KLAAS FINANCIAL ASSET ADVISORS, LLC.

Disclosure Brochure Form ADV Part 2A (Klaas 360) to approximately 24 client consulting services households. Klaas Financial Asset Advisors, LLC 4707 Perry Ridge Lane Loves Park, IL 61111 Firm CRD No. 121399 Currently, our brochure may be requested by contacting us at (877) 495-5227 or info@klaasfinancial.com. The brochure is also available on our website at www.klaasfinancial.com. We will provide you with a copy of our current brochure at any time without charge. August 26, 2025 Item 1. Cover Page Information about each of our Investment Adviser Representatives may be found in their respective Form ADV Part 2B Brochure Supplement, which can also be found on our website at www.klaasfinancial.com. This brochure provides information about the qualifications and business practices of Klaas Financial Asset Advisors, LLC (Klaas). If you have any questions about the contents of this brochure, please contact us at (877) 495-5227 or by email at info@klaasfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Klaas is a registered investment adviser registered with the SEC. Registration as an investment adviser does not imply any level of skill or training. Additional information about Klaas is also available on the SEC’s website at www.adviserinfo.sec.gov by conducting a Firm search using our Firm CRD No. 121399. Item 2. Material Changes We deliver our Disclosure Brochure initially when we enter into an advisory agreement with you. The Disclosure Brochure will be updated no less than annually within 90 days of our December 31 fiscal year end. Within 120 days of our fiscal year end, we will deliver to you a summary of material changes which have been made to our Disclosure Brochure since its last annual update. This summary will include information about how you may obtain a complete copy of our updated Disclosure Brochure at no charge, and it will include the date of the last annual update. We will provide updated disclosure information about material changes more frequently as needed. Since the last annual update to our Disclosure Brochure dated March 28, 2025, we have made the following material changes:  As of the date of this Disclosure Brochure, we have amended our Klaas 360 services and fees. We offer ongoing Comprehensive Financial Planning Services for a monthly fee based on investable assets, or Project-Based Financial Consulting Services on a fixed- fee basis. Please see Item 4, Advisory Business, and Item 5, Fees and Compensation for more information. We have made edits as necessary to correct typographical or grammatical errors, or to provide clarification where necessary. We do not consider these changes to be material. Item 3. Table of Contents Item 1. Cover Page ...................................................................................... 1 Item 2. Material Changes ........................................................................... 1 Item 3. Table of Contents ........................................................................... 1 Item 4. Advisory Business .......................................................................... 1 Klaas Investment Portfolios (KIP) — Wrap Fee Program ................. 2 Klaas 360 — Financial Planning and Consulting .............................. 2 Tax Preparation Services ..................................................................... 2 Financial Institution Consulting Services .......................................... 2 Klaas 401K — Retirement Plan Services ............................................. 2 Item 5. Fees and Compensation ............................................................... 3 KIP Wrap Fee Program Fees............................................................... 3 Klaas 360 Financial Planning and Consulting Fees ........................ 3 Tax Preparation Services ..................................................................... 4 Financial Institution Consulting Services Fees ................................. 4 Klaas 401K Fees .................................................................................... 4 Other Compensation ........................................................................... 5 Item 6. Performance-Based Fees .............................................................. 5 Item 7. Types of Clients .............................................................................. 5 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss . 5 Methods of Analysis ............................................................................. 5 Investment Strategies .......................................................................... 5 Risks ........................................................................................................ 5 Risks of Specific Securities .................................................................. 5 Item 9. Disciplinary Information ................................................................ 6 Item 10. Other Financial Industry Activities and Affiliations ................. 6 Item 11. Code of Ethics; Participation or Interest in Client Transactions and Personal Trading .......................................................................... 6 Item 12. Brokerage Practices..................................................................... 7 Item 13. Review of Accounts ..................................................................... 7 KIP Wrap Fee Program ........................................................................ 7 Klaas 360 ............................................................................................... 7 Financial Institution Consulting Services .......................................... 7 Klaas 401K ............................................................................................. 7 Item 14. Client Referrals and Other Compensation .............................. 7 Item 15. Custody ......................................................................................... 8 Item 16. Investment Discretion ................................................................. 8 Item 17. Voting Client Securities ............................................................... 8 Item 18. Financial Information ................................................................... 