actual conflict of interest with our clients insofar as our firm and/ or our associated persons may have a financial incentive to trade in securities for Proprietary Accounts in advance of or opposite to transactions in the same securities for client accounts. To address this conflict, our general policy is to aggregate any Accounts Managed at Betterment. Where your account is managed via Betterment’s platform, Betterment’s automated trading system automatically reviews all accounts (including both client accounts and accounts owned by Human Investing and/or its associated persons) for rebalancing opportunities. Where the holdings of any account drift outside certain pre-determined limits, Betterment’s system will autonomously place orders to rebalance the account. Rebalancing trades may also be placed by Betterment to account for deposits and withdrawals of funds, changes made by Human Investing to its proprietary HI Investment ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 14  Models, and/or Human Investing selecting different HI Investment Models for implementation in a client’s account. Our firm does not have the ability to exercise any influence over the timing of orders processed through Betterment. consideration the full range of the recommended broker-dealer’s services. Some of the factors we may consider when evaluating a broker-dealer for best execution include, without limitation, the broker- dealer’s: • transaction costs; • facilities, reliability, and financial responsibility; • ability to effect transactions, particularly with regard to such aspects as timing, order size, and the speed of order execution; • research and related brokerage services provided; and • any other factors the firm considers to be relevant. ITEM 12 BROKERAGE PRACTICES A. Recommendation of Broker-Dealers; Best Execution; Directed Brokerage; Soft Dollar Practices. When you engage us for investment management services under the Access Program, we will generally recommend that you separately engage the sub-advisory services of Betterment and the custodial and trade execution services of its affiliated broker-dealer, Betterment Securities (Member FINRA/SIPC) as part of your participation in the Betterment Wrap Fee Program. We do not open these accounts for you, although we may assist you in completing the related account opening paperwork required by Betterment and Betterment Securities. If you do not wish to place your assets with Betterment, then we cannot manage your account on the Betterment platform. Where you elect to engage a custodian other than the custodian we recommend for custody and execution of transactions (i.e., Betterment Securities), you are advised that we may be unable to seek best execution of your transactions and your commission costs may be higher than those experienced by clients who elect to utilize our recommended custodian. This is known as client directed brokerage. For example, in a client directed brokerage account, you may pay higher brokerage commissions and/ or receive less favorable prices on the underlying securities purchased or sold for your account because we may not be able to aggregate your order with the orders of other clients. In addition, where you direct brokerage, we may place orders for your transactions after we place transactions for clients using our recommended custodian. We reserve the right to reject your request to use a particular custodian other than the recommended custodian if such selection would frustrate our management of your account, or for any other reason. If you agree to engage their services, Betterment Securities will hold your assets in a brokerage account held in your name and buy and sell securities automatically as directed by Betterment according to the HI Investment Model(s) we select for your account. As described in Item 5, the Account Fee charged by Human Investing for its investment management services covers the costs of Betterment’s wrap fee of 0.14% per annum of the assets managed via their platform, resulting in no additional costs to you. “Soft dollar” arrangements refer to the practice of directing a certain volume of securities transactions (and their resulting trading commissions) to a particular broker-dealer in exchange for the receipt of certain ancillary benefits (such as proprietary investment research) by an investment advisor. Human Investing does not maintain any soft dollar arrangements with any broker-dealers and does not intend to enter into any such arrangements in the future. In recommending broker-dealers to clients, we have an obligation to seek the “best execution” of transactions for client accounts. This duty requires us to seek to execute securities transactions for clients such that the total costs or proceeds in each transaction are the most favorable under the circumstances. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 15  already in the portfolio, taking into consideration the tax impacts of such transactions. In the event of enough deviation from model targets to trigger a rebalance, the account will be rebalanced as determined by an algorithm-based trading system. All trades are processed automatically using Betterment’s automated technology. Human Investing and its clients are not able to affect specific transactions through Betterment’s platform. Accordingly, clients wishing to direct the specific time of day to buy or sell securities should not enroll in the Betterment Wrap Fee Program. Transactions do not generally occur during the first 30 minutes and final 30 minutes of the trading day. Human Investing may suspend trading for particular accounts on the Betterment platform. No trades will occur in these accounts until specified otherwise by Human Investing. Notwithstanding the foregoing, the broker-dealers we recommend to clients (e.g., Betterment Securities) provide us with certain services and benefits, either free of charge or at a discount, in connection with our custodial relationships. Examples of the services and benefits we receive may include access to a dedicated trading desk; trading and client relationship management software; enhanced reporting capabilities; the ability to directly deduct fees from client accounts; access to aggregated trading; and admission to industry seminars and events. Many of these services and benefits assist in managing client accounts, while others assist us in managing our overall business enterprise. While these benefits do not materially affect the investment advice we provide to clients, clients should be aware that our receipt of these services and benefits may indirectly influence our choice to recommend certain broker-dealers to clients. We address this conflict of interest by ensuring that our clients receive best execution from the broker-dealers we recommend. B. Trade Aggregation. Human Investing is authorized in its discretion to aggregate purchases, sales, and other transactions made for client accounts with the purchases, sales and other transactions in the same or similar securities/ instruments for the accounts of other clients of Human Investing. When transactions are aggregated, the actual prices applicable to the aggregated transactions will be averaged, and your account will be deemed to have purchased or sold its proportionate share of the securities/instruments involved at the average price so obtained. In conformity with applicable law, Human Investing will direct their custodians to send confirmations of all transactions effected in client accounts to the client’s address of record. ITEM 13 REVIEW OF ACCOUNTS A. Account Reviews. Client accounts are typically reviewed periodically by the investment advisor representative who is primarily responsible for managing the client’s assets. However, individuals conducting reviews may vary from time to time, as personnel join or leave our firm. The frequency of reviews is determined based on each client’s investment objectives and investment profile. Accounts are also systematically checked on a daily basis by the Betterment platform and rebalanced automatically if their holdings drift outside certain pre-determined tolerances set by Betterment. In addition, Human Investing typically performs an overall assessment of each client account on at least an annual basis. Human Investing encourages clients to review their financial plan and to meet with their advisor annually (at a minimum) to discuss potential changes to their financial plan. During this meeting, we may request that clients complete a risk tolerance questionnaire. B. More Frequent Reviews. More frequent reviews of client accounts may be triggered by a change in a client’s investment objectives, tax For accounts managed via the Betterment platform, trades are processed automatically by Betterment based on the HI Investment Model assigned to your account by Human Investing and may be combined with trades for the accounts of other clients. Inflows or outflows of funds will be utilized to try and bring the account closer to the targets built into the selected HI Investment Model(s). Absent inflows or outflows of capital, Betterment may rebalance the account by buying and selling securities which are ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 16  considerations, large deposits or withdrawals, large sales or purchases, loss in confidence of corporate management and objectives, and/or changes in the macro-economic climate. C. Reporting. Clients will receive account statements directly from the custodian of their account(s) generally on a monthly basis, but no less than quarterly, in paper and/or electronic formats. providing advisory, custodial, and trade execution services under the Betterment Wrap Fee Program. These fees are included in the Account Fees detailed in Item 5, and do not result in any increased costs relative to other advisory clients of Human Investing. We do not receive compensation from Betterment or its affiliates in exchange for requiring that clients engage their sub-advisory, brokerage, and custodial services in order to participate in the Access Program. ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION As described in Item 4, Rivermark CU refers its members to Human Investing for investment advisory services offered under the Access Program. In exchange for its referral of members, Human Investing has entered into a fee-splitting arrangement with Rivermark CU pursuant to the schedule below: Clients are advised that Human Investing pays bonus compensation to its investment advisor representatives based on the referral and/or servicing of new client accounts. This arrangement creates a conflict of interest since our investment advisor representatives have a financial incentive to refer new clients to the firm and to encourage the deposit and/or maintenance of funds and securities in accounts managed by Human Investing. The firm and its investment advisor representatives are fiduciaries and will only provide advice to you that we believe to be in your best interests. TOTAL ASSET SIZE OF CU MEMBERS REVENUE SHARE (FLAT % FOR ALL REVENUE) Up to $100,000,000 20.00% $100,000,001-$150,000,000 22.50% $150,000,001+ 25.00% Human Investing engages one or more promoters who refer prospective clients. Such promoters are compensated indirectly through their ownership interest in the firm and therefore benefit financially from advisory fees paid by referred clients. This arrangement creates a conflict of interest because the promoter has an incentive to recommend Human Investing. Clients are under no obligation to engage our firm as a result of such referrals. As of the date of this brochure, we have no other arrangements, written or oral, in which we compensate others or are compensated by others for client referrals. While referred Rivermark CU members do not pay any increased fees or costs to Human Investing relative to other participants in the Access Program as a result of their referral by Rivermark CU, such clients are advised that the foregoing revenue sharing arrangement creates a financial incentive for Rivermark CU to recommend the Access Program to its members. Human Investing and Rivermark CU may share data regarding clients referred to Human Investing from Rivermark CU. Human Investing will not share your data with Rivermark CU if you are not a referral from Rivermark CU. As described in Item 5, Betterment charges a 0.14% per annum wrap fee for all assets under management on their platform in exchange for ITEM 15 CUSTODY All client funds and securities on which we advise are held in accounts titled in the client’s name maintained by an independent qualified custodian (typically, Betterment Securities). For Access Program clients receiving ongoing investment management services, the custodian will be ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 17  authorized to execute trades within the client’s account upon our instructions (or the instructions of the Independent Manager, typically, Betterment), acting within the scope of the authority granted in our written advisory agreement with the client and the custodian’s account opening documentation. fire Independent Managers to manage some or all of the client’s account, to reallocate client assets among the selected Independent Managers, and to select the specific investment models or strategies to be implemented within the client’s account managed by any Independent Managers. Clients grant the foregoing authority to Human Investing in our written investment advisory agreement and/or the account opening documentation of their custodian. ITEM 17 VOTING CLIENT SECURITIES While we may receive informational copies of proxy statements and annual reports, unless specifically directed otherwise in writing by the client, Human Investing is not authorized to receive and vote proxies on issues held in the account or receive annual reports. Where we directly debit our advisory fees from your account held at the custodian, the custodian will independently send you an account statement at least quarterly identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any fees paid to us. Your custodian is not responsible for verifying the accuracy of our fee calculations. Therefore, we encourage you to review the Custodian’s account statements carefully upon receipt. If you believe our fees have been miscalculated or if you have any other questions related to your account, you should contact us immediately at the phone number listed on the cover page of this brochure. Certain clients may execute standing letters of authorization (“SLOAs”) granting Human Investing the ability to disburse certain funds on behalf of the client. Where a client has executed a SLOA, Human Investing follows the guidance set forth in the SEC’s no-action letter to the Investment Adviser Association dated February 21, 2017. Human Investing has engaged an independent third-party service provider, Broadridge Financial Solutions, Inc. (“BFS”), to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of our firm’s investment management services clients. Human Investing does not receive any fees or remuneration in connection with this service, nor does it receive any fees from the third-party provider(s). BFS earns a fee based on a flat percentage (typically 20%) of all claims it collects on behalf of Human Investing’s clients. This fee is collected and retained by BFS out of the claims paid by the claim administrator. Clients are advised that it may be necessary to share client information, such as your name and account number, with BFS in connection with this service. All clients who engage Human Investing for investment management services are automatically enrolled in this service unless they elect to opt-out. You may opt-out of this service at any time by notifying us in writing. If a client opts out, Human Investing does not have an obligation to advise or take any action on behalf of a client with regard to class action litigation involving investments held in or formerly held in a client’s account. We have the right to change the provider of this service at any time in our sole ITEM 16 INVESTMENT DISCRETION Except as otherwise agreed, clients grant us ongoing and continuous discretionary authority to execute investment recommendations within their designated accounts without obtaining the client’s prior approval for each specific transaction. Under this discretionary authority, clients allow us to purchase and sell securities and other instruments in their account(s), arrange for delivery and payment in connection with the foregoing, and otherwise act on their behalf in most matters necessary or incidental to the handling of the account, which includes monitoring of certain assets. This authority includes the ability of Human Investing to hire and ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 18  discretion. If we do so, we will notify you and send you another opt-out election form. Because we are providing this service through BFS, we no longer monitor class action suits or process claim forms on your behalf (whether or not you participate in the service BFS provides). We are not responsible or liable for: (a) any assistance we provide to BFS concerning monitoring or processing class action claims or (b) any act or omission by BFS in monitoring or processing such claims. ITEM 18 FINANCIAL INFORMATION A. Human Investing does not require prepayment of more than $1,200 in fees six or more months in advance, therefore, we have nothing to disclose that is applicable to this item. B. As mentioned in Item 16 above, we have discretionary authority over some client funds. As we have no financial commitments which would impair our ability to meet the contractual and fiduciary commitments to our clients, we have nothing to disclose that is applicable to this item. C. Human Investing has never been the subject of any bankruptcy proceedings. ACCESS BY HUMAN INVESTING ADVISORY PROGRAM FORM ADV 2A • 19  

