Ima Advisory Services, Inc.

IMA PRIVATE WEALTH BROCHURE IMA ADVISORY SERVICES, INC. DBA IMA PRIVATE WEALTH March 31, 2026 Corporate Address: 1705 17th Street, Suite 100, Denver, Colorado 80202 Mailing address: 430 E. Douglas Ave., Suite 400, Wichita, Kansas 67202 316.266.6574 | www.IMAPrivatewealth.com This Brochure provides information about the qualifications and business practices of IMA Advisory Services, Inc. (“IMAAS”) doing business as IMA Private Wealth. If you have any questions about the content of this brochure, contact us at 316.266.6574. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about IMA Advisory Services is also available on the SEC’s website at www.adviserinfo.sec.gov. IMA Advisory Services, Inc. is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. IMACORP.COM  ITEM 2 SUMMARY OF MATERIAL CHANGES Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last update on May 1, 2025, we have updated information regarding the referral arrangements and our use of Private Fund investment options. 1  ITEM 3 TABLE OF CONTENTS ITEM 2 SUMMARY OF MATERIAL CHANGES .................................................................................................... 1 ITEM 3 TABLE OF CONTENTS ................................................................................................................................. 2 ITEM 4 ADVISORY BUSINESS .................................................................................................................................. 3 ITEM 5 FEES AND COMPENSATION ..................................................................................................................... 7 ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .......................................... 11 ITEM 7 TYPES OF CLIENTS ..................................................................................................................................... 11 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........................... 12 ITEM 9 DISCIPLINARY INFORMATION .............................................................................................................. 16 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................. 16 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................................................................................................................... 18 ITEM 12 BROKERAGE PRACTICES ........................................................................................................................ 19 ITEM 13 REVIEW OF ACCOUNTS ......................................................................................................................... 24 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION .................................................................... 25 ITEM 15 CUSTODY .................................................................................................................................................... 26 ITEM 16 INVESTMENT DISCRETION ................................................................................................................... 27 ITEM 17 VOTING CLIENT SECURITIES ................................................................................................................ 27 ITEM 18 FINANCIAL INFORMATION .................................................................................................................. 28 2  ITEM 4 ADVISORY BUSINESS Description of Firm IMA Advisory Services, Inc. ("IMA Advisory Services", “IMA Private Wealth”, "we", or "us") is a registered investment adviser headquartered in Denver, Colorado, with offices throughout the United States. We are organized as a corporation under the laws of the State of Kansas and have been providing investment advisory services since 1999. As of October 2023, we are wholly owned by IMA Advisors, a wholly owned subsidiary of IMA Financial Group, Inc. This disclosure brochure describes our wealth management services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to an individual's specific needs. Services Described in this Brochure IMA Advisory Services has three brochures describing our services. This brochure focuses on our wealth management and financial planning services. Advisory services provided to employers on qualified and non-qualified retirement plans, or services provided to endowments, foundations and non-profit organizations are described in separate brochures. If you are interested in receiving the brochure that describes our other services, please contact our office at 316.266.6574. Advisory Services IMA Private Wealth offers the following services as an investment adviser: wealth management services (asset management),financial planning, and use of unaffiliated third-party money managers through Envestnet’s Unified Managed Account (UMA) program. We provide access to a broad range of clients including individuals, high net worth individuals, trusts, estates, pension and profit-sharing plans, charitable organizations and corporations. Asset Management We make investments decisions or provide advice to clients based on their individual needs. We typically provide these services on a discretionary basis, meaning we will determine the specific securities, and the amount of securities, to be purchased or sold for your account without prior approval for each transaction. We also accept non-discretionary accounts. All recommendations and trades are made in accordance with each client's investment objectives and goals. We allow clients to place reasonable restrictions on their discretionary accounts (see Item 16). Clients may also seek our advice on a client’s investment in a private fund (“Private Funds”) sponsored and managed by unaffiliated managers (the “Fund Sponsors”). Financial Planning Services As an integrated part of our investment management services, we offer financial planning primarily using MoneyGuide Pro© and other related software. We offer the following financial planning services depending on the client’s situation: cash flow analysis, budgeting, retirement needs, asset allocation consulting, education funding, tax efficiency, charitable giving, estate considerations, wealth transfer, and other goals or special needs. With respect to our limited financial planning services, clients are free 3  Item 4 Advisory Business (continued) to accept or reject any of our recommendations, and clients alone have the authority to implement any of our recommendations. With respect to estate and tax planning, our role is limited to consulting and facilitating with clients and their other professional advisors. We do not offer legal or tax advice. When the financial planning engagement is independent of an investment management relationship, the engagement begins with defining the scope of the engagement and services to be included and confirmed in an agreement. Advice and planning provided during a financial planning only engagement are not implemented by IMA Private Wealth as part of the engagement. Limitations of Financial Planning and Non-Investment Consulting or Referral Services: To the extent requested by the client, IMA Private Wealth will generally provide limited financial planning and related consulting services regarding non-investment-related matters, such as tax and estate planning, insurance, etc. IMA Private Wealth does not serve as an attorney, accountant, or insurance agent, and you should not construe any part of our services as such. Accordingly, IMA Private Wealth does not prepare legal documents, or prepare tax returns. Upon request, we can refer a client to other professionals such as attorneys, accountants, or insurance agents, including to affiliated agencies. The client retains absolute discretion to make any engagement decisions and has no obligation to engage any professional to whom we make a referral. The client is free to accept or reject any recommendation from IMA Private Wealth or its representatives. If the client engages any professional (i.e., attorney, accountant, insurance agent, etc.), whether or not referred by IMA Private Wealth, and a dispute later arises related to that engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not IMA Private Wealth, is responsible for the quality and competency of the services provided. UMA/SMA Program Through arrangements with third-party service providers, we have access to third-party investment models, third-party investment managers, mutual funds, exchange traded funds, portfolio maintenance tools and portfolio trade order processing services as needed to achieve your financial and investment objectives. As part of these discretionary management services, we will assist you in selecting a third-party investment program and the selection of third-party manager(s) in which to invest after gathering information about your financial situation and objectives. We will remain responsible for the continuous monitoring and ongoing management of your investment account based on the most recent statement of investment objectives you have provided us in writing. We will grant the active discretionary management of all or part of your investment account to one or more independent investment managers and/or investment management programs ("Third-Party Managers") based on your stated investment objectives. Discretionary authorization will permit the Third-Party Managers to buy, sell, exchange, convert or otherwise trade in any securities and to further delegate such discretionary authority to other Third-Party Managers. 4  Item 4 Advisory Business (continued) You will have the opportunity to place reasonable restrictions on the management of your account(s), or modify existing restrictions. You must provide these restrictions and/or modifications to us in writing. Review & Monitoring of Third-Party Managers and Private Funds Prior to making any recommendations with respect to a Third-Party or Private Fund, the individual advisor will collect (or update, if already collected) the suitability information. Your Portfolio Managers will monitor the Third-Party accounts, and any reports from the Third-Party Manager or Fund Sponsor and performance to ensure its management and investment style remains aligned with your investment goals and objectives. At least annually, your Portfolio Managers will review performance of the portfolio against targets, and assess Third-Party’s or Fund Sponsor’s overall management, and whether to recommend reallocation of your assets. Types of Investments For portfolios for which we serve as portfolio manager, assets may be invested in mutual funds; money market funds; exchange-traded funds ("ETFs"); common and preferred stocks; REITs; security options; real estate partnerships; corporate debts; municipal securities; and if appropriate, "sweep" arrangements where cash balances are transferred into money market funds; money market deposit accounts, or bank accounts for cash management purposes, which may be advised by or maintained with the account's qualified custodian. Our investment strategy and any liquidity needs and investment restrictions imposed by the client will affect the specific types of investments we purchase or recommend for the client’s account. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client’s specific financial situation, the investment advice we provide to you may be different or conflict with the advice we give to other clients regarding the same security or investment. Retirement Rollovers and Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan and may choose a combination of these options: (I) leave the money in the former employer’s plan, if permitted, (ii) roll the assets into a new employer’s plan, if one is available and rollovers are permitted, (iii) roll the assets into an Individual Retirement Account (IRA), or (iv) cash out the account value (which could result in adverse tax consequences). If IMA Private Wealth recommends that a client roll over retirement plan assets into an account to be managed by IMA Private Wealth, that recommendation creates a conflict of interest when IMA Private Wealth will earn new or increased compensation from the rollover. When acting in such capacity, IMA Private Wealth serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by IMA Private Wealth. IMA Private Wealth’s Chief Compliance Officer is available to address any questions that a client or prospective client has about the potential for conflict of interest presented by such rollover recommendations. 5  Item 4 Advisory Business (continued) Investment Risk: Different types of investments involve different degrees of risk. Clients should not assume that future performance of any specific investment or investment strategy (including the investments and investment strategies recommended or undertaken by IMA Private Wealth) will be profitable or achieve any specific performance level. Portfolio Activity: IMA Private Wealth has a fiduciary duty to provide services consistent with the client’s best interest. IMA Private Wealth will review client portfolios on an ongoing basis to determine whether any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions or withdrawals, or a change in the client’s investment objective. Based upon these factors, there can be extended periods of time when IMA Private Wealth determines that changes to a client’s portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations: In performing our services, IMA Private Wealth shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is responsible for promptly notifying IMA Private Wealth of changes in the client’s financial situation or investment objectives so that we can review, evaluate, and potentially revise our recommendations or services. Cash Positions: IMA Private Wealth continues to treat cash as an asset class. As such, all cash positions (money markets, etc.) are included as assets under management for purposes of calculating IMA Private Wealth’s advisory fee, unless specifically agreed otherwise by IMA Private Wealth. At any specific point in time, depending upon perceived or anticipated market conditions or events, IMA Private Wealth may keep cash positions for defensive purposes. While assets are kept in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, IMA Private Wealth’s advisory fee could exceed the interest paid by the client’s money market fund. IMA Private Wealth’s Chief Compliance Officer remains available to address any questions that a client or prospective client has about the above fee billing practice. Unaffiliated Private Investment Funds: IMA Private Wealth also provides investment advice regarding private investment funds. IMA Private Wealth recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts, and fees, including incentive compensation) is in the fund’s offering documents. If a client decides to invest in an unaffiliated private fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of IMA Private Wealth calculating its investment advisory fee. IMA Private Wealth’s fee shall be in addition to the fund’s fees. IMA Private Wealth’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including but not limited to potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client 6  Item 4 Advisory Business (continued) owns, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he or she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please also note, Valuation: If IMA Private Wealth displays private investment funds owned by the client on any supplemental account reports prepared by IMA Private Wealth, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if the fund has not provided an updated valuation after purchase, the valuation shall reflect the initial purchase price until the fund provides an updated valuation. Please also note: As a result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, IMA Private Wealth shall calculate its fee based upon the most recent value provided by the fund sponsor. Assets Under Management As of December 31, 2025, IMAAS maintains total regulatory assets under management of $3,901,795,952 of which $557,197,021 are non-discretionary. Assets Under Advisement (“AUA”) may appear in client and sales materials in addition to IMAAS’ regulatory Assets Under Management (“AUM”). AUA is presented when, due to the nature of the contractual agreements with certain clients, we provide consultative advice to our clients in a non- discretionary capacity and do not maintain discretionary authority over the clients’ portfolios(s). In such relationships, the clients maintain the ability and authority to manage and allocate assets within their own portfolio(s) independent of our advice. Therefore, these clients are not reflected within regulatory assets under management. Instead, these engagements are represented as part of our AUA. In the instance that AUA is listed in client or sales materials it will be accompanied by relevant disclosure indicating how AUA has been calculated. ITEM 5 FEES AND COMPENSATION Asset Management Services We typically charge an annual fee for wealth management services as a percentage of assets under management. We occasionally agree to enter into a fee arrangement other than one based upon a percentage of assets under management. his decision is based on the amount of assets under management and the nature of the services to be provided. 