8 Item 4. Advisory Business Klaas Financial Asset Advisors, LLC (Klaas) is located in Loves Park, Illinois and Fitchburg, Wisconsin. The firm’s shareholders are Craig J. Klaas, Maleeah L. Wernsing-Cuevas, Kyle A. Kite, Eric J. Schwartz, Joshua E. Stirling, and Nathan A. Breiby. As of June 30, 2025, we provided investment advisory services on approximately $757 million in client assets for more than 1,000 client households. This total represents approximately $699 million in client assets under management through our discretionary asset management wrap fee program (Klaas Investment Portfolios – KIP), approximately $30 million in retirement plan assets through our retirement plan services (Klaas 401K) for 18 retirement plans, and approximately $28 million in assets under advisement through our non-discretionary Klaas Investment Consulting Services for brokerage financial planning and customers. Furthermore, we provided Page 1 of 8 Rev. 08-26-2025  o Assisting heirs of a deceased client with determining options for the assets they have inherited. Klaas is registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC). Our services include: reducing debt, establishing o Developing a plan  o for emergency savings, and future retirement savings. Providing guidance on educational funding options and establishing 529 plan accounts.   Klaas Investment Portfolios (KIP) — Wrap-fee program offering discretionary portfolio management Klaas 360 — Financial planning and consulting services Klaas Investment Consulting Services — Non-discretionary advisory services to brokerage customers Klaas 401K — Retirement plan services  Depending on your specific needs, we will help develop strategies and provide recommendations for actionable steps to implement your strategies and help achieve goals. Klaas Investment Portfolios (KIP) — Wrap Fee Program We will deliver our analysis and recommendations verbally or in writing, during an in-person meeting, by telephone, by video conference, or by other means as agreed to by the parties. You may seek clarifications or present additional questions within thirty (30) days following the delivery. We will have an additional thirty (30) days after any such inquiries, up to a maximum of (60) days from delivery, to resolve any outstanding questions you may have. Klaas Investment Portfolios (KIP) is the brand name under which we offer discretionary portfolio management services and financial planning through the KIP Wrap Fee Program on a wrap-fee basis. Details about the KIP Wrap Fee Program, including fees, is more fully described in the Wrap Fee Program Brochure, which is available upon request, or which can be found by visiting our website at www.klaasfinancial.com. Project-Based Financial Planning and Consulting Services are point- in-time advice, and we do not provide any ongoing monitoring or implementation of our recommendations. Tax Preparation Services As of June 30, 2025, within the KIP Wrap Fee Program, we provided discretionary asset management on approximately $699 million in client assets for more than 1,000 client households. Discretionary asset management means we have the authorization to make investment decisions on behalf of our clients. Klaas 360 — Financial Planning and Consulting Klaas 360 is the brand name under which we provide financial planning and consulting services. Clients who wish to obtain these services will enter into a financial planning agreement (Klaas 360 Agreement) with us. Comprehensive Financial Planning Services Clients who engage our KIP or Klaas 360 services may also choose to receive tax preparation services for an additional fee. Clients are not required to use our Tax Preparation Services and may choose another tax professional. A separate tax engagement agreement is required for each tax year. An IRS-enrolled tax professional will prepare your federal and state income tax returns from information you furnish to us. We will not audit or otherwise verify the data you submit, although it may be necessary to ask you for clarification of some of the information. Financial Institution Consulting Services financial projections, and financial Through discussions, interviews, and questionnaires, we will gather sufficient information to develop a written financial plan tailored to your needs, which may include investment guidance, ongoing goals- review meetings. based Comprehensive Financial Planning Services will cover all topics relevant to your financial circumstances, and may include retirement planning, Social Security optimization, risk management (life, disability, long-term care, health, home, auto, and umbrella insurance coverage), college savings, cash flow and debt management, work benefits, and estate and incapacity planning. We have entered into an agreement with Mutual Securities, Inc. (Mutual Securities), a registered broker-dealer, member FINRA, SIPC, to provide non-discretionary investment consulting services to certain of Mutual Securities’ brokerage customers (Brokerage Customers). Brokerage Customers who elect this service provide written consent to Mutual Securities for us to provide services, and enter into a non-discretionary investment consulting agreement (Consulting Agreement) with us. For our services under the Consulting Agreement, we offer to provide Brokerage Customers with periodic reviews, analysis, and recommendations regarding their holdings with Mutual Securities. The Brokerage Customers are solely responsible for all decisions relating to the implementation of the advice we provide. We will deliver your comprehensive financial plan, including analysis and recommendations, to you verbally or in writing, during an in- person meeting, by telephone, by video conference, or by other means as agreed to by the parties. Comprehensive Financial Planning Services include access to Klaas Portal, a comprehensive web-based financial planning platform. As of June 30, 2025, we provided non-discretionary advice on approximately $28 million in assets under the Klaas Investment Consulting Services. Your comprehensive financial plan will be updated periodically as needed due to changes in your financial circumstances or as you progress toward your financial goals. We will offer a complete review of the comprehensive financial plan on an annual basis. Klaas 401K — Retirement Plan Services Project-Based Financial Consulting Services We offer Project-Based Financial Consulting to provide a one-time comprehensive financial plan addressing all applicable financial topics relevant to your financial circumstances, or to provide guidance and support focusing on a specific financial topic or project. Examples of specific topics or projects may include: Klaas 401K is the brand name under which we provide services to the Plan Sponsors and Plan Participants of qualified retirement plans. The Employee Retirement Income Security Act of 1974, as amended (ERISA) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, Klaas will be considered a fiduciary under ERISA. Plan Sponsors who wish to engage our services to the Plan and its Participants will enter into a retirement plan services agreement Page 2 of 8 Rev. 08-26-2025  Investment Monitoring and Review Services (Klaas 401K Agreement) with us. Our services can be