FORM ADV PART 2A WEALTH ADVISORY PRIVATE WEALTH ADVISORY ACCESS BY HUMAN INVESTING WORKPL ACE ADVISORY Human Investing 6000 Meadows Rd, Suite 105 Lake Oswego, OR 97035 (503) 905-3100 www.humaninvesting.com  ITEM 1 COVER PAGE HUMAN INVESTING, LLC (DBA HUMAN INVESTING) 6000 Meadows Rd, Suite 105 Lake Oswego, OR 97035 (503) 905-3100 www.humaninvesting.com March 13, 2026 This Form ADV Part 2A brochure provides information about the qualifications and business practices of Human Investing, LLC. If you have any questions or want to obtain additional information about the contents of this brochure, you may contact us by phone at (503) 905-3100 or by email to andrewg@humaninvesting.com. Human Investing, LLC is a registered investment advisor with the United States Securities and Exchange Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or training. The information in this brochure has not been approved or verified by the SEC or any state securities authority. Additional information about Human Investing, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for our firm is 133017. FORM ADV PART 2 • 1 human investing® ITEM 2 MATERIAL CHANGES We have made the following material changes to this brochure since the previous annual amendment dated March 13, 2025: • • • • Item 4 has been amended to reflect effective as of 1/31/2026, Peter Fisher is retired from Human Investing. Mr. Fisher remains a minority shareholder and is a promoter for Human Investing, who only receives compensation for referrals to Human Investing in the form of his share of the earnings of the firm. This promoter relationship has been disclosed in Item 14. Item 4 has been amended to include language about our new offering with Vanguard Personalized Indexing (“VPI”). Item 5 has been amended to reflect a new fee schedule available for clients with over $3 million in AUM Item 12 has been amended to confirm we do not engage in soft dollar arrangements. In addition to the above material change(s), this brochure has been amended in certain instances for purposes of providing clients with increased clarity and transparency regarding our services, fees, and business practices. These changes are not material. We will update this brochure and summarize in this Item 2 any material changes with respect to our business in accordance with applicable law. All current clients will receive a Summary of Material Changes to this and subsequent brochures within 120 days of the close of our fiscal year and certain additional updates regarding changes with respect to our firm and our business practices as they may occur. Updated information concerning these changes will be provided to you free of charge. A Summary of Material Changes is also included within our brochure found on the SEC’s website at www.adviserinfo.sec.gov. You can obtain additional information about our firm by searching for us on the foregoing website by our firm name or by our unique IARD/CRD number (133017). Currently, our brochure may be requested by contacting Andrew Gladhill at (503) 905-3100 or by email to andrewg@humaninvesting.com. FORM ADV PART 2 • 2 human investing® ITEM 3 TABLE OF CONTENTS Item 1 — Cover Page ................................................................................................................................1 Item 2 — Material Changes ......................................................................................................................2 Item 3 — Table of Contents .....................................................................................................................3 Item 4 — Advisory Business . ....................................................................................................................4 Item 5 — Fees and Compensation ............................................................................................................6 Item 6 — Performance-Based Fees and Side-By-Side Management ............................................................9 Item 7 — Types of Clients .........................................................................................................................9 Item 8 — Methods of Analysis, Investment Strategies and Risk of Loss .......................................................10 Item 9 — Disciplinary Information .............................................................................................................13 Item 10 — Other Financial Industry Activities and Affiliations .....................................................................13 Item 11 — Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .....................13 Item 12 — Brokerage Practices ................................................................................................................14 Item 13 — Review of Accounts .................................................................................................................15 Item 14 — Client Referrals and Other Compensation .................................................................................15 Item 15 — Custody ..................................................................................................................................16 Item 16 — Investment Discretion ..............................................................................................................16 Item 17 — Voting Client Securities ............................................................................................................17 Item 18 — Financial Information...............................................................................................................17 FORM ADV PART 2 • 3 human investing® We offer the following investment advisory services: ITEM 4 ADVISORY BUSINESS A. Our Firm. Human Investing, LLC DBA Human Investing (“Human Investing,” “firm,” “we,” “our,” and “us”) is an Oregon limited liability company registered as an investment advisor with the SEC, which was founded in 2004. Our principal place of business is located in Lake Oswego, Oregon. Andrew Nelson is the CEO. The firm’s Chief Compliance Officer is Andrew Gladhill. Will Kellar and Marc Kadomatsu are also managing partners of the firm. As of 1/31/2026, Peter Fisher is retired from Human Investing. Mr. Fisher remains a minority shareholder and is a promoter for Human Investing, who only receives compensation for referrals to Human Investing in the form of his share of the earnings of the firm. Financial Planning Services: We offer financial planning and financial plans which are tailored to match the unique financial circumstances, goals, and needs of each client. This approach includes a team of credentialed experts to analyze and make financial recommendations customized to your unique financial objectives and needs. We are part of the 5% of advisors that are true fiduciaries, receiving no commissions for our advice. It is from the financial plan where we make saving, investing, and borrowing recommendations to our clients. The plan we provide to you will contain a series of investment recommendations that are designed to accomplish your specific short-term and long-term financial goals and objectives. Our financial planning advice is typically offered exclusively in conjunction with our investment management services as a combined suite of wealth management services intended to help our clients manage their overall financial affairs. A comprehensive cash-flow based planning process is utilized to address financial concerns including social security and retirement planning, education planning, and various other savings and investment goals. Goals-based plans may be utilized as well depending on the client’s financial situation. Full details regarding the scope of the financial planning services we will provide to you and the frequency with which we will review and update our recommendations to you are set forth in a written investment advisory agreement you will enter with Human Investing at the inception of our relationship. B & C. Our Services. Human Investing offers comprehensive financial planning, investment management, and tax consulting and compliance services to its clients (“you,” “your,” and “client”). We utilize third party providers for certain functionalities to best serve you, including but not limited to tools to assist with: financial planning, portfolio rebalancing, AI notetakers, etc. Additionally, for the workplace, we offer committee level fiduciary services to retirement plan sponsors as well as services focused on education and advice to individual retirement plan participants inside those workplace accounts (most often consisting of employer sponsored 401(k) accounts). All services are tailored to your unique financial goals and needs. Prior to forming an investment advisor-client relationship with you, Human Investing may offer you a complimentary general consultation to discuss the nature of its services and to determine how we may best assist you in achieving your financial goals and objectives. You will be required to enter into one or more written investment advisory agreements with us prior to the commencement of an advisor-client relationship and the delivery of any services. The written advisory agreement will set forth the scope of our services, our fees, and our respective rights and obligations to each other. For more information about our fees, please see Item 5 of this brochure. As described above, we provide these services exclusively in conjunction with our rendering of ongoing investment management services (described below) to clients. Accordingly, we will use our investment discretion to implement and monitor the investments we recommend in the financial plan within the client’s designated