7  Item 5 Fees and Compensation (continued) Our advisory fees vary by service provided and will not exceed an annual fee of 1.25%. Advisory fees may be negotiable at the sole discretion of the Advisor. In addition, a separate administrative fee beginning at 0.05% is charged which covers the firm’s technology platforms used for billing, reporting, research, reports, models and other services, including accessing a wide field of money managers. Additional platform fees may be assessed by our platform provider for additional services selected by you. All fees will be disclosed in your Statement of Investment Selection. Each account shall be subject to a $10 minimum quarterly technology platform fee ($40 annually). To the extent that the overall quarterly fee assessed on each account is less than $10, the difference shall be assessed and charged to the client. This fee may be waived at the sole discretion of the Advisor. The way we bill for fees is established in our written agreement with you. We bill our fees in advance on a quarterly basis. You can either authorize us to deduct our fee from your account or you can direct us to bill you directly for our fees. Fee Dispersion: IMA Private Wealth, in its discretion, will sometimes reduce its investment advisory fee, charge a flat fee, waive its fee entirely, or charge fees on a different interval based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Certain clients may be subject to legacy fees or other arrangements. We retain the right to provide services to related persons of IMA Advisory Services and its affiliates at rates that are not made available to other clients. Please Note: As a result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. Fee adjustments: Our fees for managed accounts are prorated for each addition and withdrawal made during the applicable calendar quarter (apart from contributions and withdrawals of less than $25,000). Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians or broker-dealers, including but not limited to any transaction charges such as trading costs. Clients will also be responsible for any interest charges or other costs associated with margin loans or other secured loans. We have contracted with a service provider to provide securities class-action services to our clients with accounts at certain custodians. The service provider will conduct research and file claims on behalf of those clients in securities class actions in which they might be entitled to recovery. The service provider will keep 15% of any recovery as its fee for services. Clients can opt out of this service. If clients opt out, they will be solely responsible for filing claims in any class action in which they may be eligible for recovery. Mutual Fund and ETF Fees: Most mutual funds and exchange-traded funds are available directly to the public. Thus, a client could invest in a mutual fund directly, without engaging IMA Private Wealth. In 8  Item 5 Fees and Compensation (continued) that case, the client would not receive our investment advisory services. In addition to IMA Private Wealth’s investment management fee described above, and transaction and custodial fees discussed below in Item 15, clients will also incur, relative to all mutual fund and ETF purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Financial Planning Services Our fees for financial planning are stated in the engagement agreement and are subject to negotiation. Fees for Third Party Managers and Private Funds Third Party Managers and Private Funds are able to establish their own fee and refund policies, which may differ materially from IMA Private Wealth, and which we do not control or influence. The policies of the Third Party Managers and Fund Sponsors will control when such fees and refunds are paid. Third Party Managers Management fees charged by Third Party Manager for investment management and related services are in addition to the advisory fees payable to IMA Private Wealth. From time to time, we may recommend Third-Party Managers to manage all or a portion of client accounts on a discretionary basis. Each Third Party Manager will assess an additional advisory fee, which will be disclosed, in advance, in the client’s advisory agreement along with any corresponding platform fees. Additional information regarding the Third Party Manager’s advisory and/or platform fees will be disclosed in the current Form ADV Part 2A Brochure of the Third Party Manager. Private Funds A client who chooses to invest in a private investment vehicle through IMA Private Wealth will pay additional fees. Typically, in addition to IMA Private Wealth’s fee, the client will pay fees to the fund manager that include administration and management fees, incentive fees or carried interest, and an additional administration or management fee to the access fund provider. We will provide additional more specific disclosures and engage in additional discussions before investing any client funds in private investments. Brokerage and Investment Expenses Client accounts will generally contain individual stocks, ETFs, and money market funds. They may also contain mutual funds, bonds, and other types of securities. Although many of the mutual funds are "load-waived" investments, clients should expect that their account will incur some or all of the brokerage and investment expenses described below. Client accounts will pay their custodian transaction-related fees for each transaction, and for some transactions, will also pay other costs that could significantly increase your overall expenses and decrease any profits from these programs. Following are examples of some of the types of fees and expenses that are included in the brokerage and investment expenses: + per-trade principal trade mark-up/mark-downs, and other transaction-related costs paid to introducing and executing brokers (including its clearing firm, the Custodian and its affiliates), stock 9  Item 5 Fees and Compensation (continued) exchanges, electronic communications networks, and other trading intermediaries involved in executing account transactions to buy or sell securities; + odd lot charges, transfer and other taxes, floor brokerage fees, service, handling, delivery, and mailing fees, electronic wire transfer fees, currency exchange fees, margin interest, and other expenses related to investments made or assets held for the client's account; + dealer spread (mark-up/mark-down) incurred when securities are purchased on principal basis, rather than on an "agency basis" (where a commission would be charged); fixed income securities tend to be bought and sold more frequently on a principal basis, so accounts that invest more frequently in fixed income securities may incur the cost of the dealer mark-up/down for each purchase and sale; and + service, handling, delivery, and mailing fees, electronic wire transfer fees, and other miscellaneous expenses related to the client's account. Cash Management Fees and Expenses Cash in a client’s account that is awaiting investment or reinvestment may be invested in cash balance, money market fund, or deposit account at the custodian (or their affiliate), pursuant to an automatic cash "sweep" program. clients should refer to the Prospectus and Statements of Additional Information of the money market funds in which they invest for further information regarding such payments. Custodial Expenses We will not have possession of managed assets. Managed assets must be maintained in an account under client's name with a custodian designated for their account (the "Custodian"). The custodial account will be governed by a separate agreement (a "Custodial Agreement") between the client and each custodian, and the client will be solely responsible for negotiating the terms of such agreement. The custodial account will bear all fees and expenses of the Custodian and of transactions for such account, according to the Custodian Agreement, all of which will be separate from and in addition to the advisory fees payable to us under the Advisory Agreement. Clients must pay the cost of services provided by the Custodian for (1) arranging for the receipt and delivery of securities that are purchased, sold, borrowed or loaned for the custodial account; (2) making and receiving payments with respect to custodial account transactions and securities; (3) maintaining custody of custodial account securities; and (4) maintaining custody of cash, receiving dividends, and processing exchanges, distributions, and rights accruing to the custodial account. The specific fees and terms of each Custodian's services are described in the client's separate Custodial Agreement(s). Margin Account – Risks and Conflict of Interest: IMA Private Wealth does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities or for other non-investment borrowing purposes. The broker or custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. Should a client specifically request to use margin, IMA Private Wealth will consider the entire market value of the margined assets as managed; that is, IMA Private Wealth will not deduct the margin loan value from the managed asset value when computing its advisory fee. As a result, a conflict 10  Item 5 Fees and Compensation (continued) of interest arises since IMA Private Wealth may have an economic disincentive to recommend that the client terminate the use of margin. Please Note: The use of margin can cause significant adverse financial consequences in the event of a market correction. Termination of Advisory Agreements An Advisory Agreement may be terminated by us or the client for any reason upon written notice to the other, as provided in the Advisory Agreement. If the Advisory Agreement is terminated, the client will receive a full refund of any prepaid fees prorated based on the number of days the Advisory Agreement was in effect during such calendar period, within 30 days. Any unpaid advisory fees owed to us will become immediately due and payable upon termination of the Advisory Agreement. After an Advisory Agreement has been terminated, the client will be charged commissions, sales charges, and transaction, clearance, settlement, and custodial charges, at prevailing rates, by any executing or carrying broker-dealer. The client will be responsible for monitoring all transactions and assets and we will not have any obligation to monitor or make recommendations or take any further action with respect to any account or assets. ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance- based fees. ITEM 7 TYPES OF CLIENTS Asset Management and Financial Planning Services We provide asset management and financial planning services to individuals, high net worth individuals, corporations, trusts, charitable organizations and foundations. 11  Item 7 Types of Clients (continued) In general, we require a minimum amount of $50,000 to open and maintain an advisory account or enter into a financial planning agreement. This amount is negotiable at our discretion. Third-Party Managers & Private Fund Services Certain Third Party Managers or Private Funds may impose a higher minimum to open and maintain an advisory relationship. ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Our Methods of Analysis and Investment Strategies At IMA Private Wealth, we believe that long-term strategic asset allocation is a primary determinant of portfolio outcomes. As such we implement diversified investment portfolios that align risk and return objectives with client objectives and goals. Working together, we will suggest an investment portfolio that we deem appropriate to the client’s individual circumstances and the relative long-term attractiveness of the various asset classes. We will work with you to align your investment accounts within your household’s risk tolerance. Fundamental Analysis Fundamental analysis involves analyzing a company's income statement, financial statements and health, its management and competitive advantages, and its competitors and markets. The fundamental analysis school of thought maintains that markets may misprice a security in the short run, however, that the "correct" price will eventually be reached. Profits can be made by trading the mispriced security and then waiting for the market to recognize its "mistake" and re-price the security. However, fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and company developments may result in significant price fluctuations that can lead to investor losses. Modern Portfolio Theory This investment philosophy refers to the process of seeking to reduce portfolio risk through systematic diversification across and within various asset classes. Implementation of Modern Portfolio Theory often emphasizes the analysis of asset classes and the fund managers in the selection of investments to comprise portfolios, with additional consideration of market and economic factors when considering the specific allocations and weightings within each portfolio, as well as decisions affecting changes in portfolio investments, allocations, and weightings. 12  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) Our investment strategies and advice may vary depending upon each client’s holistic specific financial situation. We first determine your risk tolerance, at the household level, before assigning investment strategies to your accounts. As a result, your household risk profile may be comprised of accounts with varying risk profiles based on the characteristics of different account types. We determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. We use risk based portfolios that will be similar across clients: However, we take the time and expend the effort to ensure each of our clients’ portfolios is managed with their unique set of circumstances considered. Therefore, it is important that you discuss these strategies and risks with us as they may or may not apply to how your particular portfolio is being managed. We will work with clients and prospective clients to determine an appropriate asset allocation-based portfolio consisting of stocks, bonds, cash and other investments. Asset allocation means determining an approximate percentage of each asset class to be used as long-term guidelines, based on individual clients’ unique set of circumstances. This involves, but is not limited to, age, net worth, legacy assets, dependents, future funding needs, cash flow needs, investable asset base, and risk assessment. The risk assessment is the combination of the client’s ability to take risk and the client’s desire for risk. For example, you may want to be very aggressive but if you have a lot of dependents, little money or high need for income you may not have much ability to be exposed to significant price volatility. Conversely, you may have a high liquid net worth, but are just simply uncomfortable with a lot of exposure to the stock market (low desire for risk). Tactical decisions (shorter-term in nature) may be employed to take advantage of temporary changes in the investment opportunity set. We monitor a wide variety of variables including broad economic trends and financial markets worldwide in order to identify both risks and long-term opportunities. However, economic outcomes and financial market prices are notoriously unpredictable. Thus, our investment decisions are based primarily on long-term, fundamental, considerations, not market timing or economic forecasts. We pursue a long-term investment philosophy and, therefore, investments are made with a several year time horizon and turnover tends to be low. As a result, trading expenses and current period tax payments, where relevant, may be lowered. In addition to common stocks and bonds, we invest our clients in mutual funds and ETFs in order to provide clients exposure to the desired investment opportunities. We examine the long-term experience and investment record of the mutual fund or ETF to evaluate the fund’s ability to successfully invest over the long-term and in different economic conditions. We also review the underlying assets in a mutual fund or ETF to determine whether there is significant overlap in the underlying investments held in other funds or as individual securities in the client’s portfolio. We also 13  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) monitor the mutual funds and ETFs to determine whether they are continuing to follow their stated investment strategy. Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your Custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Recommendation of Particular Types of Securities We recommend various types of securities, and we do not primarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. A description of some, however not all types of securities we may recommend to you and some of their inherent risks are provided below. Mutual Funds and Exchange Traded Funds: Mutual funds and ETFs are professionally managed collective investment vehicles that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that invests in accordance with the fund’s investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs will be reduced by the costs to manage the funds. Also, while some mutual funds are “no load” and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Municipal Securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them including the credit worthiness of the governmental entity that issues the bond; the stability of the revenue stream that is used to pay the interest to the bondholders; when the bond is due to mature; and, whether or not the bond can be “called” prior to maturity. When a bond is called, it 14  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. Bonds: Corporate debt securities (or “bonds”) are typically safer investments than equity securities, however their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to mature, and whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Third Party Managers & Private Funds For Third Party Managers and Private Funds, we select and evaluate the Fund Sponsor or Third Party Manager in making the recommendation to the client and conduct ongoing monitoring of the Fund Sponsor or Third Party Manager. We will not perform quantitative or qualitative analysis of individual securities within Private Funds. Instead, we will advise the client regarding allocation of their assets among the Fund Sponsors or Third Party Managers, and allocation of assets among various classes of securities. The portfolio managers consider, but does not rely exclusively on, any research or performance information provided by the Fund Sponsor or Third Party Manager in reaching the decision to recommend a Fund Sponsor or Third Party Manager. We do not audit, verify, or guarantee the accuracy, completeness, or methods of calculating any historic or future performance or other information provided by a Fund Sponsor or Third Party Manager. There is no assurance that the performance or other information from a Fund Sponsor or Third Party Manager, or other source is or will be calculated on any uniform or consistent basis or has been or will be calculated according to or based on any industry or other standards. Other Tools & Analysis We may also consider the results of analytics made available through Envestnet, provided by other non- affiliated investment advisers at no additional cost. Risks for All Forms of Analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, 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 inaccurate or misleading information will compromise our analysis. Moreover, securities are often priced on factors that cannot be predicted, such as emotional and behavioral factors of other market participants. Use of Alternative Intelligence (“AI”) and Related Risks We rely on certain third party service providers that use artificial intelligence (“AI”) tools in systems supporting research, data management, and other operational functions. Our personnel may also use AI 15  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) enabled tools for operational and administrative purposes. We do not use AI to make or implement investment decisions, and all advisory judgments remain subject to human oversight. AI tools may present risks, including errors resulting from inaccurate or incomplete data, potential model bias, programming flaws, or cybersecurity vulnerabilities. As regulatory expectations for AI continue to evolve, future rule changes may affect how AI can be used or supervised by investment advisers. Because AI use is becoming more widespread across the financial industry, reliance on similar models or data sources may contribute to correlated or systemic risks, particularly during periods of market stress. We mitigate these risks by maintaining human oversight of any activities involving AI and by assessing vendor controls, data handling practices, and system security. Risk of Loss. Securities investments are not guaranteed, and you may lose some or all of your money on any of your investments. We ask that you communicate with us to help us understand your tolerance for risk. ITEM 9 DISCIPLINARY INFORMATION We have no disciplinary information to report under this item. ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS IMA Advisory Services, Inc. is owned by IMA Advisors which is wholly owned by IMA Financial Group, Inc. (“IMAFG”). IMA has numerous subsidiary corporations which are engaged in retail and wholesale and specialty insurance operations. If you need professional insurance services for yourself or your business, we will refer you to IMAFG and its subsidiaries. Should insurance products be purchased as a result of this referral, IMA Advisory Services, Inc. associated persons could be eligible to receive compensation for contributing to these sales. You are not obligated in any way to use IMAFG and its subsidiaries to purchase insurance products. 16  Item 10 Other Financial Industry Activities and Affiliations (continued) IMA Advisors is also the parent company to TRG Investment Advisers, LLC, (“TRGIA”). TRGIA provides investment advisory services to individuals and retirement plans. If you wish to engage these services, we will refer you to TRGIA. You are not obligated in any way to use TRGIA or the services they offer. IMA Advisors is also the parent company to IMA Executive Benefits and Life Insurance LLC. (“IMA EXLI”) IMA EXLI and IMA Advisory Services are also each a registered insurance agency. Certain employees are licensed to sell life, health, disability, and long-term care insurance. As such, these employees may recommend that a client (in his or her separate capacity as an insurance customer) buy insurance products which are entirely separate from investments made for the client's managed account. For these separate insurance recommendations, the employees will receive customary insurance compensation. Clients, however, are not under any obligation to engage these employees when considering implementation of insurance recommendations. The possibility of receiving additional compensation from selling insurance products to a client provides an economic incentive for an employee to recommend these products based on the compensation to be received rather than on a client’s investment needs. This is a conflict of interest that clients should consider. We have adopted the following steps to address this conflict of interest in this situation: + we disclose the existence of the conflict of interest that arises from the incentive an employee has to earn additional compensation from recommending the purchase of insurance products over and above the advisory fees we receive, and we endeavor to act consistent with our fiduciary duty; + we disclose to clients they have the right to decide whether or not to act on such recommendations; + we request clients to provide and update material information regarding their personal and financial situation, and the investment objective, tolerance for risk, liquidity needs, and investment time horizon for the advisory account that will be managed by us, and we conduct regular reviews of account investments; + we require that our employees seek prior approval of outside employment activity so that we may detect conflicts of interests and ensure such conflicts are properly addressed; + we periodically ask employees to certify information regarding their disclosed outside employment activities; and + we educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. If you wish to purchase these products, we will offer them to you as an agent or producer of IMA EXLI or IMA Advisory Services’ insurance agency. If you purchase these products through IMA Advisory Services’ insurance agency our associated persons are eligible to receive a percentage of the commissions generated by these sales. These referrals and payments are made pursuant to agreements between IMA Advisory Services, and such individuals. You are not obligated to use IMA Advisory Services to purchase insurance products if you are a client of IMA Advisory Services. 17  Item 10 Other Financial Industry Activities and Affiliations (continued) Please see Item 14 (“Client Referrals and Other Compensation”) for information about other referral arrangements between IMA Advisory Services, Inc. and its affiliates. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Description of Our Code of Ethics We have adopted a Code of Ethics expressing our commitment to ethical conduct. Our Code of Ethics describes our fiduciary responsibilities to our clients, and our procedures in supervising the personal securities transactions of our supervised persons who have access to information regarding client recommendations or transactions (“access persons”). A copy of our Code of Ethics is available to our clients and prospective clients. You may request our Code of Ethics by contacting us at the number listed on the cover page of this brochure. We owe a duty of loyalty, fairness, and good faith towards our clients and have an obligation to adhere not only to the specific provisions of the Code of Ethics however also to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of our access persons’ quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by our access persons. Among other things, our Code of Ethics also requires the prior approval of any equity or fixed income securities transactions, any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our Code also provides for oversight, enforcement, and recordkeeping provisions. Our Chief Compliance Officer may grant exceptions to certain provisions contained in the Code where we reasonably believe the interests of our clients will not be materially adversely affected or compromised. Doubts arising in connection with personal securities trading should be resolved in favor of the client even at the personal expense of our employees. Our Code of Ethics prohibits the misuse of material non-public information. While we do not believe that we have any access to material non-public information regarding publicly traded companies that would be subject to misuse, all employees are reminded that any such information may not be used in a personal or professional capacity. IMA Advisory Services. and its principals, officers, affiliates, employees, and advisors may act as investment adviser for others, may manage funds or capital for others, may have, make and maintain investments in its or their own names, or may serve as an officer, director, consultant, partner, or stockholder of one or more investment partnerships or other businesses, subject to compliance with our Code of Ethics. In doing so, IMA Advisory Services, or such 18  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading (continued) persons may give advice, take action, and refrain from taking action, any of which may differ from advice given, action taken or not, or the timing of any action, for any particular client. Protecting the confidentiality of our clients’ nonpublic information is important to us. We have instituted policies and procedures to ensure that nonpublic customer information is kept confidential. We do not disclose non-public personal information about our clients or former clients to any non- affiliated third parties, except as provided pursuant to our privacy policies or as required by or permitted by law. In the course of servicing a client’s account, we may share client information with service providers, such as custodians, transfer agents, accountants, and attorneys. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. ITEM 12 BROKERAGE PRACTICES Factors in Recommending Custodians and Brokers We seek to recommend a custodian and broker who will hold your assets and execute transactions that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: + combination of transaction execution services and asset custody services (generally without a separate fee for custody services); + breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.); + capacity to execute, clear and settle trades (buy and sell securities for your account); + capacity to facilitate transfers and payments to and from your account (wire transfers, check requests, bill payments, etc.); + availability of investment research and tools that assist us in making investment decisions; + quality of services; + competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices; + reputation, financial strength and stability; + prior service to us and our other clients; and + availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us from Schwab”) 19  Item 12 Brokerage Practices (continued) We have evaluated Schwab and have determined, based on our experience with them, they offer clients an excellent blend of services and reputation, competitive total cost, and access to mutual funds otherwise not available to us or our clients. Schwab generally does not charge you separately for custody services, however is compensated by charging you commissions or other fees on trades they execute or settle into your account. We may not be able to accept clients who wish to utilize other custodians. Schwab commission rates were negotiated based on the condition that our clients collectively maintain a total of at least $230 million of their assets in Schwab accounts. In addition, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker dealer. Products and Services Available to Us Through Schwab Schwab Advisor Services™ (“SAS”) is Schwab’s business that serves independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services – trading, custody, reporting, and related services – many of which are not typically available to Schwab retail customers. They also make available various support services. Some of these services help us manage or administer our clients’ accounts. Others help us manage and grow our business. These support services generally are available on an unsolicited basis (we don’t have to request them) and at no charge to us provided that our clients collectively maintain a total of at least $10 million of their assets at SAS. If our clients collectively have less than $10 million at SAS, SAS can charge us quarterly service fees of $1,200 (SAS). Here is a more detailed description of support services made available by SAS: Services That Benefit You: Institutional brokerage services available through SAS include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through SAS include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The services described in this paragraph generally benefit you and your account. Services That May Not Directly Benefit You: SAS also makes available to us other products and services that benefit us, however may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both from Schwab as well as third parties. This research is used to service all or a substantial number of our clients’ accounts, including accounts not maintained at SAS. In addition to investment research, SAS also makes available software and other technology that: + provide access to client account data (such as duplicate trade confirmations or account statements); + facilitate trade execution and allocate aggregated trade orders for multiple client accounts; + provide pricing and other market data: 20  Item 12 Brokerage Practices (continued) + facilitate payment of our fees from our clients' accounts; and + assist with back-office functions, recordkeeping and client reporting Services That Generally Benefit Only Us: SAS also provides other services intended to help us manage and further develop our business enterprise. These services include: + educational conferences and events; + technology, compliance, legal and business consulting; + publications and conferences on practice management, business succession and marketing; and + access to employee benefits providers, human capital consultants, and insurance providers SAS provides some of these services themselves. In other cases, SAS arranges for third-party vendors to provide the services to us. SAS also discounts or waives fees for some of these services or pays all or a part of a third-party’s fees for us. SAS also provides us with other benefits, such as occasional business entertainment for our personnel. SAS has provided us with a discount on software solutions made available through Schwab Performance Technologies®. This discount allows us to obtain this software at a reduced fee. Our Interest in Schwab Services The availability of these services from SAS benefits us because we do not have to produce or purchase them. We do not have to pay for Schwab services if a total of at least $10 million of our clients’ account assets are maintained with SAS. Beyond that, these services are not contingent upon IMA Advisory Services, committing any specific amount of business to SAS in trading commissions or assets in custody. This minimum asset requirement could give us an incentive to request that you maintain your account with Schwab, based on our interest in receiving services from SAS that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that our request to choose SAS as custodian and broker is in the best interest of our clients. Our recommendation is primarily supported by the scope, quality and price of these services and not the services that benefit only us. Given the amount of our client assets under management as shown in Item 4 of this Brochure, we do not believe that recommending our clients to collectively maintain at least $10 million of those assets at Schwab to avoid paying quarterly service fees to Schwab presents a material conflict of interest. Third Party Manager Brokerage Considerations The details of each Third Party Manager program must be considered individually with respect to the costs and other considerations involving the execution of trades for the client’s account; depending on the Third Party Manager program, different arrangements will affect which broker-dealer will execute trades for the client’s account, whether the program is a wrap fee arrangement, and whether Third Party Managers are permitted to place trades “away” with non-program broker-dealers that will charge additional transaction charges, typically, when the Third Party Manager believes by doing so it has an opportunity (however not a guarantee) to obtain a more favorable price. 