tailored to the Plan Sponsor’s requirements and may be offered on either a discretionary or non-discretionary basis. In providing these services, we serve as a fiduciary as described in ERISA § 3(21). We may additionally serve as a discretionary investment manager as defined in ERISA § 3(38). that document Our Klaas 401K program includes the services described below. Plan Sponsors may choose whether to use any or all of these services. Participant Investment Education Services Klaas will assist the Plan Sponsor with the development of an Investment Policy Statement (IPS). The IPS outlines the process used by Klaas to review and monitor existing investment fund options in the Plan. Klaas will provide Plan Sponsor with periodic Plan Investment Review and Monitoring Reports investment performance, consistency of fund management, and conformance to the guidelines described in the IPS. As applicable, Klaas will use this report and other available investment reports and statistics to make recommendations to maintain or remove or replace investment fund options. Under the 3(21) Fiduciary Service, the Plan Sponsor shall have the final decision-making authority regarding the retention, removal or replacement of investment fund options. Under the 3(38) Fiduciary Service, we have the full authority to remove or replace investment options available in the Plan. Additional Plan Services Klaas may provide additional services, as requested by the Plan Sponsor or as necessary based on the needs of the Plan and/or its Participants: Klaas will provide the following investment education services at the Plan Sponsor’s reasonable request. Participant Investment Education Services are not intended to be investment advice under the definition of fiduciary in ERISA section 3(21)(A)(ii), but are intended to be investment education as outlined in the Department of Labor Interpretive Bulletin 96-1. These investment education services may include information about the plan, general financial and investment information, and/or generalized asset allocation models, or interactive investment materials (e.g., questionnaires or worksheets), but will not address the appropriateness for any individual investment option or model for any particular Participant.            Provide advice with respect to the selection of a qualified default investment alternative (QDIA) for participants who otherwise fail to make an active investment election. Perform an Annual Plan Review, and meeting with Plan Sponsor to discuss key Plan demographics that relate to the overall health of the Plan. Perform Fee and Expense Benchmarking that will provide expense comparison to Plans of a similar asset size and participants. The Benchmarking helps to determine that Plans overall fees and expenses are reasonable. Provide Financial Wellness services and tools to the Plan for Participants. Provide Vendor Relationship Management to coordinate with the Recordkeeper and TPA (if appropriate) in servicing the Plan. Perform analysis of fees and expenses associated with service providers of the Plan. Provide searches and analysis of service providers by assisting the Plan with Requests for Proposals or Requests for Information as needed. Klaas 401K Assets Under Advisement Assist Plan Sponsor with the development of communications and educational materials for Participants. Conduct seminars for Participants on investment issues relevant to the Plan and retirement planning in general (in group settings) upon Plan Sponsor’s reasonable request. Conduct other periodic group education meetings as reasonably requested by Plan Sponsor. Assist Plan Sponsor with the planning and coordination of an initial enrollment and communication meeting in a group setting for the purpose of introducing the Plan to Participants and educating Participants about the Plan. Upon Plan Sponsor’s reasonable request, conduct individual meetings with Participants in the Plan to provide information or answer questions regarding the Plan, give general financial and investment information, provide generalized asset allocation models, and offer assistance to participants through interactive investment materials (e.g., questionnaires or worksheets). Note that Klaas is unable to provide specific investment advice unless the participant enters into a separate advisory agreement with Klaas. Investment Selection Services As of June 30, 2025, under the Klaas 401K services, we provided advisory services on approximately $30 million in retirement plan assets for 18 plans. We do not have discretion to execute trades in these accounts; however, we collect a fee for our services based on the plan assets or as a fixed fee. Item 5. Fees and Compensation is solely responsible KIP Wrap Fee Program Fees Upon Plan Sponsor’s request, Klaas will analyze funds in the universe of funds defined by Plan Sponsor or the recordkeeper, and make recommendations for funds to be made available to Participants in the Plan. Under our non-discretionary service (3(21) Fiduciary Service), the Plan Sponsor for reviewing Klaas’s recommendations and making the final selection of funds to be made available in the Plan. The fees for our KIP Wrap Fee Program are described in detail in the Wrap Fee Program Brochure, which is available upon request, or which can be found by visiting our website at www.klaasfinancial.com. Klaas 360 Financial Planning and Consulting Fees Comprehensive Financial Planning Services Fees Klaas may also assist the Plan Sponsor with selecting and retaining a discretionary Investment Manager, as defined in §3(38) of ERISA. We may be able to coordinate our services with the Investment Manager to help facilitate the implementation of our recommendations, as approved by the Plan Sponsor. For Comprehensive Financial Planning Services, we charge a Program Fee of $275 per month for up to $1,500,000 of Investable Assets, plus $75 per month for each $500,000 above $1,500,000. See the table below. You will pay a one-time Initial Fee equal to half of the total Under our discretionary service (3(38) Fiduciary Service), the Plan Sponsor appoints Klaas as its discretionary Investment Manager as defined in ERISA § 3(38). We have the full authority to select the investment options available in the Plan. Page 3 of 8 Rev. 08-26-2025  Fees may be negotiable in certain circumstances. Klaas reserves the right to waive or discount fees at its sole discretion. Fees are due and payable upon acceptance by Client of the final tax returns. Program Fees for the first year of service. The Initial Fee covers initial discovery meetings, data gathering, research and analysis, and creation of the initial financial plan. The Initial Fee is due after delivery of the initial financial planning recommendations; Monthly Program Fees are payable