investment accounts. Where the client’s financial plan includes recommendations related to assets held outside of the accounts designated for our ongoing management and supervision, the client will make all final investment decisions and will be responsible for implementation and monitoring of all such “held away” investments. FORM ADV PART 2 • 4 human investing®  securities in a given index directly, instead of buying a mutual fund or ETF. VPI has a separate fee structure that clients utilizing the service are responsible for bearing, like the expense ratio of a mutual fund or ETF. See Item 5 for more details about the costs associated with utilizing VPI. Investment Management Services: We focus on developing, managing, and supervising disciplined investment portfolios prescribed to our clients based on their unique financial circumstances, investment objectives, goals, and needs. Most clients who engage us for these services will receive financial planning services recommendations on a complimentary basis as part of their engagement. The nature of our financial planning services is described above. For individual clients, the basis for our investment management advice is their financial plan recommendations. For institutional clients, the recommended portfolios are a derivative of their investment policy statement (“IPS”). We either help the client build an IPS or we manage the investments to an existing IPS, depending on the client’s circumstances. We typically utilize broadly diversified low-cost index fund portfolios and/or individual stock and bond strategies depending on the client’s financial plan/IPS, risk tolerance, and/or stated investment preferences and restrictions. Tax Consulting and Compliance Services: We are licensed with the State of Oregon’s Board of Tax Practitioners. Tax preparation and consulting services (collectively, “Tax Services”) include the preparation of client tax returns and/or consulting regarding the client’s specific tax circumstances and needs. Some tax planning, within the context of a financial plan, is included within our service offering. Tax compliance services (e.g., filing tax returns) as well as tax consulting projects are billed separately and like our financial planning services, will require gathering all necessary documents and information from you. You are never required to engage the firm or any of its associated persons for Tax Services and may seek tax preparation and consulting advice from any provider of your choice. Workplace Advisory Services: We offer general employee investment education and tailored investment advice to retirement plan participants. We also offer consulting services to retirement plan sponsors acting as a fiduciary and/or investment manager pursuant to sections 3(21) and/or 3(38) of the Employee Retirement Income Security Act of 1974 (“ERISA”). In this capacity, our role is typically to provide investment management to 401(k) plans and/or to advise on the selection of funds within such plans. The fees associated with each of the above services are described in Item 5 of this brochure. When engaging us for these services, you will typically be required to grant us ongoing and continuous discretionary authority to execute our investment recommendations within your designated accounts without obtaining your prior approval for each specific transaction. For more information on the scope of our discretionary authority, please see Item 16 of this brochure. You are always able to place reasonable restrictions on our management of your accounts, such as restricting our ability to invest in certain specific securities or industries. Following our initial implementation of the desired portfolio of investments, we will monitor the status of your accounts on an ongoing basis and implement changes to your portfolio as we believe to be necessary and appropriate based on your unique investment objectives and needs and our fiduciary duty to you. In certain circumstances we may recommend and implement direct indexing strategies through third- party providers, including Vanguard Personalized Indexing (“VPI”), which will act as a sub-advisor or Independent Manager. VPI offers direct indexing strategies, which allow you to own the underlying D. Wrap Fee Programs. A wrap fee program generally involves an investment account where you are charged a single, bundled, or “wrap” fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. Except for services offered under our separate “Access by Human Investing” advisory program (“Access Program”), we do not sponsor, serve as the portfolio manager to, or recommend any wrap fee programs to our clients. We maintain a separate informational FORM ADV PART 2 • 5 human investing® For new clients beginning with assets below $3,00,000, we will charge you fees in accordance with the following fee schedule: brochure that describes the nature of our Access Program services and fees. Please inquire with us at the telephone number reflected on the cover page of this brochure if you would like to receive a free copy of our Access Program brochure. ANNUAL ASSET-BASED FEE VALUE OF ASSETS MANAGED BY HUMAN INVESTING Up to $500,000 1.25% (125 basis points) $500,001-$2,000,000 1.00% (100 basis points) $2,000,001-$5,000,000 0.85% (85 basis points) $5,000,001+ 0.80% (80 basis points) E. Assets Under Management. Human Investing manages approximately $964,226,219 of client assets on a discretionary basis and $1,259,935,556 client assets on a non-discretionary basis. Of the total assets reflected above, approximately $771,550,280 of non-discretionary assets can be attributed to retirement plans where Human Investing serves as a fiduciary under section 3(38) of ERISA, and $486,643,978 of non-discretionary assets can be attributed to retirement plans where Human Investing serves as a fiduciary under section 3(21) of ERISA. The total amount of regulatory assets under management for Human Investing is approximately $2,224,161,775. These amounts were calculated as of December 31, 2025. Where you elect to receive combined ongoing investment management and financial planning services, your account will be subject to a minimum annual fee of $6,250. Clients who elect to receive ongoing investment management services only are not subject to this minimum annual fee. Please see Item 7 of this brochure for additional information regarding how you can avoid our minimum annual fee. For new clients beginning with assets above $3,000,000 we have an alternative fee schedule, in accordance with the following fee schedule: ANNUAL ASSET-BASED FEE VALUE OF ASSETS MANAGED BY HUMAN INVESTING 1.00% (100 basis points) Up to $3,000,000 $3,000,001-$5,000,000 0.85% (85 basis points) $5,000,001-$10,000,000 0.80% (80 basis points) $10,000,001-$20,000,000 0.70% (70 basis points) $20,000,001+ 0.50% (50 basis points) ITEM 5 FEES AND COMPENSATION A. Our Fees. We are a “fee-only” investment advisor and neither our firm, nor any of our associated persons, accept commissions or any other form of remuneration for the sale of any securities or insurance products to clients. We act as your fiduciary and will only recommend investments to you when we believe them to be in your best interests. The fees we charge for our services are set forth in a written advisory agreement entered with the client at the inception of our relationship. We may negotiate fees with clients in certain circumstances. Our fees may be amended prospectively from time to time upon thirty (30) days’ prior written notice to the client. Fees for Combined Financial Planning and Investment Management Services: As reflected above in Item 4, clients typically receive financial planning services in conjunction with our rendering of ongoing investment management services. In these circumstances, we will charge you an annual asset- based fee calculated as percentage of the market value of your account. Fees for these services are typically billed quarterly in advance and are paid to Human Investing via direct fee deduction from the client’s account at the qualified custodian. Unless otherwise agreed, we will rely on the market value of your account as determined by the custodian of your assets in calculating our advisory fees. Fees for the initial period of services are based on the market value of the client’s assets as of the date of the deposit. Thereafter, such fees will be calculated based upon FORM ADV PART 2 • 6 human investing® the market value of your assets as of the end of the prior quarter. We will pro-rate our asset-based fees for any partial billing periods (based on the number of days services were provided) and for mid-period additions and withdrawals of capital to or from your account (based on the transaction date). a combination of assets under management for the client and the expected complexity of the Tax Services. In the event we go over the expected hours to complete a tax return, we will alert that we will start billing an hourly rate for additional work. We will typically charge you hourly fees at a rate of $300 per hour. All fees will be set forth in a written agreement executed by the client and Human Investing prior to our performance of any Tax Services. All fees are due upon presentation of our