21  Item 12 Brokerage Practices (continued) Clients should discuss the terms of their specific Third Party Manager program with their individual advisor. Current Third Party Manager programs permit Third Party Managers to place trades away with few controls on the additional costs to the client. While we will request information regarding trade- away costs and practices, there is a risk we may not be able to identify when trade-away activities are occurring, or the extent of such activities. Third Party Managers may provide information from which it is difficult to determine whether their trade away activities have been reasonable. Clients should monitor their confirmations and account statements carefully. Directed Brokerage We do not permit directed brokerage. Aggregated Trades We typically aggregate purchases or sales of the same security for multiple accounts. We are not, however, obligated to aggregate purchases and sales. When we do aggregate orders, all accounts included in a block trade participate at the average share price. Each account participating in a block trade will share in transaction costs equally and on a pro-rated basis. Block trading allows us to execute transactions in a more timely and equitable manner, as detailed below. Clients participating in block trades do not receive the benefit of negotiated commissions, as we do not have that authority on an account-by-account or transaction-by-transaction basis. Clients with non-discretionary accounts or who place certain restrictions on discretionary accounts sometimes experience delays in order execution as compared to clients with unrestricted discretionary accounts. Typically, partial fills will be allocated among accounts in proportion to the total orders participating in the block, unless we determine that another method of allocation is equitable (such as an alphabetical rotation, rotation based on the clients of a particular advisor, or other method). Exceptions may be granted or allowed due to varying cash availability, divergent investment objectives, existing concentrations, tax considerations, investment restrictions, or a desire to avoid “odd lots” (an amount of a security that is less than the normal unit of trading for that security). Schwab may aggregate purchase and sale orders for ETFs across accounts enrolled in the IIP, including accounts for our clients and accounts for clients of other independent investment advisory firms using the Platform. Trade Error Policies From time to time, we may make an error when submitting a trade order on your behalf. When this happens, we typically work directly with the custodian’s trading desk to correct the trade error. This is done within the account in which the trade occurred. We seek to identify errors and work Sub-Manager and/or qualified custodian to correct the error affecting any client account as quickly as possible. Errors may be corrected by either the purchase or sale of a security as originally intended, or in the form of monetary reimbursement to the applicable client account. 22  Item 12 Brokerage Practices (continued) IMA Advisory Services’ policy and practice is to monitor and reconcile trading activity, identify, and resolve any trade errors promptly, document each trade error with appropriate supervisory approval and maintain a trade error file. If the error is the responsibility of IMA Advisory Services, any transaction will be corrected, and IMA Advisory Services will be responsible for any loss resulting from an inaccurate or erroneous order. In the case of errors due to the inaction, or actions of others (Advisors, Sub- Manager's, Custodians), we may help facilitate the error correction process, again in the best interests of our clients. Schwab’s trade error policy is to donate the amount of any gain $100 and over to charity. Schwab will retain the loss or gain (if the gain is not retained in your account) if it is under $100 to minimize and offset its administrative time and expense. If a loss occurs greater than $100, we will receive an invoice for the amount of the loss. IMA Advisory Services, if needed, will utilize our error account to correct the trade for your account. Private Fund Investment Opportunities From time to time, we may offer private fund investment opportunities on a limited basis to qualifying investors, subject to the capacity constraints of the underlying fund. Employees of IMA Private Wealth may invest in these offerings alongside our clients. Due to limited availability, employee participation may contribute to oversubscription, potentially resulting in reduced allocations for clients. In instances where IMA Private Wealth controls the allocation process, clients will receive full allocations before employees are permitted to participate. Where allocation decisions are made by the fund sponsor, employees may receive the same pro rata allocation as clients. Class Action Lawsuit Filings We have entered into an arrangement with Chicago Clearing Corporation (“CCC”) to provide you with a service that automatically files your forms for securities class-action lawsuits. The fee you would pay for services provided by CCC is 20% of any amount collected. The service fee is paid entirely by you, and it is deducted from the amount collected by CCC on your behalf. The award is paid directly to you by CCC after they have deducted their 20% fee. The entire amount you pay for this service stays with CCC; we do not receive any share of the fee collected by CCC, nor do we receive any revenue in exchange for making this service available to you. You do not pay any fee to sign up for this service. You will not owe anything whatsoever to CCC until CCC collects an award on your behalf. We will furnish to CCC the holding information for clients who choose to use this service. You are not required to participate in this service. You can choose to handle your own securities class action claims and receive 100% of any awards payable to you. Clients who opt-out of this service agree to research, document, and submit their own class action lawsuit claims. New clients can opt-in by signing an authorization form when we enter into an investment advisory arrangement with you. You can discontinue this service at a later date by contacting our office at number found on the cover page 23  Item 12 Brokerage Practices (continued) of this brochure. Class action lawsuit claim information already received by CCC could continue to be processed by their firm following receipt of your service discontinuation notification. ITEM 13 REVIEW OF ACCOUNTS Account Reviews Account investments are reviewed regularly by our Investment Committee. The Investment Committee also conducts periodic evaluations of the portfolio for consistency with investment objectives and restrictions, and with the account’s stated objectives and strategy. While the investments within accounts are regularly monitored, the accounts are reviewed at least annually in the context of each client’s stated investment objectives and guidelines. More frequent reviews can be triggered by significant market or economic factors, or if we are notified of changes in the client’s financial situation, large withdrawals or significant deposits, or changes in the account investment objectives, liquidity needs, or risk tolerance. An account review is done by the individual advisor assigned to the client account(s). The Investment Committee will be responsible for overseeing all reviews. Generally, Financial Planning or Consulting Services do not include reviews, unless specifically included in the client’s Advisory Agreement. Extended Planning Services clients receive on-going account reviews through frequent meetings with their individual advisor and (approximately) annual account reviews, as the client and individual advisor mutually agree. For clients whose account is being managed by a Third Party Manager, the Investment Committee monitors the Third Party Manager account for consistency with target investment characteristics and restrictions, suitability for the client’s broader portfolio, and control over of transaction fees and expenses, including any trade away expenses and evaluation of best execution. Client Reports Clients will receive account statements directly from their Custodian on at least a quarterly basis showing all transactions in their account during the reporting period. clients should review the Custodian’s statements carefully. We provide quarterly reports regarding client accounts which provide information detailing account debits, credits, receipts, deliveries, and positions as part of our advisory services. If a client receives a report, which refers to the value of an asset also shown on a Custodian’s statement, we urge the client to compare the information with the statement they receive from the Custodian and contact us immediately if any discrepancies are found. Financial Planning Services clients receive a written financial plan or report from us only if agreed upon in the planning agreement. 24  Item 13 Review of Accounts (continued) Clients engaging a Third Party Manager will receive monthly or quarterly account statements from the custodian of the Third Party Manager account(s); and will receive reports from the Third Party Manager, if agreed in the Third Party Manager Agreement. ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION Client Referrals Some of our affiliated individuals also earn compensation based on (1) acquisition and retention of investment advisory client assets under management and (2) advisory fees paid to IMA Advisory Services. Should referred clients decide to hire us, these individuals will receive compensation. This is a conflict of interest because these affiliated individuals have an economic incentive to recommend our advisory services. Economic Benefit from Schwab We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts with Schwab. The availability to us of Schwab’s products and services is not based on us giving advice concerning any particular investment, such as buying particular securities for our clients. Referral Arrangements with Third Parties We can recommend other investment advisers for our clients. For this referral, we will receive a portion of the fee paid to the other advisor for the referral. Clients are advised of this payment when considering whether to invest with the other investment adviser. The payment provides an incentive to recommend the other adviser based on the share of fees received rather than based solely on the client’s investment needs. We use the services of the CFP Board’s “Find Your CFP Professional” search to match prospective advisory clients with investment advisers in exchange for a non-success-based fee paid by IMA for engaging advisory services. We participate in the Advisor Referral Program sponsored by Empower Retirement. Through this program, qualifying retirement plan clients may choose to refer eligible retirees and departing plan participants to IMA Private Wealth for individual investment advisory services. Participation in this program does not involve any compensation to or from Empower Retirement. Referred individuals are under no obligation to engage our services and may choose to do so at their sole discretion. 25  ITEM 15 CUSTODY At our client’s direction, the client’s independent Custodian will directly debit account(s) for the payment of advisory fees. This ability to deduct the client’s advisory fees from client accounts means we have “limited” custody over client funds or securities. We do not have physical custody of any client funds and/or securities. Client funds and securities will be held with a bank, broker-dealer, or other qualified custodian. Clients will receive account statements directly from their Custodian on at least a quarterly basis showing all transactions in their account during the reporting period. The account statements from the client’s Custodian(s) will indicate the amount of our advisory fees deducted from client account(s) each billing period. Clients should review the Custodian’s statements carefully. If a client receives a report from us which refers to the value of an asset also shown on a Custodian’s statement, we urge the client to compare the information with the statement they receive from the Custodian and contact us immediately if any discrepancies are found. Third-Party Authorizations Clients may provide the Custodian with written instruction authorizing us to direct transfers to a specified third party, either on a set schedule or from time to time, subject to certain regulatory requirements. As a result of this limited authority, we will be deemed to have custody of the client’s assets, however we are not required to engage an independent CPA to conduct a surprise verification of the account assets as long as we meet the following criteria: 1. Clients provide a written, signed instruction to the qualified Custodian that includes the third party’s name and address or account number at a Custodian; 2. Clients authorize IMA Advisory Services in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. The Custodian verifies the client’s authorization (e.g., signature review) and provides a transfer of funds notice to clients promptly after each transfer; 4. Clients can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to IMA Advisory Services nor located at the same address as IMA Advisory Services; and 7. The Custodian sends clients, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 26  ITEM 16 INVESTMENT DISCRETION Investment guidelines and restrictions must be provided to us in writing. We usually receive discretionary authority from our clients at the beginning of an advisory relationship. Clients sign a limited power of attorney directing their Custodian to accept instructions from us to purchase and sell securities in the client’s account. This discretionary authority includes securities selection as well as determining the amount of securities to be bought or sold. This discretionary authority is to be exercised by our firm in a manner consistent with the stated investment objectives for the particular client relationship. We will also allow clients to place reasonable restrictions on their discretionary accounts. Typical restrictions include: + restriction on the sale of specific low-basis holdings held in the client’s account; and + prohibition on investment in one or more specific securities. We prefer to manage advisory accounts on a discretionary basis however will occasionally accept non- discretionary accounts. Clients who establish non-discretionary accounts or who place certain restrictions on discretionary accounts may experience delays in order execution as compared to clients with unrestricted discretionary accounts. Clients who wish to have their assets managed by a Third Party Manager should understand that the accounts are managed on a discretionary basis, on terms established by the Third Party Manager. ITEM 17 VOTING CLIENT SECURITIES We typically agree to vote proxies for portfolio securities as a courtesy to our clients. We have adopted policies and procedures designed to ensure that proxies are voted in the client’s best interest. We vote proxies related to securities held by wealth management services clients who provide us with specific, written authority to do so. This service is available for all managed accounts held at our approved Custodian. This written authority is provided in our Advisory Agreement and through written instruction to your Custodian. We have engaged a proxy advisory firm to assist us with voting all of our clients' proxies. The proxy advisory firm provides an electronic vote management system which allows: (1) population of each client's votes shown on the proxy advisory firm's electronic voting platform with the firm's recommendations ("pre-population"); and (2) automatic submission of the client's votes to be counted ("automated voting"). Pre-population and automated voting generally occur prior to the submission deadline for proxies to be voted at the shareholder meeting. 27  Item 17 Voting Client Securities (continued) In the course of reviewing proposals subject to a proxy vote, our firm may become aware that a company that is the subject of a voting recommendation by the proxy advisory firm intends to file or has filed additional soliciting materials with the SEC describing the company’s views regarding the voting recommendation. These materials may (or may not) reasonably be expected to affect our voting determination. Such materials may become available after or around the same time that our votes have been pre-populated with the proxy advisory firm, however, before the submission deadline for proxies to be voted at the shareholder meeting. Our proxy voting policies contemplate the possibility of issuer materials being made available after we submit to the proxy advisory firm information for client proxy votes, however before the submission deadline for proxies. These procedures include assessing pre-populated votes shown on the proxy advisory firm’s electronic voting platform and considering additional information that may become available before the relevant votes are cast. We also review our processes for monitoring and assessing information alerts informing us of additional soliciting materials (or updates from the proxy advisory firm that such materials are available). Depending on the facts and circumstances, including the complexity of the additional submitted materials, the timing of the notice we receive of such materials, and the deadline for voting, we may (or may not) have the ability, in the exercise of our fiduciary obligation, to consider and respond by changing previously set votes. Please contact our office to receive a report of how your proxies were voted or a copy of our complete proxy voting policies and procedures (see cover page for contact information). If you choose to vote your own proxies, the solicitation materials will be delivered directly to you by your custodian (or by a third-party agent through an arrangement with your custodian). Clients who wish to have their assets managed by a Third Party Manager or who participate in a Private Fund, should understand that the proxy voting policies for those assets are based on terms established by the Third Party Manager or the Private Fund. ITEM 18 FINANCIAL INFORMATION Not applicable. 28  About IMA Financial Group Based in North America, IMA Financial Group, Inc. is an integrated financial services company focused on protecting the assets of its widely varied client base through insurance, risk management, employee benefits, and wealth management solutions. As an employee-owned company, IMA’s 3,000-plus associates are empowered to provide customized solutions for their clients’ unique needs. Please visit http://imacorp.com/terms-service/ to review our full privacy and compensation disclosure statements. IMACORP.COM 