monthly in arrears and begin accruing with the first full month following the Initial Fee payment. Investable Assets Monthly Program Fee Initial Fee Up to $1,500,000 $275 $1,650 Up to $2,000,000 $350 $2,100 Up to $2,500,000 $425 $2,550 Up to $3,000,000 $500 $3,000 Up to $3,500,000 $575 $3,450 Clients may terminate the Tax Services Agreement without penalty within five business days of signing said Agreement. Engagements will automatically terminate upon the earlier of (i) the acceptance of Client’s electronically filed tax returns by the taxing authorities, (ii) delivery of the final printable PDF to Client (if Client opts out of electronic filing), or (iii) eighteen (18) months from the Effective Date of the Agreement. In addition, either party may terminate this service upon written notice to the other party. We will take all reasonable steps to assist in the orderly transfer of your tax information to a new preparer. You remain liable for all services provided prior to termination. Up to $4,000,000 $650 $3,900 Financial Institution Consulting Services Fees Over $4,000,000 $650 + $75 for each additional $500,000 Half of total Program Fees for first year Investable Assets used to calculate the Initial Fee and Monthly Program Fees are determined prior to entering into the Klaas 360 Agreement based on information you provide. Investable Assets are re-evaluated annually, and we will notify you of any changes to your fees. Periodic re-evaluations are based on information available in Klaas Portal. You should notify us promptly if any information in Klaas Portal is inaccurate. Re-evaluations may also occur more frequently due to material changes in Investable Assets. Mutual Securities pays us a consulting fee based on the assets under management from Brokerage Customers who have provided written consent to Mutual Securities to receive the investment consulting service from us, and have entered into a Consulting Agreement with us. Clients who receive this service do not pay us a fee directly, and the fees and expenses Brokerage Customers pay to Mutual Securities related to their brokerage accounts are not higher or lower as a result of the investment consulting services we provide. Clients may terminate the Consulting Agreement with us at any time without penalty by providing written notice. In addition, the Consulting Agreement will automatically terminate if the Brokerage Customer revokes written consent to Mutual Securities for us to provide investment consulting services, or if the Brokerage Customer closes the brokerage account(s). Comprehensive Financial Planning Services will continue until terminated by either party upon notice to the other party. Upon termination, Monthly Program Fees are not prorated. Because fees are paid in arrears, no refunds are given upon termination. Klaas 401K Fees Project-Based Financial Consulting Fees For our Project-Based Financial Consulting Services, we charge a fixed fee based on the complexity of your financial situation and your specific needs. Project-Based Financial Consulting Services will automatically terminate sixty (60) days following delivery of our analysis and recommendations. In addition, either party may terminate these services by providing notice to the other party. In the event of early termination, you will be invoiced for fees in an amount equal to the hourly rate of $300 times the number of hours of work that has been completed up to and including the date of termination, not to exceed the fixed fee. In the event of early termination, we will provide you with any completed deliverables. However, the scope and/or soundness of any analysis or other work product made prior to completion may be limited, inaccurate, or incomplete due to the early termination. The fees for our Klaas 401K retirement plan consulting services may be based on a percentage of assets under advisement or may be a fixed fee. The fee may vary depending upon the complexity of the Plan and the level of services provided to the Plan Sponsor and Participants. Asset-based fees typically range between .05% to 1.0%, although in some instances fees could be higher or lower. Fixed fees are negotiated on a case-by-case basis. The specific fee is described in the Klaas 401K Agreement between Klaas and the Plan Sponsor. Asset-based fees are calculated on the total assets as of the last business day of each billing period, or on average daily balance. Fees for any partial billing period will be reduced on a pro rata basis. Fees may be paid in advance or in arrears, and may be billed on a monthly or quarterly basis. Fees may be paid by the Plan Sponsor or deducted from Plan Assets, at the Plan Sponsor’s direction. In some cases (e.g., depending on plan size, number and complexity of investment options, or number of employees), fees may be negotiable. The Klaas 401K Agreement between Klaas and the Plan Sponsor will outline the specific fees and billing arrangements. Fees are billed in arrears and will be invoiced upon the completion of the Services. Client agrees to pay all fees upon receipt of invoice. Because fees are paid in arrears, no refunds are given upon termination. Tax Preparation Services Plan Sponsors may terminate their contracts at any time upon a 30-day written notice. If the contract is terminated prior to the end of a billing period, the fees for the last billing period will be prorated. Any unearned fees paid in advance will be refunded. In the event the Plan Sponsor requests to engage Klaas for additional services, including but not limited to customized printed participant or Plan Sponsor marketing campaigns, additional fees mutually agreed upon by the Plan Sponsor and Klaas will apply. Fees for our Tax Preparation Services will be charged according to our standard fee schedule, which is based on the complexity of your returns (number and type of required forms and schedules and/or other circumstances). Some forms that are billed hourly are also subject to minimum fees. A fee guide is available on our website at www.klaasfinancial.com. Fees are subject to change without notice. Page 4 of 8 Rev. 08-26-2025  Other Compensation Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis As mentioned previously, some Investment Adviser Representatives are licensed to sell insurance products. If you purchase an insurance product through one of our Investment Adviser Representatives who is a licensed insurance agent, the Investment Adviser Representative will earn a commission on such products. If you choose to purchase insurance products, you are not obligated to do so through our Investment Adviser Representatives or our firm. In addition to our fees, you may incur additional charges on your investment accounts, such as:     With regard to Klaas 360 and Financial