invoices and are payable to us via check or other mutually agreed upon payment method. In some instances, and only with your prior written consent, Human Investing may charge you hourly fees of up to $300 per hour for certain projects, as authorized in the Investment Advisor Agreement (“IAA”). These fees will be invoiced to you and paid by check, wire transfer or ACH, or debited directly from your nonqualified account at the qualified custodian of your assets with 30 days prior written notice or your approval. Hourly fees, if any, are separate and distinct from the asset based charges described above. For those utilizing VPI’s services, VPI’s fee schedule is in accordance with the following. Fees are billed quarterly in arrears, based on the last day of the quarter as valued by the custodian. Additional rates may apply for utilizing specific indices. Fees for Workplace Advisory Services: When you engage us for these services, the fee structure will depend on the size and complexity of the plan and the level of services required to properly serve the plan and will typically be paid via direct fee deduction from the client’s account at the qualified custodian. Plan sponsors have the choice of how to absorb or delegate the fee payment. Asset-based fees are billed in advance, using the quarter end balance based on the recordkeeper for the plan. All fees are negotiable. We have three typical approaches to structuring our workplace advisory fees, which can be combined. FIRM LEVEL RATES • Flat Fees: Our flat fees range from $10,000 to ANNUAL ASSET-BASED FEE AGGREGATE ASSETS UNDER MANAGED FOR HUMAN INVESTING BY VANGUARD PERSONALIZED INDEXING (“VPI”) $20,000 a year. We may also charge flat fees for ad-hoc or one-time projects, depending on the scale of the project. Up to $50,000,000 0.20% (20 basis points) • Flat Asset-Based Fees: A flat asset-based fee $50,000,001-$100,000,000 0.18% (18 basis points) calculated as a percentage of the market value of your (or plan sponsor’s) total 401(k) plan assets, ranging from 0.07% to 0.55%. $100,000,001-$500,000,000 0.15% (15 basis points) $500,000,001+ Custom • Tiered Fees: A tiered asset-based fee calculated as a percentage of the market value of your (or the plan sponsor’s) total 401(k) assets, charged in accordance with the following fee schedule: INDIVIDUAL ACCOUNT RATES ANNUAL ASSET-BASED FEE ANNUAL ASSET-BASED FEE VALUE OF PLAN ASSETS MANAGED BY HUMAN INVESTING INDIVIDUAL ACCOUNT ASSETS UNDER MANAGEMENT Up to $125,000,000 0.075% (7.5 basis points) $10,000,000 to $50,000,000 0.15% (15 basis points) $125,000,000 to $200,000,000 0.05% (5 basis points) $50,000,001 to $100,000,000 0.13% (13 basis points) $200,000,001+ 0.025% (2.5 basis points) $100,000,001+ Custom There are no fees for early termination of the agreement. If the agreement is terminated during a Fees for Tax Services: When you engage us for Tax Services, fees will be determined based on FORM ADV PART 2 • 7 human investing® partial fee period, any unearned fees will be returned on a prorated basis. services, you should review the prospectus of each mutual fund, ETF, sub-advisor, and/or other pooled investment vehicle in which you participate and the account opening documentation of your custodian. B. Direct Fee Deduction. Where authorized by the client in writing, we will directly deduct our advisory fees from your account at the qualified custodian. Your written authorization for direct fee deduction will be contained in our written advisory agreement and/or the account opening documentation of your custodian. Payment of our fees may result in the liquidation of the client’s securities if there is insufficient cash in the account. D. Terminating Our Services. In the event we fail to provide you with a copy of this brochure at least forty-eight (48) hours in advance of your execution of a written investment advisory agreement with our firm, you may terminate our services without penalty within five (5) business days of entering into the investment advisory agreement. Thereafter, either party may terminate an advisory relationship on fifteen (15) days’ written notice. For asset-based fee engagements, clients will pay Human Investing a pro- rated fee based on the number of days services were provided through the date of termination. Human Investing will rebate clients on a pro-rata basis for any unearned fees that were billed in advance as of the date of termination. For hourly fee engagements, clients will pay Human Investing for all earned but unpaid hourly fees through the date of termination. All such fees are due immediately upon termination. Your custodian will independently send you an account statement, typically monthly, but no less than quarterly, identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any fees paid to us. Your custodian is not responsible for verifying the accuracy of our fee calculations. Therefore, we encourage you to review the custodian’s account statements carefully upon receipt. If you believe our fees have been miscalculated or if there is any other issue with your account, you should contact us immediately at the phone number listed on the cover page of this brochure. E. Sale of Securities and/or Insurance Products. Neither the firm, nor any of its associated persons, accept any commissions for the sale of any securities or insurance products. We act as a fiduciary and will only recommend investments to you when we believe them to be in your best interests. Fees for stand-alone financial planning and Tax Services are billed via traditional invoicing as described above. C. Additional Fees and Expenses. Separate and in addition to the advisory fees payable to Human Investing, you shall be solely responsible to bear the costs of all internal management fees, advisory fees, and other costs and expenses that may be charged by mutual funds, exchange traded funds (“ETFs”), sub-advisor, and other pooled investment vehicles to their shareholders. You will also pay all usual and customary transaction-based fees (brokerage fees and commissions), custodial charges, wire transfer fees, and other fees and taxes associated with activity and holdings in your accounts as set forth in the account opening documentation of your custodian. We do not share in any portion of the foregoing additional fees and expenses. To fully understand the total costs you will incur when engaging our Rollover Recommendations. As part of our investment advisory services to you, we may recommend that you roll assets from your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I of the ERISA and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. FORM ADV PART 2 • 8 human investing® the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide you with a written explanation of the advantages and disadvantages of both account types and the basis for our belief that the rollover transaction we recommend is in your best interests. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset- based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e., receipt of additional fee-based compensation). You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in your best interests and not put our interests ahead of yours. Under this special rule’s provisions, we must: ITEM 6 PERFORMANCE-BASED FEES AND SIDE- BY-SIDE MANAGEMENT We do not charge any performance-based fees for our services or engage in the side-by-side management of accounts. Accordingly, this item is not applicable to our firm. • meet a professional standard of care when making investment recommendations (give prudent advice); • never put our financial interests ahead of yours when making recommendations (give loyal advice); • avoid misleading statements about conflicts of interest, fees, and investments; ITEM 7 TYPES OF CLIENTS We provide investment advice to the following types of clients: • follow policies and procedures designed to ensure that we give advice that is in your best interests; • charge no more than a reasonable fee for our services; and • give you basic information about conflicts of interest. • Individuals, including high-net worth individuals; • Banks and credit unions; • Pension and profit sharing plans; • Trusts, estates, and charitable organizations; and • Corporations and other business entities. Because each client is unique, we encourage involvement in the planning and processes involved in the management of their accounts. Such involvement does not have to be time consuming, however it is our goal that clients remain informed and have a sense of security about their investments. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in your employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from As a firm, we value having a diverse client base and ensuring that professional financial advice remains reasonably accessible to clients from all walks of life. For this reason, with the exception of our minimum annual fee of $6,250 for combined financial planning and investment management services (described in Item 5), we do not impose any minimum annual fee requirements or account FORM ADV PART 2 • 9 human investing® we rely upon when researching and analyzing securities using fundamental analysis include research materials prepared by others, annual reports, corporate rating services, prospectuses, and company press releases. size requirements to open or maintain an advisory relationship with our firm. Clients wishing to obtain our combined financial planning and ongoing investment management services while avoiding the foregoing minimum annual fee requirement should consider engaging Human Investing under our Access Program. We maintain a separate informational brochure that describes the nature of our Access Program services and fees. Please inquire with us at the telephone number reflected on the cover page of this brochure if you would like to receive a free copy of our Access Program brochure. Asset Allocation: Rather than focusing on selecting the particular securities or other assets to invest for your account, we attempt to identify an appropriate ratio of various types of investments (for example, stocks, fixed income, and cash) suitable to your investment goals, time horizon, and risk tolerance. A risk of asset allocation is that you may not participate in sharp increases in a particular security, industry, or market sector. 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 to meet with your investment goals. ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. Methods of Analysis and Investment Strategies. We construct portfolios based upon the client’s financial plan, IPS (if applicable), and/or risk tolerance. Client portfolios are typically constructed using a diversified mix of some or all of the following instruments: mutual funds, ETFs, individual stocks and bonds, cash, and cash equivalents. We may use some or all of the following methods of analysis in providing investment advice to you: Mutual Fund and ETF Selection and Analysis: We evaluate and select mutual funds and ETFs based on several factors which may include, without limitation, (1) the experience and track record of the underlying portfolio manager(s), (2) the performance of the fund over time and through various market conditions; (3) expected market conditions that might impact the underlying holdings of the fund or applicable market sector; and (4) whether and to what extent the underlying holdings of the fund overlap with other assets held in your account. We also monitor the fund in an attempt to determine if it is continuing to follow its stated investment strategy. Fundamental Analysis: In using fundamental analysis, we attempt to determine the intrinsic value of target securities through a review of, among other things, company specific financial disclosures, the strength and track record of management personnel, industry sector financial health, and at a macro level, the overall direction of the economy at large. We use this information as a basis to determine if such securities are underpriced or overpriced relative to current market prices and then to make a buy or sell recommendation to you. Relying on this type of analysis leaves open the risk that the price of a security may move along with the overall direction of the market, irrespective of the economic and financial factors which may have indicated that an opposite movement would have been expected. The main sources of information A risk of this form of analysis is that, as in all securities investments, past performance does not guarantee future results. A fund manager’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of the fund are determined by independent fund managers and may change overtime without advance warning, creating the potential for overlap with other investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund, which could make the holding(s) less suitable for the FORM ADV PART 2 • 10 human investing® client’s portfolio. We typically use the following investment strategies in managing client accounts: the investment of their account and understand that investment decisions made for their account are subject to market, currency, economic, political and business risks. It is the responsibility of each client to provide us with complete and accurate information and to notify us in a timely manner of any changes in the client’s financial circumstances or goals. Long-term Purchases: We may recommend a long term “buy and hold” approach to investing client assets. In this type of investment strategy, we suggest the purchase of securities with the idea of holding them in a portfolio for a year or longer. Typically, we employ this strategy when (1) we believe the securities to be currently undervalued, and/or (2) we want the portfolio to have 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, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the recommendation to sell. C. Summary of Investment Risks. While all investing involves risks and losses can and will occur, we generally recommend a broad and diversified allocation of securities and other investments intended to reduce the specific risks associated with a concentrated or undiversified portfolio. Nonetheless, you should consider the following high-level summary of investment risks. This list is not intended to be an exhaustive description of all risks you may encounter in engaging our firm for advisory services. We encourage you to inquire with us frequently about the risks related to any investments in your account. Short-term purchases: When utilizing this strategy, we may suggest the purchase of securities with the idea of selling them within one year of purchase. We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we recommend for purchase. Risk of Loss: Securities investments are not guaranteed, and you may lose money on your investments. As with any investment manager that invests in common stocks and other equity securities, our investment recommendations are subject to market risk—the possibility that securities prices will decline over short or extended periods of time. As a result, the value of your account(s) will fluctuate with the market, and you could lose money over short or long periods of time. You should recognize whenever you determine to invest in the securities markets your entire investment is at risk. Clients should not invest money if they are unable to bear the risk of total loss of their investments. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are 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 will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short- term capital gains. B. We will use our best judgment and good faith efforts in rendering services to each client. We cannot guarantee any level of investment performance or that any investment will be profitable over time. Not every investment decision or recommendation made by us will be profitable. Investing in securities involves risk of loss that clients should be prepared to bear. Clients assume all market risk involved in Economic Risk:The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country FORM ADV PART 2 • 11 human investing®  that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the “dot com” companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Cybersecurity Risk: We rely on the use of various electronic technologies to conduct our investment advisory business and are therefore susceptible to operational, information security, and related risks, including risks of unintentional cyber incidents and deliberate cyber-attacks. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of corrupting data, or causing operational disruption, as well as denial- of-service attacks on websites. Cyber incidents may cause disruptions and impact on our business operations, potentially resulting in financial losses, interference with a client’s ability to value their investments, impediments to trading, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. While the firm and its most significant counterparties and vendors have established business continuity plans and risk management systems to help mitigate cyber incidents, there are inherent limitations in such plans and systems that are inherently outside of our control. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g., earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and macroeconomic factors may negatively impact investment returns. Risks Related to Analysis Methods: Our analysis of securities relies in part on the assumption that the issuers whose securities we recommend for purchase and sale, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Securities Transactions at the Direction of Clients: All assets are held at an independent qualified custodian in your name. You will typically maintain the concurrent ability to self-direct transactions within your account. We are not responsible for the consequences, costs, and fees generated by your self-directed investment transactions or transactions you instruct us to implement on your behalf where we have advised you that such transactions are not in your best interests. FORM ADV PART 2 • 12 human investing® Rivermark Community Credit Union (“Rivermark CU”) is compensated for its referral of Rivermark CU members to Human Investing for investment advisory services under our separate Access Program. Human Investing may enter into similar referral arrangements with additional credit unions, banks, other financial institutions and third parties in the future. To the extent we should do so, Human Investing will disclose to all referred clients in writing the nature of the referral arrangement and any related conflicts of interest. Please see our separate Access Program brochure for a description of these arrangements. Interim Changes in Client Risk Tolerance and Financial Outlook: The particular investments recommended by our firm are based solely upon the investment objectives and financial circumstances disclosed to us by the client. While we strive to meet with clients at regular intervals (at least annually, unless otherwise agreed, either in person, telephonically, or by electronic means) to discuss any changes in the client’s financial circumstances, the lack of constant and continuous communication presents a risk insofar as your liquidity, net worth, risk tolerance and/or investment goals could change abruptly, with no advance notice to our firm, resulting in a mis-aligned investment portfolio and the potential for losses or other negative financial consequences. ITEM 9 DISCIPLINARY INFORMATION We are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm or the integrity of our management. We have no information to disclose applicable to this item. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Our Code of Ethics. Human Investing has adopted a Code of Ethics which all employees are required to follow. The Code of Ethics outlines proper conduct related to all services provided to our clients. Prompt reporting of internal violations is mandatory. Our Chief Compliance Officer periodically evaluates employee performance to ensure compliance with the Code of Ethics. A copy of the Code of Ethics is available to any client upon request. ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Human Investing and its associated persons are not registered and do not have any application(s) pending to register as a broker-dealer or as a registered representative of any broker-dealer. B-D. Material/Proprietary Interests in Securities Recommended to Clients. Our firm and our associated persons do not have any proprietary or material interests in or any role in the management of any companies or investments that we recommend to our clients. B. Human Investing and its associated persons are not registered and do not have any application(s) pending to register as a future commissions merchant, commodity pool operator, commodity trading advisor, or as a representative of any of the foregoing. C. Human Investing and its associated persons do not receive any commissions or any other forms of compensation in connection with the sale of any securities or insurance products. Personal Trading; Participation or Interest in Client Transactions. Human Investing and/or its associated persons may manage accounts which belong either to themselves, individually, or to their family or their affiliates (collectively, “Proprietary Accounts”) while simultaneously managing client accounts. Proprietary Accounts may buy and sell some the same securities as we buy or sell for client accounts. This practice creates an actual conflict of interest with our clients insofar as our firm and/ or our associated persons may have a financial FORM ADV PART 2 • 13 human investing® recommended by our firm. incentive to trade in securities for Proprietary Accounts in advance of or opposite to transactions in the same securities for client accounts. To address this conflict, our general policy is to aggregate any trades for proprietary accounts along with trades for our clients’ accounts. Alternatively, we may process trades in proprietary accounts after completing all trades in those securities in client accounts. In some cases, we may buy or sell securities for our own accounts for reasons not related to the strategies deployed on behalf of our clients. In summary, our practice of buying and selling for Proprietary Accounts the same securities that we buy or sell for client accounts is restricted by the following controls: In recommending broker-dealers to clients, we have an obligation to seek the “best execution” of transactions for client accounts. This duty requires us to seek to execute securities transactions for clients such that the total costs or proceeds in each transaction are the most favorable under the circumstances. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the recommended broker-dealer’s services. Some of the factors we may consider when evaluating a broker-dealer for best execution include, without limitation, the broker- dealer’s: • We are always required to uphold our fiduciary duty to our clients; • transaction costs; • facilities, reliability, and financial responsibility; • ability to effect transactions, particularly with • We are prohibited from misusing information about our clients’ securities holdings or transactions to gain any undue advantage for ourselves or others; regard to such aspects as timing, order size, and the speed of order execution; • research and related brokerage services provided; and • any other factors the firm considers to be relevant. • We are prohibited from buying or selling any security that we are currently recommending for client accounts, unless we participate in an aggregated trade with clients or place our orders after client orders have been executed; and • We are required to periodically report our securities holdings and transactions to the firm’s Chief Compliance Officer, who must review those reports for improper trades. We will disclose to clients material conflicts which could reasonably be expected to impair the rendering of unbiased and objective advice. ITEM 12 BROKERAGE PRACTICES A. Recommendation of Broker-Dealers; Best Execution; Directed Brokerage; Soft Dollar Practices. Except to the extent that the client directs otherwise, Human Investing may use its discretion in recommending a broker-dealer for the custody of client funds and securities and the execution of transactions. However, no client is ever obligated to effect transactions through the broker-dealer(s) If the client selects a broker-dealer other than those we recommend for execution of transactions (i.e., client directed brokerage), you are advised that we may be unable to seek best execution of your transactions and your commission costs may be higher than those of our recommended broker- dealer. For example, in a directed brokerage account, you may pay higher brokerage commissions and/ or receive less favorable prices on the underlying securities purchased or sold for your account because we may not be able to aggregate your order with the orders of other clients. In addition, where you direct brokerage, we will typically place orders for your transactions after we place transactions for clients using our recommended broker-dealer. We reserve the right to reject your request to use a particular broker-dealer or custodian if such selection would frustrate our management of your account, or for any other reason. “Soft dollar” arrangements refer to the practice of directing a certain volume of securities transactions FORM ADV PART 2 • 14 human investing® (at a minimum) to discuss potential changes to their financial plan. During this meeting, we may request that clients complete a risk tolerance questionnaire. (and their resulting trading commissions) to a particular broker-dealer in exchange for the receipt of certain ancillary benefits (such as proprietary investment research) by an investment advisor. Human Investing does not maintain any soft dollar arrangements with any broker-dealers and does not intend to enter any such arrangements in the future. B. More Frequent Reviews. More frequent reviews may be triggered by a change in a client’s investment objectives, tax considerations, large deposits or withdrawals, large sales or purchases, loss in confidence of corporate management and objectives, and/or changes in the macro-economic climate. C. Reporting. Clients will receive account statements directly from the custodian of their account(s) generally monthly, but no less than quarterly, in paper and/or electronic formats. Portfolio performance and allocation reviews are performed on a quarterly basis for all accounts that desire this level of reporting. This report typically highlights fees, investment returns, portfolio performance, and asset allocation and can be customized on an account by account basis. B. Trade Aggregation. Human Investing is authorized in its discretion to aggregate purchases, sales, and other transactions made for client accounts with the purchases, sales, and other transactions in the same or similar securities/ instruments for the accounts of other clients of Human Investing. When transactions are aggregated, the actual prices applicable to the aggregated transactions will be averaged, and your account will be deemed to have purchased or sold its proportionate share of the securities/instruments involved at the average price so obtained. In conformity with applicable law Human Investing will direct their custodians to send confirmations of all transaction effected in client accounts to the client’s address of record. ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION Rivermark CU is compensated for its referral of Rivermark CU members to Human Investing for investment advisory services under the Access Program. Please see our separate Access Program brochure for a description of these arrangements. ITEM 13 REVIEW OF ACCOUNTS A. Account Reviews. Client accounts are typically reviewed periodically by the investment advisor representative who is primarily responsible for managing the client’s assets. However, individuals conducting reviews may vary from time to time, as personnel join or leave our firm. The frequency of reviews is determined based on each client’s investment objectives and investment profile. Clients are advised that Human Investing pays bonus compensation to its investment advisor representatives based on the referral and/or servicing of new client accounts. This arrangement creates a conflict of interest since our investment advisor representatives have a financial incentive to refer new clients to the firm and to encourage the deposit and/or maintenance of funds and securities in accounts managed by Human Investing. The firm and its investment advisor representatives are fiduciaries and will only provide advice to you that we believe to be in your best interests. Human Investing engages one or more promoters who refer prospective clients. Such promoters are Accounts to which we provide ongoing investment management services are subject to routine reviews at least monthly for rebalancing opportunities due to deviations from the target model. The investment models selected for client accounts are derived from a client’s financial plan, IPS (if applicable), behavior, and risk tolerance. In addition, Human Investing typically performs an overall assessment of each client account at least annually. Human Investing encourages clients to review their financial plan and to meet with their advisor annually FORM ADV PART 2 • 15 human investing®  no-action letter to the Investment Adviser Association dated February 21, 2017. compensated indirectly through their ownership interest in the firm and therefore benefit financially from advisory fees paid by referred clients. This arrangement creates a conflict of interest because the promoter has an incentive to recommend Human Investing. Clients are under no obligation to engage our firm as a result of such referrals. As of the date of this brochure, we have no other arrangements, written or oral, in which we compensate others or are compensated by others for client referrals. Additionally, excepting clients who engage us under the Access Program, at our discretion, certain clients may engage our firm to perform bill pay services and to perform other discretionary services based on power of attorney, granting our firm the discretion to disburse client funds and/or securities without first obtaining client approval. We are deemed to have actual custody over all such client assets. Accordingly, we have entered into a written agreement with an independent certified public accountant to verify by actual examination all such accounts at least once during each calendar year at a time that is chosen by the accountant without prior notice or announcement to us, and that is irregular from year to year (“surprise examination”). As part of this arrangement, the independent accountant must file a Form ADV-E with the SEC along with a copy of the audit or surprise examination report within 120 days of the audit or surprise examination’s conclusion. ITEM 15 CUSTODY All client funds and securities on which we advise are held in accounts titled in the client’s name maintained by an independent qualified custodian. For clients receiving ongoing investment management services, the custodian will be authorized to execute trades within the client’s account upon our instructions, acting within the scope of the authority granted in our written advisory agreement with the client and the custodian’s account opening documentation. Where we directly debit our advisory fees from your account held at the custodian, the custodian will independently send you an account statement at least quarterly identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any fees paid to us. Your custodian is not responsible for verifying the accuracy of our fee calculations. Therefore, we encourage you to review the custodian’s account statements carefully upon receipt. If you believe our fees have been miscalculated or if you have any other questions related to your account, you should contact us immediately at the phone number listed on the cover page of this brochure. ITEM 16 INVESTMENT DISCRETION Except as otherwise agreed, clients grant us ongoing and continuous discretionary authority to execute investment recommendations within their designated investment accounts without obtaining the client’s prior approval for each specific transaction. Under this discretionary authority, clients allow us to purchase and sell securities and instruments in their account(s), arrange for delivery and payment in connection with the foregoing, and otherwise act on their behalf in most matters necessary or incidental to the handling of the account, which includes monitoring of certain assets. Clients grant the foregoing authority to Human Investing in our written investment advisory agreement and/or the account opening documentation of their custodian. Certain clients may execute standing letters of authorization (“SLOAs”) granting Human Investing the ability to disburse certain funds on behalf of the client. Where a client has executed a SLOA, Human Investing follows the guidance set forth in the SEC’s As noted in Item 4 above, we serve retirement plan sponsors acting as 3(21) or 3(38) written fiduciaries with respect to the investment management and selection of funds and investment options made available within 401(k) plans. As a 3(21) fiduciary, FORM ADV PART 2 • 16 human investing® involving investments held in or formerly held in a client’s account. We have the right to change the provider of this service at any time in our sole discretion. If we do so, we will notify you and send you another opt-out election form. we do this on a non-discretionary basis. As a 3(38) fiduciary, we do this on a discretionary basis. While we may have discretionary authority to determine the fund platform available to a client’s retirement plan and/or the investment options made available within the plan, if such plans are “participant directed,” then we do not have discretion to select the particular investments to be held in individual participant accounts. Non-discretionary authority requires us to obtain a client’s prior approval of each specific transaction prior to executing investment recommendations, as well as for the selection and retention of sub-advisors to the account. Because we are providing this service through BFS, we no longer monitor class action suits or process claim forms on your behalf (whether or not you participate in the service BFS provides). We are not responsible or liable for: (a) any assistance we provide to BFS concerning monitoring or processing class action claims or (b) any act or omission by BFS in monitoring or processing such claims. ITEM 18 FINANCIAL INFORMATION A. Human Investing does not require prepayment of more than $1,200 in fees six or more months in advance, therefore, we have nothing to disclose that is applicable to this item. ITEM 17 VOTING CLIENT SECURITIES While we may receive informational copies of proxy statements and annual reports, unless specifically directed otherwise in writing by the client, Human Investing is not authorized to receive and vote proxies on issues held in the account or receive annual reports. B. As mentioned in Item 16 above, we have discretionary authority over some client funds. As we have no financial commitments which would impair our ability to meet the contractual and fiduciary commitments to our clients, we have nothing to disclose that is applicable to this item. C. Human Investing has never been the subject of any bankruptcy proceedings. Human Investing has engaged an independent third-party service provider, Broadridge Financial Solutions, Inc. (“BFS”), to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of our firm’s investment management services clients. Human Investing does not receive any fees or remuneration in connection with this service, nor does it receive any fees from the third-party provider(s). BFS earns a fee based on a flat percentage (typically 20%) of all claims it collects on behalf of Human Investing’s clients. This fee is collected and retained by BFS out of the claims paid by the claim administrator. Clients are advised that it may be necessary to share client information, such as your name and account number, with BFS in connection with this service. All clients who engage Human Investing for investment management services are automatically enrolled in this service unless they elect to opt-out. You may opt-out of this service at any time by notifying us in writing. If a client opts out, Human Investing does not have an obligation to advise or take any action on behalf of a client with regard to class action litigation FORM ADV PART 2 • 17 human investing® human investing ® INDEPENDENT SINCE 200 4