RETIREMENT PLAN ADVISORY SERVICES BROCHURE IMA ADVISORY SERVICES, INC. DBA IMA RETIREMENT March 31, 2026 Corporate Address: 1705 17th Street, Suite 100, Denver, Colorado 80202 Mailing address: 430 E. Douglas Ave., Suite 400, Wichita, Kansas 67202 316.266.6574 | www.IMARetirement.com This Brochure provides information about the qualifications and business practices of IMA Advisory Services, Inc. (“IMAAS”), doing business as IMA Retirement. If you have any questions about the content of this brochure, contact us at 316.266.6574. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about IMA Advisory Services is also available on the SEC’s website at www.adviserinfo.sec.gov. IMA Advisory Services, Inc. is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. IMACORP.COM  ITEM 2 SUMMARY OF MATERIAL CHANGES Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our March 31, 2025 amendment, this Brochure contains updated information regarding our assets under management. 1  ITEM 3 TABLE OF CONTENTS ITEM 2 SUMMARY OF MATERIAL CHANGES .................................................................................................... 1 ITEM 3 TABLE OF CONTENTS ................................................................................................................................. 2 ITEM 4 ADVISORY BUSINESS .................................................................................................................................. 3 ITEM 5 FEES AND COMPENSATION ..................................................................................................................... 4 ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................ 6 ITEM 7 TYPES OF CLIENTS ....................................................................................................................................... 7 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................. 7 ITEM 9 DISCIPLINARY INFORMATION ................................................................................................................ 9 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................. 10 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................................................................................................................... 10 ITEM 12 BROKERAGE PRACTICES ........................................................................................................................ 12 ITEM 13 REVIEW OF ACCOUNTS ......................................................................................................................... 12 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION .................................................................... 13 ITEM 15 CUSTODY .................................................................................................................................................... 13 ITEM 16 INVESTMENT DISCRETION ................................................................................................................... 14 ITEM 17 VOTING CLIENT SECURITIES ................................................................................................................ 15 ITEM 18 FINANCIAL INFORMATION .................................................................................................................. 15 2  ITEM 4 ADVISORY BUSINESS Description of Firm IMA Advisory Services, Inc. ("IMA Advisory Services", “IMA Retirement”, "we", or "us") is a registered investment adviser headquartered in Wichita, Kansas. We are organized as a corporation under the laws of the State of Kansas and have been providing investment advisory services since 1999. As of October 2023, we are wholly owned by IMA Advisors, Inc. a wholly owned subsidiary of IMA Financial Group, Inc. This disclosure brochure describes our retirement plan services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your plan's specific needs. Services Described in this Brochure We have three brochures that describe our services. This brochure focuses on our fee-based Qualified and Non-Qualified Employee-Directed Retirement Plan Consulting Services. Our wealth management services for individuals and services provided to non-profit organizations are described in separate brochures. If you are interested in receiving the brochure that describes these services, please contact our office at 316.266.6574. Retirement Plan Advisory Services – Qualified and Non-Qualified Retirement Plans We provide investment advisory, consulting services, and educational seminars/workshops to qualified and non-qualified retirement plans (the "Plans") and their Plan participants. Any investment advice provided will be tailored to the investment policies of the plans. We may assist a plan in developing, modifying, and managing an investment policy statement ("IPS") for our clients. A. Continuous Advisory Arrangement We agree to provide investment advice on either a non-discretionary or discretionary basis. The written Advisory Agreement that we enter into with the Plan sponsor specifies the capacity in which we have been engaged: + If a Plan sponsor selects non-discretionary investment advice, we would serve by providing investment advice within the meaning of section §3(21)(A)(ii)of the Employee Retirement Income Security Act of 1974 ("ERISA") with respect to the specific investments we recommend in connection with our services to the Plan, and only to the extent that our investment recommendations are actually implemented by the Plan sponsor. + If the Plan sponsor selects discretionary investment advice, we serve as an investment manager for the Plan within the meaning of ERISA § 3(38). Our fiduciary investment responsibilities are limited to those of an investment manager. B. Limited Consulting Engagement We occasionally provide consulting services on either a one-time or periodic basis, depending on the Plan sponsor's needs and the nature of the work requested. These services range from a one-time 3  Item 4 Advisory Business (continued) engagement to comprehensive services provided on an as needed basis. This may include one or more of the consulting services listed above. Retirement Plan Due Diligence Services We provide retirement plan due diligence services to organizations as part of their mergers and acquisitions activity. This due diligence includes, however, is not limited to review of plan documents, examination of required filings, review of Fiduciary Governance, review of investment portfolio construction and overall plan health. Assets Under Management As of December 31, 2025, our total regulatory assets under management is $3,904,795,952 of which $557,197,021 are non discretionary. IMA Retirement also provides monitoring/consulting services to ERISA §3(21) retirement plans with assets of approximately $3,072,394,367. These assets are commonly referred to as assets under advisement. Assets Under Advisement (“AUA”) may appear in client and sales materials in addition to IMAAS’ regulatory Assets Under Management (“AUM”). AUA is presented when, due to the nature of the contractual agreements with certain clients, we provide consultative advice to our clients in a non- discretionary capacity and do not maintain discretionary authority over the clients’ portfolios(s). In such relationships, the clients maintain the ability and authority to manage and allocate assets within their own portfolio(s) independent of our advice. Therefore, these clients are not reflected within regulatory assets under management. Instead, these engagements are represented as part of our AUA. In the instance that AUA is listed in client or sales materials it will be accompanied by relevant disclosure indicating how AUA has been calculated. ITEM 5 FEES AND COMPENSATION Factors we consider in negotiating fees with a Plan sponsor include: + scope of services to be provided + frequency of the services + number of investment menu choices and Plan investment universe + frequency and complexity of reports + Plan assets 4  Item 5 Fees and Compensation (continued) Plan sponsors may choose one of two ways to pay our advisory fee: + pay directly + if the Plan document permits, the Plan sponsor can make arrangements with the Platform Provider to pay our advisory from the Plan assets Continuous Advisor Arrangement Fees Our continuous advisory service fees are negotiated with the Plan sponsor. The minimum annual fee arrangement we typically enter with new continuous service clients is $5,000, payable quarterly in advance. The specific way we bill for fees is established in our written agreement with the Plan sponsor. We calculate our fee one of two ways, as a percentage of Plan assets or as a fixed fee. Fee Dispersion: IMA Retirement, in its discretion, will sometimes reduce its investment advisory fee, charge a flat fee, waive its fee entirely, or charge fees on a different interval based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Certain clients may be subject to legacy fees or other arrangements. We retain the right to provide services to related persons of IMA Advisory Services and its affiliates at rates that are not made available to other clients. Please Note: As a result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. Limited Consulting Engagement Fees Our limited consulting engagement fees are negotiated with the Plan sponsor. This decision is based upon the nature of the services provided. We typically negotiate these fees using either: + A fixed fee for a particular consulting project based on the nature of the project and the amount of time needed to complete the project. We request half of the fee to be paid upon accepting the consulting project with the balance due and payable upon completion. + A minimum hourly rate of $250, based on the nature and complexity of the work requested. We will present an hourly rate to the Plan sponsor prior to beginning any work and, if possible, an estimated number of hours for completion of the job will be given. Hourly fees are due and payable as earned. Limited consulting engagement fees and compensation may include a provision for travel expenses depending on, among other things, the nature of the project. 5  Item 5 Fees and Compensation (continued) We typically negotiate separate fees if the Plan sponsor asks us to provide additional services outside the scope of our written agreement. For example, we request an additional fee, plus out of pocket travel expenses, to conduct employee education events in excess of the agreed number of days per year. Upon termination of our advisory agreement, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable to us. We will provide the Plan sponsor with a statement showing how the final invoice or refund is calculated. Upon termination, we will have no obligation to recommend or take any further action regarding the Plan. Retirement Plan Due Diligence Fees Our due diligence fee is negotiated with the organization. The decision is based upon the scope of services provided and is established in our written agreement with the organization. The fee for this service is due and payable upon completion of the agreed services. Additional Fees and Expenses As part of our investment advisory services, we will recommend that Plan participants invest in mutual funds and other products permitted by ERISA and the Plan. The fees that a Plan pays to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders, which are described in their prospectus. These fees will generally include a management fee and other fund expenses. The Plan will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom Plan account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost the Plan and its participants will incur, the Plan sponsor and the responsible Plan fiduciaries should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Our fees are calculated as described in the Fees and Compensation section above and are not charged on the basis of a share of capital gains or capital appreciation of invested funds. 6  ITEM 7 TYPES OF CLIENTS IMA Retirement provides retirement plan advisory services to qualified and non-qualified deferred compensation Plans established for employees of non-profit organizations, corporations and other businesses. In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate an engagement if it falls below a minimum size which, in our sole opinion, is too small to manage effectively. ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS We use one or more of the following methods of analysis or investment strategies when providing investment advice to a Plan: quantitative analysis, qualitative analysis and modern portfolio theory. Quantitative and Qualitative Analysis We use a quantitative system and qualitative methodology to analyze, rank and review investment performance utilizing information from both fund management companies and from various outside, independent sources to obtain fund information inputs and analysis. Quantitative fund information is accumulated each quarter-end and weighted according to its significance to the management and evaluation of an investment fund. Modern Portfolio Theory Modern portfolio theory is a portfolio theory that determines the minimum level of risk for an expected return. It assumes that investors will favor a portfolio with a lower risk level over a higher risk level for the same level of return. A central part of modern portfolio theory is how an individual security impacts the risk and return profile of an entire portfolio. In providing this advice, we use various sources of data from research materials provided by investment data providers, financial publications, fund information, and other public information sources. We advise clients to invest for the long term and take risks they are comfortable with to achieve their objectives. For Plan sponsors, we advise them to provide an array of investment choices to allow any of their employees the opportunity to develop a well-diversified portfolio that meets their individual investment needs, in keeping with modern portfolio theory. We usually advise against providing more speculative investment options within the retirement plan. 7  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that a Plan participants’ financial goals and objectives will be met. Past performance is in no way an indication of future performance. Recommendation of Particular Types of Securities We usually recommend mutual funds and other investment products permitted under the ERISA. Mutual Funds Mutual funds provide additional disclosures specific to each individual fund. These disclosures can be found in the fund’s prospectus. Clients should read each fund’s prospectus to obtain additional information prior to choosing the funds to be included in the investment menu of their retirement plan. The fund’s prospectus is generally available to the Plan sponsor and to participants through the Platform Provider either online or by telephone request. Stable Value Funds Stable value funds are designed to preserve capital while providing steady, positive returns. They are often made available as an investment elective in retirement savings plans. While stable value funds are considered one of the lowest risk investments offered in retirement savings plans, it is important to be aware of certain risks. Clients should read each fund’s prospectus to obtain additional information prior to choosing the funds to be included in the investment menu of their retirement plan. The fund’s prospectus is generally available to the Plan sponsor and to participants through the Platform Provider either online or by telephone request. Life-Cycle Funds Life-cycle funds (also referred to as “aged-based funds” or “target-date funds”) have two broad categories: “target date” and “target risk”. 1. Target-date funds operate under an asset allocation formula that assumes retirement in a certain year and adjusts their asset allocation model as it gets closer to that year. 2. Target-risk funds are based on risk tolerance, and generally provide several risk levels from which to choose (for example, conservative, moderate or aggressive). Life-cycle funds (both target-date and target risk) may provide performance results that vary considerably from their stated investment objectives. Portfolio allocation ranges can vary greatly from one life-cycle fund to another. Performance results may also vary considerably when compared to a peer group of life-cycle funds managed according to a similar objective. Collective Investment Trusts (CITs) CITs are maintained by a bank as trustee and are subject to federal or state banking regulation. As a result, CITs generally have fewer disclosure and reporting requirements concerning the trust's holdings, 8  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) performance, and management practices than traditional registered investment companies. This can make it more difficult to assess the trust's overall risk and effectiveness. CITs operate under a different regulatory framework than other investment companies. While all securities are regulated by the Securities and Exchange Commission (SEC), CITs are not securities and thus are only subject to oversight by federal and state banking regulators and the Department of Labor (DOL). This difference in regulatory oversight can lead to less stringent investor protections when compared to SEC registered securities. CITs are non-transferable and can only be liquidated by the issuer. This can result in liquidity constraints, particularly during periods of market volatility or if a retirement plan needs to remove a CIT option due to performance concerns. Some CITs may also impose restrictions on withdrawals, which could hinder access to funds when needed. Use of Alternative Intelligence (“AI”) and Related Risks We rely on certain third party service providers that use artificial intelligence (“AI”) tools in systems supporting research, data management, and other operational functions. Our personnel may also use AI enabled tools for operational and administrative purposes. We do not use AI to make or implement investment decisions, and all advisory judgments remain subject to human oversight. AI tools may present risks, including errors resulting from inaccurate or incomplete data, potential model bias, programming flaws, or cybersecurity vulnerabilities. As regulatory expectations for AI continue to evolve, future rule changes may affect how AI can be used or supervised by investment advisers. Because AI use is becoming more widespread across the financial industry, reliance on similar models or data sources may contribute to correlated or systemic risks, particularly during periods of market stress. We mitigate these risks by maintaining human oversight of any activities involving AI and by assessing vendor controls, data handling practices, and system security. ITEM 9 DISCIPLINARY INFORMATION We have no disciplinary information to report under this item. 9  ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS IMA Advisory Services, Inc. is owned by IMA Advisors which is wholly owned by IMA Financial Group, Inc. (“IMAFG”). IMAFG has numerous subsidiary corporations which are engaged in retail, wholesale and specialty insurance operations. If you need professional insurance services for yourself or your business, we will refer you to IMAFG and its subsidiaries. Should insurance products be purchased as a result of this referral, IMA Advisory Services, Inc. associated persons could be eligible to receive a commission generated by these sales. You are not obligated in any way to use IMAFG and its subsidiaries to purchase insurance products. IMA Advisors is also the parent company to TRG Investment Advisers, LLC, (“TRGIA”). TRGIA provides investment advisory services to individuals and retirement plans. If you wish to engage these services, we will refer you to TRGIA. You are not obligated in any way to use TRGIA or the services they offer. IMA Advisors is also the parent company to IMA Executive Benefits and Life Insurance LLC. (“IMA EXLI”) IMA EXLI and IMA Advisory Services, Inc. are also each a registered insurance agency. Certain employees are licensed to sell life health, disability, and long-term care insurance. If you wish to purchase these products we will offer them to you as an agent or producer of IMA Advisory Services’ insurance agency. If you purchase these products through IMA Advisory Services, Inc. insurance agency our associated persons are eligible to receive a percentage of the commissions generated by these sales. These referrals and payments are made pursuant to agreements between IMA Advisory Services, and such individuals. You are not obligated to use IMA Advisory Services, to purchase insurance products if you are a client of IMA Advisory Services. Please see Item 14 (“Client Referrals and Other Compensation”) for information about other referral arrangements between IMA Retirement, and its affiliates. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Description of Our Code of Ethics We have adopted a Code of Ethics expressing our commitment to ethical conduct. Our Code of Ethics describes our fiduciary responsibilities to our clients, and our procedures in supervising the personal securities transactions of our supervised persons who have access to information regarding client recommendations or transactions (“access persons”). A copy of our Code of Ethics is available to our clients and prospective clients. You may request our Code of Ethics by contacting us at the number listed on the cover page of this brochure. 10  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading (continued) We owe a duty of loyalty, fairness, and good faith towards our clients and have an obligation to adhere not only to the specific provisions of the Code of Ethics however also to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of our access persons' quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by our access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our Code also provides for oversight, enforcement, and recordkeeping provisions. Our Chief Compliance Officer may grant exceptions to certain provisions contained in the Code where we reasonably believe the interests of our Clients will not be materially adversely affected or compromised. Doubts arising in connection with personal securities trading should be resolved in favor of the client even at the personal expense of our employees. Our Code of Ethics prohibits the misuse of material non-public information. While we do not believe that we have any access to material non-public information regarding publicly traded companies that would be subject to misuse, all employees are reminded that any such information may not be used in a personal or professional capacity. IMA Advisory Services, Inc. and its principals, officers, affiliates, employees, and advisors may act as investment adviser for others, may manage funds or capital for others, may have, make, and maintain investments in its or their own names, or may serve as an officer, director, consultant, partner, or stockholder of one or more investment partnerships or other businesses, subject to compliance with our Code of Ethics. In doing so, IMA Advisory Services, Inc. or such persons may give advice, take action, and refrain from taking action, any of which may differ from advice given, action taken or not, or the timing of any action, for any particular client. Protecting the confidentiality of our customers' nonpublic information is important to IMA Advisory Services, Inc. We have instituted policies and procedures to ensure that nonpublic customer information is kept confidential. We do not disclose nonpublic personal information about our clients or former clients to any non-affiliated third parties, except as provided pursuant to our privacy policies or as required by or permitted by law. In the course of servicing a client’s account, we may share client information with service providers, such as custodians, transfer agents, accountants, and attorneys. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. 11  ITEM 12 BROKERAGE PRACTICES We do not accept authority to select broker-dealers or negotiate commission rates for Retirement Plan Advisory Services clients. ITEM 13 REVIEW OF ACCOUNTS Account reviews will be conducted for advisory clients who enter into an agreement with us to provide this service. Reviews are conducted according to the schedule and frequency in our agreement with the Plan sponsor. Unless otherwise agreed with the Plan sponsor, IMA Retirement will conduct a review and analysis of investments held by the Plans on a quarterly basis. Funds may be added to a watch or replacement list governed by the Investment Policy of the Plan and the prudent judgement of its Investment Committee. Other factors may also be taken into consideration, including whether the entire category suffered a period of underperformance, availability of viable replacements within the menu, restrictions that would limit the ability to make a change, or other mitigating circumstances specific to the Plan. Client Reports Written reports for continuous advisory services are provided to the Plan on a mutually agreed upon schedule. Limited consulting engagement reports are provided to the Plan sponsor within a reasonable time frame following the receipt of all requested information related to the Plan. The schedule and time frame are specified in our written advisory agreement with the Plan sponsor. You are responsible for ensuring that we receive copies of all information related to the Plan necessary to perform our services. This may include a listing of current investment selections and the current dollar value of assets within each investment selection. Continuous advisory services clients typically receive a comprehensive report package illustrating absolute and relative performance of the retirement plan investment choices. These reports are in addition to those prepared by the Platform Provider. Client Meetings The meeting schedule for continuous advisory services clients is typically determined with the Plan sponsor based on factors such as plan size and relative complexity of its investment portfolio, however will be scheduled no less than an annual basis for all Plan clients. 12  ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION Client Referrals Some of our affiliated individuals may earn compensation based on (1) acquisition and retention of investment advisory client assets under management and (2) advisory fees paid to IMA Retirement. Should referred clients decide to hire IMA Retirement, these individuals will receive compensation. This is a conflict of interest because these affiliated individuals have an economic incentive to recommend our advisory services. Compensation paid under these arrangements does not increase by the fees paid by our Clients. We do not receive payment from any company for the referral of advisory business. Other Compensation We from time to time receive services from retirement plan service providers, including Platform Providers, which are intended to help us manage and further develop our business enterprise. These services may include: + educational conferences ad events + publications, conferences and presentations on practice management, compliance, and marketing Retirement plan service providers may also: + make available, arrange and/or pay for these types of services to our firm by independent third parties + discount or waive fees it would otherwise charge for some of these services + pay all or a part of the fees of a third-party providing these services to our firm We may also receive other benefits from retirement plan service providers, such as occasional business entertainment of our personnel. IMA uses the services of the CFP Board’s “Find Your CFP Professional” search to match prospective advisory clients with investment advisers in exchange for a non-success-based fee paid by IMA for engaging advisory services. ITEM 15 CUSTODY We do not have custody of assets held in qualified and/or non-qualified deferred compensation Plans. We are not able to directly deduct our fee for advisory services provided to a Plan (as described in this Brochure) directly from the Plan assets. 13  Item 15 Custody (continued) The Plan custodian maintains actual custody of Plan assets. Plan sponsors have direct access to Plan information and balances through their arrangement with the Plan custodian. ITEM 16 INVESTMENT DISCRETION IMA Retirement typically agrees to provide investment advice on either a non-discretionary or discretionary basis. The written Advisory Agreement we enter with the Plan Sponsor specifies the capacity in which we have been engaged. Non-Discretionary Investment Advice We will accept a non-discretionary arrangement under ERISA §3(21)(A)(ii). We provide investment advice with respect to the specific investments we recommended to you and only to the extent that our investment recommendations are actually implemented by the Plan sponsor. The Plan fiduciary, under this arrangement, retains sole responsibility for determining whether to implement any recommendations from us. The Plan sponsor is not required to implement any of the recommendations or otherwise conduct business through us and we have no responsibility for decisions made by the Plan sponsor that are inconsistent with our advice. Discretionary Investment Advice We may also serve as an investment manager for a Plan within the meaning of ERISA § 3(38). Under the investment advisory agreement, our fiduciary responsibilities are limited to those of an investment manager and do not include any other trustee responsibility as that term is defined under ERISA § 405(c)(3). We maintain a fidelity ERISA bond that covers our services as an investment manager to the extent required by ERISA. The Plan’s investment guidelines and restrictions must be provided to us in writing. When we provide investment advice to a Plan on either a discretionary or non-discretionary basis, we observe written investment policies, limitations and restrictions established for the Plan. Plan sponsors may change or amend these investment policies, limitations and restrictions as required. Amendments must also be provided to us in writing. 14  ITEM 17 VOTING CLIENT SECURITIES IMA Retirement does not vote client securities. ITEM 18 FINANCIAL INFORMATION Not applicable. 15  About IMA Financial Group Based in North America, IMA Financial Group, Inc. is an integrated financial services company focused on protecting the assets of its widely varied client base through insurance, risk management, employee benefits, and wealth management solutions. As an employee-owned company, IMA’s 3,000-plus associates are empowered to provide customized solutions for their clients’ unique needs. Please visit http://imacorp.com/terms-service/ to review our full privacy and compensation disclosure statements. IMACORP.COM 

SYNTRINSIC BROCHURE IMA ADVISORY SERVICES, INC. DBA SYNTRINSIC, AN IMA COMPANY March 31, 2026 Corporate Address: 1705 17th Street, Suite 100, Denver, Colorado 80202 303.296.7100 | www.syntrinsic.com Contact: Valerie Ruppel, valerie.ruppel@imacorp.com This brochure provides information about the qualifications and business practices of IMA Advisory Services, Inc., (IMAAS) doing business as Syntrinsic. If you have any questions about the contents of this brochure, please contact us at 303.296.7100 or valerie.ruppel@imacorp.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about IMAAS also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. IMAAS’ CRD number is 112091. References herein to IMAAS as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training. IMACORP.COM  ITEM 2 MATERIAL CHANGES Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our March 31, 2025 amendment, this Brochure contains updated information regarding our assets under management. 1  ITEM 3 TABLE OF CONTENTS ITEM 2 MATERIAL CHANGES .................................................................................................................................. 1 ITEM 3 TABLE OF CONTENTS ................................................................................................................................. 2 ITEM 4 ADVISORY BUSINESS .................................................................................................................................. 3 ITEM 5 FEES AND COMPENSATION ..................................................................................................................... 4 ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................ 6 ITEM 7 TYPES OF CLIENTS ....................................................................................................................................... 6 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................. 6 ITEM 9 DISCIPLINARY INFORMATION ................................................................................................................ 9 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................... 9 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................................................................................................................... 11 ITEM 12 BROKERAGE PRACTICES ........................................................................................................................ 12 ITEM 13 REVIEW OF ACCOUNTS ......................................................................................................................... 17 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION .................................................................... 17 ITEM 15 CUSTODY .................................................................................................................................................... 18 ITEM 16 INVESTMENT DISCRETION ................................................................................................................... 18 ITEM 17 VOTING CLIENT SECURITIES ................................................................................................................ 19 ITEM 18 FINANCIAL INFORMATION .................................................................................................................. 