Institution Consulting Services, when we provide advice regarding investments, we use information gathered in the financial planning process to assess the client's financial objectives, risk tolerance, time horizon, and liquidity needs. We evaluate asset classes to construct a diversified portfolio that aligns with the client's financial goals, while seeking an appropriate balance between risk and return. For our Klaas 401K services, the methods of analysis are set forth in the plan's Investment Policy Statement. See our Wrap Fee Program Brochure for details on our methods of analysis used in our discretionary portfolio management through the KIP Wrap Fee Program. Investment Strategies  custodial fees; brokerage commissions; transaction fees; internal fees and expenses charged by mutual funds, ETFs and variable annuities; fees charged by Third-Party Asset Managers in our Wrap Fee Program;  maintenance and termination fees for IRAs, certain retirement  and qualified accounts; and other fees and taxes on brokerage accounts and securities transactions. Klaas generally employs long-term investment strategies, using broad asset allocation exposures, incorporating diversification across sources of risk and return, asset classes, countries, and sectors. Long- term trading is designed to capture market rates of both return and risk. Asset allocation and diversification are strategies designed to reduce risk, but they do not protect against losses. Risks Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and expenses for their products. These fees and expenses are in addition to any advisory fees charged by us. Complete details of these internal fees and expenses are explained in the prospectuses for each investment. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Investing carries the risk of loss of principal. Investments in securities are not guaranteed or insured by the FDIC or any other government agency. Past performance is no indication of future performance, and we cannot offer any guarantees or promises your goals and objectives will be met. Klaas generally recommends investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. If you purchase mutual fund shares through the custodian, you may pay a transaction fee that would not be charged if the transaction were made directly through the mutual fund company. Also, mutual funds held in accounts at brokerage firms may charge internal fees that are different from mutual funds held at the mutual fund company. Mutual funds held at a mutual fund company may not be part of a managed account. This means they will not be included in the investment strategies, investment investment performance monitoring, or reallocation performed by an investment manager. Please be sure to read Item 12 entitled Brokerage Practices, which follows later in this brochure. Item 6. Performance-Based Fees We do not charge performance-based fees for any of the services described in this brochure. Performance-based fees are generally based on a percentage of the capital gains on and/or appreciation of the client account assets. In addition to general market risks, investment strategies may be subject to the risk of loss arising from direct or indirect exposure to catastrophic or geopolitical events, such as global pandemics, natural disasters, acts of terrorism, war, sanctions, cyber-attacks, or network outages. The extent and impact of any such event on investment strategies will depend on many factors, including the duration and scope of the event, the extent of any governmental restrictions, the effect on the supply chain, overall consumer confidence, and the extent of the disruption to global and domestic markets. Item 7. Types of Clients Risks of Specific Securities The following is a summary of some of the general risks for categories of investments that may be recommended: We provide advisory services primarily to individuals, including high net worth individuals. We also provide services to small businesses, including their pension and profit-sharing plans, and charitable organizations. In addition, we provide institutional consulting services to a broker-dealer. We do not impose a minimum investment account size to start and maintain an advisory relationship with us. Equity Securities – Investing in individual stock positions involves inherent risk, including the potential for greater concentration risk related to a single company or business enterprise. Significant risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk, and liquidity risk. Page 5 of 8 Rev. 08-26-2025  agencies and instrumentalities. U.S. government securities may be supported by the full faith and credit of the United States. Equity securities are not guaranteed or insured by the FDIC or any other government agency. Item 9. Disciplinary Information We have not been the subject of any legal or disciplinary events that would be material to your evaluation of our business or the integrity of our management. Industry Activities and Item 10. Other Financial Affiliations Mutual Fund Securities – Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. Active mutual funds have higher fees and costs that can result in lower investment returns. Mutual funds are not guaranteed or insured by the FDIC or any other government agency. We have an agreement with Mutual Securities to provide investment consulting services to its Brokerage Customers, as described in Item 4 above. Mutual Securities compensates us for providing investment consulting services to Brokerage Customers, as described in Item 5 above. We do not assume discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of securities. These consulting services offered to Brokerage Customers may include a general review of their investment holdings, which may or may not result in our investment adviser representatives making specific investment recommendations or offering general investment advice. Exchange Traded Fund (ETF) Securities – Exchange-traded funds are investment companies with shares that are bought and sold on a securities exchange. Generally, an ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, Powershares® and iShares®. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Certain ETFs or ETNs employ leverage, which creates additional volatility and price risk. ETFs are not guaranteed or insured by the FDIC or any other government agency. The relationship with Mutual Securities presents a potential conflict of interest. We mitigate this potential conflict of interest by having Brokerage Customers consent to receive investment consulting services from us. We do not accept or bill for additional compensation on brokerage assets under management beyond the consulting fees disclosed in Item 5. We are not affiliated with any broker-dealer, and we do not engage as or hold our firm out to the public as a securities broker-dealer. In addition, our Investment Adviser Representatives are not registered representatives of any broker-dealer. its Neither Klaas nor Investment Adviser Representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. Item 11. Code of Ethics; Participation or Interest in Client Transactions and Personal Trading Corporate Debt Securities, Commercial Paper, and Certificates of Deposit – Fixed income securities carry different risks than those of equity securities described above. These risks include the company’s or the government’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign), and currency risk. If bonds have maturities of 10 years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and currency risk. Corporate Debt securities are not guaranteed or insured by the FDIC or any other government agency. required of our We have adopted a Code of Ethics (Code) to address the standards of business conduct Investment Adviser Representatives and employees. The Code includes policies and procedures designed to protect your interests. The Code includes, but is not limited to, the following provisions:  Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank, and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity.      Municipal Securities – Municipal securities carry different risks than those of corporate government and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal level, but can be taxable in individual states other than the state in which both the investor and municipal issuer are domiciled. Municipal securities are not guaranteed or insured by the FDIC or any other government agency. To uphold our fiduciary duty to put your interest ahead of ours at all times. To comply with all applicable laws and to maintain a standard of conduct. To avoid actual or potential conflicts of interest where possible, and to fully disclose any actual or potential conflicts that may exist. To conduct all personal securities transactions of our Investment Adviser Representatives and employees in a manner consistent with the Code. To avoid giving or receiving gifts that may influence decisions. To prevent any abuse of our position of trust and responsibility, including the use of inside information we may obtain. You may obtain a complete copy of our Code upon request. U.S. Government Securities – U.S. government securities include securities issued by the U.S. Treasury and by U.S. government Page 6 of 8 Rev. 08-26-2025  Item 12. Brokerage Practices Item 13. Review of Accounts KIP Wrap Fee Program Please see our Wrap Fee Program Brochure for details on our review of accounts. Klaas 360 With our Comprehensive Financial Planning Services, we will monitor your financial plan on an ongoing basis and provide updates as necessary due to changes in your financial circumstances or as you progress toward your financial goals. We offer a complete review of your financial plan on an annual basis. As previously noted, we strongly encourage you to advise us of any changes in your personal circumstances, your investment goals or objectives, and your risk tolerances to ensure your investments and investment strategies are most appropriate for you. Reviews may be triggered by material market, economic or political events, or by changes in client’s financial situations (such as retirement, termination of employment, physical move, or inheritance. Unless you grant us discretionary authority over your accounts through our KIP Wrap Fee Program, we do not have the authority over your accounts, without your specific consent, to determine the amount or types of investments to be bought or sold, the broker-dealer or custodian to be used, or the commission rates paid. For additional information on our wrap fee program, please see our Wrap Fee Program Brochure. Because of our established relationship, we will generally recommend Fidelity Institutional Wealth Services (Fidelity) to you for custody and brokerage services. Fidelity, a member FINRA/SIPC, is an SEC-registered broker-dealer. Fidelity provides brokerage and custody through its affiliates, National Financial Services, LLC or Fidelity Brokerage Services, LLC, which are also SEC- registered broker-dealers and members FINRA/SIPC. Fidelity offers independent investment advisers services which include custody of securities, trade execution, clearance and settlement of transactions. Because our compensation in connection with the KIP Wrap Fee Program may vary depending on the broker-dealer or custodian selected, we may have a conflict of interest in recommending Fidelity for wrap fee accounts. You will receive account statements directly from your account custodian. These statements will identify your current investment holdings, the cost of each of those investments, and their market values. Please review these carefully. With Project-Based Financial Consulting Services, we do not provide implementation assistance, ongoing monitoring, review or updates of your financial plan. In addition to brokerage and custody services, Fidelity provides access to investments generally available to institutional investors; research; software; and, educational opportunities. Fidelity also makes available or arranges for discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third party vendors. Thus, we receive economic benefits as a result of our relationship with Fidelity, because we do not have to produce or purchase the products and services listed above. Financial Institution Consulting Services These services are not contingent upon us committing any specific amount of business to the custodians in trading commissions. Klaas does not enter into any soft dollar arrangements with custodians and broker- dealers through which we receive research or other services based on commissions generated in your account or the number of transactions effected in your account. If you are a Mutual Securities’ Brokerage Customer who elects to receive our non-discretionary advisory services, we will offer to provide a review, analysis, and recommendations regarding your brokerage account on at least an annual basis, or upon your request if a review is needed due to your financial circumstances. Our review findings will be delivered to you either verbally or in writing. It is your responsibility to implement our recommendations as you deem appropriate. Our recommendation of specific custodians may be based in part on the economic benefit to us and not solely on the nature, cost or quality of custody and brokerage services provided to you and our other clients. This creates a conflict of interest for us. We nonetheless strive to act in your best interests at all times. Custodians may not charge separately for holding our client accounts, but may be compensated by you through other transaction-related fees with the securities transactions they execute for your account. You will receive account statements directly from the sponsor of the brokerage product. These statements will identify the current investment holdings and their market values. We do not typically provide periodic reports for Brokerage Customers; however, if you are a Brokerage Customer and also receive Klaas 360 or KIP Wrap Fee Program Services from us, we may include information regarding your brokerage account in our aggregated reports as a courtesy to you for informational purposes. Klaas 401K We will typically review the investments in the Plan on a quarterly basis, or as specifically described in the Klaas 401K Agreement with the Plan Sponsor. Commissions and other fees for transactions executed through the custodians we recommend may be higher than commissions and other fees available if you use another custodian firm to execute transactions and maintain custody of your account. We believe, however, that the overall level of services and support provided to our clients by our recommended custodians outweighs the benefit of possibly lower transactions cost which may be available under other brokerage arrangements. Item 14. Client Referrals and Other Compensation Many of the services described above may be used to benefit all or a including accounts not substantial number of our accounts, maintained through our recommended custodians. We do not attempt to allocate these benefits to specific clients. We do not currently compensate any unaffiliated persons or entities for referring clients to us. In the event we enter into such an agreement for receiving client referrals, we will update this Item as necessary. Any referral arrangements we may enter into will comply with applicable rules governing the nature of the referral arrangement, the fees to be paid, and the disclosure of the arrangement to clients. With regard to the services outlined in this Disclosure Brochure, we do not implement transactions. Therefore, we do not participate in any directed brokerage arrangements. Page 7 of 8 Rev. 08-26-2025  regard to any class action lawsuit or bankruptcy related to securities held in client accounts. Item 18. Financial Information Because we do not require prepayment of advisory fees six months or more in advance, we are not required to provide a balance sheet. We have not been the subject of any bankruptcy proceedings. Clients occasionally seek recommendations for third-party service providers such as insurance agents, estate planning attorneys, or accountants (Service Providers), for assistance with carrying out our financial planning recommendations. We have developed the Klaas Professional Network (KPN), which is a list of Service Providers with whom Klaas has worked in the past and who we believe provide quality services to their clients. KPN is provided as a convenience to clients only, and clients are encouraged to perform their own due diligence on qualified professionals before engaging their services. Klaas and Service Providers agree to share information with each other, as authorized by the client, as necessary to provide coordinated services to clients. No monetary compensation is provided by either Klaas or Service Providers to participate in KPN. We receive certain economic benefits as a result of our participation in Fidelity’s institutional brokerage programs. These benefits and related conflicts of interest are described in detail in the preceding section entitled Brokerage Practices. Item 15. Custody Your assets are maintained with a qualified custodian. Klaas does not have physical custody of your assets but we are deemed to have custody when you authorize us to deduct advisory fees directly from your account. You will receive account statements from the custodian on at least a quarterly basis. We urge you to carefully review those statements. You should verify the transactions in your account are consistent with your investment goals and objectives for your account. Item 16. Investment Discretion Our advisory services through the KIP Wrap Fee Program are offered on a discretionary basis, meaning we do not need advance approval from you to determine the type and amount of securities to be bought and sold for your account. We will exercise our discretion in a manner consistent with your investment objectives. Please see our Wrap Fee Program Brochure for additional details on our investment discretion. The services we provide through Klaas 360 are non-discretionary advice and consulting. We do not have the discretion to implement recommendations on your behalf without your consent. In some limited circumstances, as a consideration and convenience, we may assist a client in establishing a brokerage account to hold investments over which we do not exercise discretion or provide ongoing supervisory management, and for which we do not collect a management fee. The client is solely responsible for the oversight and management of these assets. Klaas 401K Retirement Plan Services may be provided on a discretionary or non-discretionary basis, depending on the service selected by the Plan Sponsor. Our 3(21) Fiduciary Service is offered on a non-discretionary basis. The Plan Sponsor is solely responsible for reviewing our recommendations and making the final selection of funds to be made available in the Plan. Our 3(38) Fiduciary Service is offered on a discretionary basis, and the Plan Sponsor appoints Klaas as its discretionary Investment Manager as defined in ERISA § 3(38). We have the full authority to select the investment options available in the Plan. Item 17. Voting Client Securities Klaas does not accept voting authority for client proxies, and does not provide advice to clients on how to vote proxies. In addition, we do not take any action on behalf of clients or provide advice to clients with Page 8 of 8 Rev. 08-26-2025 