19 2  ITEM 4 ADVISORY BUSINESS IMA Advisory Services, Inc. (IMAAS), doing business as Syntrinsic (“Syntrinsic,” “we” or “us”) is an SEC- registered investment adviser based in Denver, Colorado. IMA Advisory Services, Inc. ("IMA Advisory Services", "we", or "us") is a registered investment adviser headquartered in Denver, Colorado, with offices in California, Kansas, Texas, Georgia, Utah and Massachusetts. We are organized as a corporation under the laws of the State of Kansas and have been providing investment advisory services since 1999. As of October 2023, we are wholly owned by IMA Advisors, a wholly owned subsidiary of IMA Financial Group, Inc. Services Described in this Brochure IMA Advisory Services has three brochures describing our services. This brochure focuses on the services provided by Syntrinsic. Syntrinsic began as an independent registered investment adviser, founded in August 2008 as Syntrinsic Investment Counsel LLC. In 2023, Syntrinsic Investment Council was acquired by Advisors LLC (“IMA Advisors”), which is a wholly owned subsidiary of IMA Financial Group, Inc. (“IMA”). In January 2025, Syntrinsic merged with its affiliate IMA Advisory Services though continues to operate as an independent business unit, providing continuous services to its clients. Advisory services provided to employers on qualified and non-qualified retirement plans or our Investment Supervisory and financial planning services are described in separate brochures. If you are interested in receiving the brochure that describes our retirement plan consulting services, please contact our office at 303.296.7100. About Syntrinsic Advisory Services Syntrinsic develops, implements, and monitors customized investment portfolios for endowments, foundations, nonprofit organizations and private clients committed to using their financial resources for good. Our goal is to co-create a sustainable and generative world that empowers all people. Clients can elect to engage us in a non-discretionary, partial discretionary, or full discretionary basis. Our investment advisory fee can be based upon a percentage of assets, a fixed amount, or a hybrid that uses a fixed amount and a percentage of assets. Our core services include: + Investment Policy Statement Review and Development + Capital Markets Forecasting + Manager, Search, and Selection (Traditional, Alternative, Values Aligned) + Portfolio Development/Asset Allocation Strategy + Portfolio Implementation 3  Item 4 Advisory Business (continued) + Third-party custodian interface + Performance Reporting + Trading and transfer facilitation + Business Strategy + Client Stakeholder Relations + Education for Trustees, Staff, and other Client Stakeholders + Values Aligned Investing We provide investment advisory services specific to the needs of each client. We meet with clients to identify investment objective(s), then develop investment portfolios that strive to meet those objectives over an appropriate time frame. The client may, at any time, request reasonable restrictions, in writing, which we may accept if we feel they are consistent with our fiduciary duty/consistent with the client’s best interests. Assets under Management As of December 31, 2025, IMAAS maintains total regulatory assets under management of $3,901,795,952 of which $557,197,021 are non-discretionary. Assets Under Advisement (“AUA”) may appear in client and sales materials in addition to IMAAS’ regulatory Assets Under Management (“AUM”). AUA is presented when, due to the nature of the contractual agreements with certain clients, we provide consultative advice to our clients in a non- discretionary capacity and do not maintain discretionary authority over the clients’ portfolios(s). In such relationships, the clients maintain the ability and authority to manage and allocate assets within their own portfolio(s) independent of our advice. Therefore, these clients are not reflected within regulatory assets under management. Instead, these engagements are represented as part of our AUA. In the instance that AUA is listed in client or sales materials it will be accompanied by relevant disclosure indicating how AUA has been calculated. ITEM 5 FEES AND COMPENSATION Clients pay Syntrinsic a fee for investment advice. The fee is either fixed, based on percentage of the assets under advisement, or a combination of both. We set fees in discussions with the client based on a variety of factors, including size, complexity, and service needs. Any additional investment-related fees are described below. 4  Item 5 Fees and Compensation (continued) Syntrinsic Community is available for an annual fixed fee, depending on the size and complexity of the client. Fee Calculations In order to calculate our fee, we rely on quarter or month end values as reported through our performance reporting and portfolio monitoring software. While these values may vary from quarter or month-end values as reported on custodial statements due the timing of trade settlement, security price variation, dividend and interest payments, and other factors, it ensures that there is alignment between data used for billing and for performance reporting. We urge clients to review and compare this data with their custodial statements and contact us with any questions. Both our Investment Advisory Agreement and the custodial/clearing agreement may authorize the custodian to debit the account for the amount of our investment advisory fee and to directly remit that management fee to us. In the event that we bill the client directly, payment is due upon receipt of our invoice. We deduct fees and/or bill clients quarterly, and in rare cases monthly, in advance, based upon the market value of the assets on the last business day of the previous quarter. We generally recommend that clients use either Pershing Advisor Solutions, LLC (“Pershing”), Fidelity Institutional Wealth Services (“Fidelity”) and/or Charles Schwab and Co., Inc. (“Schwab”) as the broker- dealer/custodian for client assets. If the client requests otherwise, we can work with clients to custody assets at other broker-dealers/custodians. Broker-dealers charge brokerage commissions and/or transaction fees for effecting certain securities transactions (i.e. transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and fixed income securities transactions). In addition to our investment advisory fee and the custodian’s brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange-traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). In addition, if a client decides to retain a separate account investment manager, then Pershing, Fidelity, Schwab, and/or another custodian will charge a fee for custody and trading in addition to the manager’s fee and separate from our fees. The fees, if any, charged by broker- dealers, are not shared with Syntrinsic. Please refer to Item 12 of this Brochure for additional information about how clients can access brokerage services. Our annual investment advisory fee is prorated and paid quarterly or monthly, in advance, based upon the market value of the assets on the last business day of the previous quarter. If circumstances require, fees can be paid in arrears. Our asset-based fees are generally based on the following guidelines: MARKET VALUE OF PORTFOLIO First $10,000,000 Next $40,000,000 Next $50,000,000 Above $100,000,000 Market Value of Portfolio % OF ASSETS Up to 1.00% Up to 0.50% Up to 0.35% Up to 0.25% % of Assets 5  Item 5 Fees and Compensation (continued) Neither we nor our personnel accept compensation from the sale of securities or other investment products. We do not have any soft dollar arrangements with any custodian, and neither we nor our personnel accept direct or indirect compensation or gifts from investment management firms. We pay the costs of our research and due diligence. ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance- based fees. ITEM 7 TYPES OF CLIENTS Our clients generally include charitable organizations, trusts, estates, individuals, family partnerships, and retirement plans. While we strive to serve clients with assets in excess of $15 million, we may elect to serve clients with assets below that level in our discretion. ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS We may use the following methods of economic analysis: Capital Markets Forecast On an annual basis, we forecast the long-term (ten year) return of major assets class and market segments using a building blocks method to establish reasonable expectations. In addition, we craft a near-term (less than three years) sentiment that strives to identify potential return and risk factors across asset classes and geographic regions. We provide this Capital Markets Forecast to all clients at 6  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) least annually and may provide additional updates as conditions warrant. A copy of the most recent Capital Markets Forecast is available upon request. Asset Allocation Analysis We assist clients in determining the suitability of multiple asset classes and styles, and we recommend asset allocation blends that to strive to meet the organization’s spending and growth objectives, risk tolerance, time horizon, impact objectives, and other key factors. We use efficient frontier modeling, Monte Carlo analysis, and other analytic tools to support the crafting of asset allocation blends. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, market sector, or asset class. Another risk is that the ratio between asset classes will change over time due to market movements and, if not corrected, will no longer be appropriate for the client’s goals. Third-Party Manager Analysis When implementing client portfolios, we rely upon accessing third-party investment managers that may be structured as separate account managers, mutual funds, exchange traded funds, or private placements. In all cases, regardless of structure, we employ a multi-factor process, to consider the quality of an investment company, portfolio management team, investment strategy, and historic performance in an attempt to determine if that manager has demonstrated an ability to invest effectively over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations and leverage as part of its overall periodic risk assessment. Additionally, as part of the due-diligence process, we survey the manager’s compliance and business enterprise risks. A risk of investing with a third-party manager who has been successful in the past is that the portfolio manager may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for clients. Moreover, as we do not control the manager’s daily business and compliance operations, it is possible for Syntrinsic to miss the absence of internal controls necessary to prevent business, regulatory or reputational deficiencies. Risks for all forms of analysis – Our method of analysis relies on the assumption that publicly- available sources of economic, market, and the investment manager information 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. We don’t trade at high frequency, and generally purchase investments with the intent of holding them for a year or longer, barring changes in our analysis or in the clients’ objectives and risk tolerance. Security investments are not guaranteed and all may result in losses. 7  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) We may utilize the following investment strategies when implementing investment advice given to clients: Long Term Purchases – we purchase investments with the idea of holding them in the client’s account for a year or longer. We might do this because we want exposure to a particular asset class over time, regardless of the current projection for this class. Despite this intention, we may recommend that a client reduce or terminate an investment that has been held for less than a year if deemed appropriate given the firm’s analysis and/or changes in the client’s objectives and risk tolerance. A risk in a long-term purchase strategy is that by holding the investment 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, an investment may decline sharply in value before we make the decision to sell. Risk of Loss For All Investments – Security investments are not guaranteed and may result in losses. Clients are asked to communicate with Syntrinsic on their current risk tolerance level. Unaffiliated Private Investment Funds: Syntrinsic also provides investment advice regarding private investment funds. We may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts, and fees, including incentive compensation) is in the fund’s offering documents. If a client decides to invest in an unaffiliated private fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Syntrinsic calculating its investment advisory fee. Syntrinsic’s fee shall be in addition to the fund’s fees. Syntrinsic’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including but not limited to potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client owns, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he or she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please also note, Valuation: If Syntrinsic displays private investment funds owned by the client on any supplemental account reports prepared by Syntrinsic, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if the fund has not provided an updated valuation after purchase, the valuation shall reflect the initial purchase price until the fund provides an updated valuation. Please also note: As a result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless 8  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss (continued) otherwise indicated, Syntrinsic shall calculate its fee based upon the most recent value provided by the fund sponsor. Use of Alternative Intelligence (“AI”) and Related Risks We rely on certain third party service providers that use artificial intelligence (“AI”) tools in systems supporting research, data management, and other operational functions. Our personnel may also use AI enabled tools for operational and administrative purposes. We do not use AI to make or implement investment decisions, and all advisory judgments remain subject to human oversight. AI tools may present risks, including errors resulting from inaccurate or incomplete data, potential model bias, programming flaws, or cybersecurity vulnerabilities. As regulatory expectations for AI continue to evolve, future rule changes may affect how AI can be used or supervised by investment advisers. Because AI use is becoming more widespread across the financial industry, reliance on similar models or data sources may contribute to correlated or systemic risks, particularly during periods of market stress. We mitigate these risks by maintaining human oversight of any activities involving AI and by assessing vendor controls, data handling practices, and system security. ITEM 9 DISCIPLINARY INFORMATION We have no disciplinary information to report under this item. ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS IMA Advisory Services, Inc. is owned by IMA Advisors which is wholly owned by IMA Financial Group, Inc. (“IMA”). IMA has numerous subsidiary corporations which are engaged in retail, wholesale and specialty insurance operations. If you need professional insurance services for yourself or your business, we will refer you to IMA and its subsidiaries. Should insurance products be purchased as a result of this referral, IMA Advisory Services’ associated persons could be eligible to receive a percentage of the commissions generated by these sales. You are not obligated in any way to use IMA and its subsidiaries to purchase insurance products. 9  Item 10 Other Financial Industry Activities and Affiliations (continued) IMA Advisors is also the parent company to TRG Investment Advisers, LLC, (“TRGIA”). TRGIA provides investment advisory services to individuals and retirement plans. If you wish to engage these services, we will refer you to TRGIA. You are not obligated in any way to use TRGIA or the services they offer. IMA Advisors is also the parent company to IMA Executive Benefits and Life Insurance LLC. (“IMA EXLI”) IMA EXLI and IMA Advisory Services are also each a registered insurance agency. Certain employees are licensed to sell life health, disability, and long-term care insurance. As such, these employees may recommend that a client (in his or her separate capacity as an insurance customer) buy insurance products which are entirely separate from investments made for the client's managed account. For these separate insurance recommendations, the employees will receive customary insurance compensation. Clients, however, are not under any obligation to engage these employees when considering implementation of insurance recommendations. The possibility of receiving additional compensation from selling insurance products to a client provides an economic incentive for an employee to recommend these products based on the compensation to be received rather than on a client’s investment needs. This is a conflict of interest that clients should consider. We have adopted the following steps to address this conflict of interest in this situation: + we disclose the existence of the conflict of interest that arises from the incentive an employee has to earn additional compensation from recommending the purchase of insurance products over and above the advisory fees we receive, and we endeavor to act consistent with our fiduciary duty; + we disclose to clients they have the right to decide whether or not to act on such recommendations; + we request clients to provide and update material information regarding their personal and financial situation, and the investment objective, tolerance for risk, liquidity needs, and investment time horizon for the advisory account that will be managed by us, and we conduct regular reviews of account investments; + we require that our employees seek prior approval of outside employment activity so that we may detect conflicts of interests and ensure such conflicts are properly addressed; + we periodically ask employees to certify information regarding their disclosed outside employment activities; and + we educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. If you wish to purchase these products, we will offer them to you as an agent or producer of IMA EXLI or IMA Advisory Services’ insurance agency. If you purchase these products through IMA Advisory Services’ insurance agency our associated persons are eligible to receive a percentage of the commissions generated by these sales. These referrals and payments are made pursuant to agreements between IMA Advisory Services, and such individuals. You are not obligated to use IMA Advisory Services to purchase insurance products if you are a client of IMA Advisory Services. 10  Item 10 Other Financial Industry Activities and Affiliations (continued) Please see Item 14 (“Client Referrals and Other Compensation”) for information about other referral arrangements between IMA Advisory Services, Inc. and its affiliates. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Description of Our Code of Ethics We have adopted a Code of Ethics expressing our commitment to ethical conduct. Our Code of Ethics describes our fiduciary responsibilities to our clients, and our procedures in supervising the personal securities transactions of our supervised persons who have access to information regarding client recommendations or transactions (“access persons”). A copy of our Code of Ethics is available to our clients and prospective clients. You may request our Code of Ethics by contacting us at the number listed on the cover page of this brochure. We owe a duty of loyalty, fairness, and good faith towards our clients and have an obligation to adhere not only to the specific provisions of the Code of Ethics however also to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of our access persons’ quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by our access persons. Among other things, our Code of Ethics also requires the prior approval of any equity or fixed income securities transactions, any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our Code also provides for oversight, enforcement, and recordkeeping provisions. Our Chief Compliance Officer may grant exceptions to certain provisions contained in the Code where we reasonably believe the interests of our clients will not be materially adversely affected or compromised. Doubts arising in connection with personal securities trading should be resolved in favor of the client even at the personal expense of our employees. Our Code of Ethics prohibits the misuse of material non-public information. While we do not believe that we have any access to material non-public information regarding publicly traded companies that would be subject to misuse, all employees are reminded that any such information may not be used in a personal or professional capacity. IMA Advisory Services. and its principals, officers, affiliates, employees, and advisors may act as investment adviser for others, may manage funds or capital for others, may have, make and maintain investments in its or their own names, or may serve as an officer, director, consultant, partner, or stockholder of one or more investment partnerships or other businesses, subject to compliance with our Code of Ethics. In doing so, IMA Advisory Services, or such 11  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading (continued) persons may give advice, take action, and refrain from taking action, any of which may differ from advice given, action taken or not, or the timing of any action, for any particular client. Protecting the confidentiality of our clients’ nonpublic information is important to us. We have instituted policies and procedures to ensure that nonpublic customer information is kept confidential. We do not disclose nonpublic personal information about our clients or former clients to any non- affiliated third parties, except as provided pursuant to our privacy policies or as required by or permitted by law. In the course of servicing a client’s Account, we may share client information with service providers, such as custodians, transfer agents, accountants, and attorneys. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. ITEM 12 BROKERAGE PRACTICES Brokerage Generally In the event that a client requests that we recommend a broker-dealer/custodian for execution and/or custodial services (exclusive of those clients that may direct us to use a specific broker- dealer/custodian), we generally recommend that investment management accounts be maintained at Pershing, Fidelity and/or Schwab. Prior to engaging us to provide investment management services, the client will be required to enter into an Investment Advisory Agreement with us setting forth the terms and conditions under which we manage the client's assets, and a separate custodial/clearing agreement with each designated broker- dealer/custodian. Factors that we consider in recommending a broker-dealer/custodian to clients include historical relationship with Syntrinsic, client type, financial strength, reputation, execution capabilities, pricing, and service. Consistent with our duty to obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where we determine, in good faith, that the commission/transaction fee is reasonable in relation to the value of the brokerage services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, we may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are exclusive of, and in addition to, our investment management fee. 12  Item 12 Brokerage Practices (continued) Additional Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, we may receive from Pershing, Fidelity and/or Schwab (or another broker-dealer/custodian) without cost (and/or at a discount) support services and/or products, certain of which assist us to better monitor and service client accounts maintained at such institutions. Others do not directly provide such assistance, but rather assist us to manage and further develop our business enterprise. Clients do not pay more for investment transactions affected and/or assets maintained at Pershing, Fidelity and/or Schwab as a result of these arrangements. There is no corresponding commitment made by Syntrinsic to Pershing, Fidelity and/or Schwab or any other entity to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangements. Pershing We may recommend/require that clients establish brokerage accounts with Pershing Advisor Solutions LLC (“PAS”) of One Pershing Plaza, 95 Christopher Columbus Drive, Jersey City, New Jersey 07399, a FINRA registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although we may recommend/require that clients establish accounts at PAS, it is the client’s decision to custody assets with PAS. IMAAS is not affiliated with PAS. For client accounts maintained in its custody, PAS generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through PAS or that settle into PAS accounts. PAS also makes available to Syntrinsic other products and services that benefit Syntrinsic but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of our accounts, including accounts not maintained at PAS. PAS’s products and services that assist us in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of our fees from clients’ accounts; and (v) assist with back- office functions, recordkeeping and client reporting. PAS also offers other services intended to help us manage and further develop our business enterprise. These services may include (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. PAS may make available, arrange and/or pay third-party vendors for the types of services rendered to us. PAS may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to us. PAS may also provide other benefits such as educational events to our personnel. In evaluating whether to recommend or require that clients custody their assets at PAS, we may take into account the availability of some of the foregoing products and services and other 13  Item 12 Brokerage Practices (continued) arrangements as part of the total mix of factors it considers and not solely on the nature, cost or quality of custody and brokerage services provided by PAS, which may create a potential conflict of interest. National Financial Services, LLC We have an arrangement with National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which Fidelity provides us with Fidelity's "platform" services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like Syntrinsic in conducting business and in serving the best interests of their clients but that may benefit Syntrinsic. Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Fidelity enables us to obtain some no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to Syntrinsic, at no additional charge to Syntrinsic, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by Syntrinsic (within specified parameters). We may also receive additional services which may include educational events, consulting on practice management items including technology, compliance, and business procedures. Without this arrangement, we might be compelled to purchase the same or similar services at its own expense. As a result of receiving such services for no additional cost, we may have an incentive to continue to use or expand the use of Fidelity's services. We examined this potential conflict of interest when we chose to enter into the relationship with Fidelity and have determined that the relationship is in the best interests of our clients and satisfies our client obligations, including our duty to seek best execution. A client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. Although the services that we may obtain will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for services that are not used in managing that specific client’s account. IMAAS and Fidelity are not affiliates. 14  Item 12 Brokerage Practices (continued) Schwab Advisor Services Schwab Advisor ServicesTM (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like Syntrinsic. They provide us and our clients with access to its institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we do not have to request them) and at no charge to us. The following is a more detailed description of Schwab’s support services: Services that benefit clients: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which the client might not otherwise have access or that would require a significantly higher minimum initial investment by Clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Services that may not directly benefit clients: Schwab also makes available to Syntrinsic other products and services that benefit Syntrinsic but may not directly benefit individual clients or their accounts. These products and services assist in managing and administering clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that provides access to client account data (such as duplicate trade confirmations and account statements) to: + Facilitate trade execution and allocate aggregated trade orders for multiple client accounts + Provide pricing and other market data + Facilitate payment of our fees from clients’ accounts + Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Syntrinsic: Schwab also offers other services intended to help Syntrinsic manage and further develop its business. These services include: + Educational conferences and events + Consulting on technology, compliance, legal, and business needs + Publications and conferences on practice management and business succession + Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Syntrinsic. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. 15  Item 12 Brokerage Practices (continued) Syntrinsic’s interest in Schwab’s services: The availability of these services from Schwab benefits is because we do not have to produce or purchase them. We do not have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. We may have an incentive to recommend that clients maintain their accounts with Schwab based on our interest in receiving Schwab’s services that benefit our business rather than based on the clients’ interest in receiving the best value in custody services and the most favorable execution of their transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as a custodian and broker is in the best interests of clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only Syntrinsic. Referral Fees From Broker-Dealers We do not receive referrals from broker-dealers. Directed Brokerage As we do not have the discretionary authority to determine the broker dealer to be used or the commission rates to be paid, clients must direct us as to the broker dealer to be used. In the event that a client requests that we recommend a broker-dealer/custodian for execution and/or custodial services, we generally recommend that investment management accounts be maintained at Pershing, Fidelity and/or Schwab, as we have evaluated these broker-dealers versus other competitors in the landscape and believe they will provide clients with a blend of execution services, commission costs and professionalism that will assist us in meeting our fiduciary obligations to our clients. In client-directed arrangements in which the client selects an alternative broker-dealer, the client will negotiate terms and arrangements for their account with that broker-dealer, and we will not seek better execution services or prices from other broker-dealers or be able to “batch” the client's transactions for execution through other broker-dealers with orders for other accounts we manage. As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Please Note: In the event that a client directs us to effect securities transactions for the client's accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through Syntrinsic. Trade Aggregation To the extent that we implement our investment recommendations to our clients, the transactions for each client account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) aggregate or “bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in 16  Item 12 Brokerage Practices (continued) proportion to the purchase and sale orders placed for each client account on any given day. We do not receive any additional compensation or remuneration as a result of such aggregation. ITEM 13 REVIEW OF ACCOUNTS We strive to meet with clients via phone or in person at least annually to review their objectives, investment portfolio, and market conditions to ensure continued alignment of the client’s investment strategy. From time-to-time, we prepare written recommendations and research pieces that help inform clients and serve as an opportunity for client feedback. Clients are asked regularly to inform us of any changes in their investment objectives and/or financial situation. We may review accounts based on a triggering event, such as a change in client investment objectives and/or financial situation, market corrections, or by client request. Clients get a quarterly written report with transaction confirmation notices and regular summary account statements directly from the broker-dealer/custodian for the client accounts. We may also provide a written periodic report summarizing account activity and performance. You should always compare any report we provide to your custodial statements. ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION Client Referrals Some of our affiliated individuals also earn compensation based on (1) acquisition and retention of investment advisory client assets under management and (2) advisory fees paid to IMA Advisory Services. Should referred clients decide to hire us, these individuals will receive compensation. This is a conflict of interest because these affiliated individuals have an economic incentive to recommend our advisory services. Economic Benefit from Schwab We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts with Schwab. The availability to us of Schwab’s products and services is not based on us giving advice concerning any particular investment, such as buying particular securities for our clients. 17  Item 14 Client Referrals and Other Compensation (continued) Referral Arrangements with Third Parties We can recommend other investment advisers for our clients. For this referral, we will receive a portion of the fee paid to the other advisor for the referral. Clients are advised of this payment when considering whether to invest with the other investment adviser. The payment provides an incentive to recommend the other adviser based on the share of fees received rather than based solely on the client’s investment needs. ITEM 15 CUSTODY We do not maintain physical custody of client assets; all client assets are held in custody with a qualified custodian. We are deemed to have custody because for certain clients we have authority to effect third party transfers from client accounts pursuant to standing letters of authorization and have permission from many clients to debit advisory fees from their accounts. Clients receive written transaction confirmation notices and regular account statements directly from the broker-dealer/custodian. We may also provide a written periodic report summarizing account activity and performance. The account custodian does not verify the accuracy of our advisory fee calculation. We urge clients to carefully review and compare these account statements. ITEM 16 INVESTMENT DISCRETION We offer clients three levels of discretion. The level selected for each client is indicated on the client’s Investment Advisory Agreement. Non-Discretionary In non-discretionary engagements, we make recommendations to the client on both asset class allocation and investment manager selection. The client makes the ultimate decision on both the allocation and managers prior to implementation. Partial Discretionary In partial discretionary engagements, we make recommendations on the client’s asset class allocation, with the client making the final decision. We are responsible for selecting investment managers to implement the asset allocation. 18  Item 16 Investment Discretion (continued) Full Discretionary We clients engage us on a full discretionary basis, we are responsible for selecting an appropriate asset class allocation consistent with the client’s spending and growth objectives, risk tolerance, time horizon, and other key factors. In addition, we are responsible for selecting investment managers to implement the asset allocation. ITEM 17 VOTING CLIENT SECURITIES As outlined in the client’s Investment Advisory Agreement with Syntrinsic, the client either accepts responsibility for voting proxies and legal actions, bankruptcies, class actions/proofs of claim or can assign this responsibility to Syntrinsic. In some cases, a client might assign proxy voting responsibility to a third party investment manager or outside proxy voting firm. + If the client chooses to keep this responsibility, the client maintains exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities owned by the client will be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s assets. + If the client chooses to assign this responsibility to Syntrinsic, Syntrinsic will cast votes on behalf of the Client in accordance with our written policies and procedures. Proxies, legal actions, and all notices are sent directly from the custodians. Clients may contact Syntrinsic for further information. ITEM 18 FINANCIAL INFORMATION Not applicable. 19  About IMA Financial Group Based in North America, IMA Financial Group, Inc. is an integrated financial services company focused on protecting the assets of its widely varied client base through insurance, risk management, employee benefits, and wealth management solutions. As an employee-owned company, IMA’s 3,000-plus associates are empowered to provide customized solutions for their clients’ unique needs. Please visit http://imacorp.com/terms-service/ to review our full privacy and compensation disclosure statements. IMACORP.COM