Wrap Fee Program Brochure Form ADV Part 2A – Appendix 1 Klaas Financial Asset Advisors, LLC 4707 Perry Ridge Lane Loves Park, IL 61111 Firm CRD No. 121399 (Klaas 360) August 26, 2025 management wrap fee program (Klaas Investment Portfolios – KIP), approximately $30 million in retirement plan assets through our retirement plan services (Klaas 401K) for 18 retirement plans, and approximately $28 million in assets under advisement through our non-discretionary Klaas Investment Consulting Services for brokerage financial planning and customers. Furthermore, we provided consulting services to approximately 24 client households. Item 1. Cover Page Currently, our brochure may be requested by contacting us at (877) 495-5227 or info@klaasfinancial.com. The brochure is also available on our website at www.klaasfinancial.com. We will provide you with a copy of our current brochure at any time without charge. Information about each of our Investment Adviser Representatives may be found in their respective Form ADV Part 2B Brochure Supplement, which can also be found on our website at www.klaasfinancial.com. This wrap fee program brochure provides information about the qualifications and business practices of Klaas Financial Asset Advisors, LLC (Klaas). If you have any questions about the contents of this brochure, please contact us at (877) 495-5227 or by email at info@klaasfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Item 3. Table of Contents Klaas is a registered investment adviser registered with the SEC. Registration as an investment adviser does not imply any level of skill or training. Additional information about Klaas is also available on the SEC’s website at www.adviserinfo.sec.gov by conducting a Firm search using our Firm CRD No. 121399. Klaas Investment Portfolios (KIP) is the brand name under which Klaas Financial Asset Advisors, LLC, provides investment management or investment supervision services to its clients. Item 2. Material Changes We deliver our Wrap Fee Program Brochure initially when we enter into an advisory agreement with you. The Wrap Fee Program Brochure will be updated no less than annually within 90 days of our December 31 fiscal year end. Within 120 days of our fiscal year end, we will deliver to you a summary of material changes which have been made to our Wrap Fee Program Brochure since its last annual update. This summary will include information about how you may obtain a complete copy of our updated Wrap Fee Program Brochure at no charge, and it will include the date of the last annual update. We will provide updated disclosure information about material changes more frequently as needed. Since the last annual update to our Wrap Fee Program Brochure dated March 28, 2025, we made the following material changes:  Item 1. Cover Page ...................................................................................... 1 Item 2. Material Changes ........................................................................... 1 Item 3. Table of Contents ........................................................................... 1 Item 4. Services, Fees and Compensation .............................................. 1 Financial Planning Services ................................................................ 2 Discretionary Portfolio Management Services ................................ 2 Brokerage Practices ............................................................................. 3 Aggregation of Client Trades............................................................. 3 Fees and Compensation ..................................................................... 3 Item 5. Account Requirements and Types of Clients ............................ 5 Item 6. Portfolio Manager Selection and Evaluation ............................. 5 Individual Needs of Clients and Restrictions ................................... 6 Other Services ...................................................................................... 6 Performance-Based Fees .................................................................... 6 Methods of Analysis ............................................................................. 6 Investment Strategies .......................................................................... 6 Risks ........................................................................................................ 6 Risks of Specific Securities .................................................................. 7 Voting Client Securities ....................................................................... 7 Item 7. Client Information Provided to Portfolio Managers ................. 7 Item 8. Client Contact with Portfolio Managers ..................................... 7 Item 9. Additional Information .................................................................. 8 Disciplinary Information ...................................................................... 8 Other Financial Industry Activities and Affiliations ......................... 8 Code of Ethics and Personal Trading ............................................... 8 Review of Accounts .............................................................................. 8 Client Referrals and Other Compensation ....................................... 8 Financial Information ........................................................................... 8 Item 4. Services, Fees and Compensation As of the date of this Wrap Fee Program Brochure, we have amended our fee structure. The Program Fee will be calculated on the average daily balance in your account, based on a blended tier fee schedule ranging from 0.30% to 1.20% annually depending on assets under management, and subject to an annual minimum of $1,500. Please see Item 4, Fees and Compensation for more information. Klaas Financial Asset Advisors, LLC (Klaas) is the sponsor of the Klaas Investment Portfolios (KIP) Wrap Fee Program (Program). Klaas is located in Loves Park, Illinois and Fitchburg, Wisconsin. The firm’s shareholders are Craig J. Klaas, Maleeah L. Wernsing-Cuevas, Kyle A. Kite, Eric J. Schwartz, Joshua E. Stirling, and Nathan A. Breiby. We have made additional edits as necessary to correct typographical or grammatical errors, or to provide clarification where necessary. We do not consider these changes to be material. Klaas is registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC). As of June 30, 2025, we provided investment advisory services on approximately $757 million in client assets for more than 1,000 client households. This total represents approximately $699 million in client through our discretionary asset assets under management This Wrap Fee Program Brochure describes the services offered under the Program. In addition to the services outlined here, we also provide Page 1 of 8 Rev. 08-26-2025  non-discretionary financial planning and consulting services, and retirement plan consulting. Further information regarding these services can be found in our Disclosure Brochure, which is available upon request, or which can be found by visiting our website at www.klaasfinancial.com. we assist you in selecting one or more of the investment strategies available through the Program (Program Strategies). Other relevant information that may be considered may include (but is not limited to) your preference for certain types of investments, the amount of your assets, the projected risk and return of your portfolio, and the management fees charged. The Program includes Financial Planning Services and Discretionary Portfolio Management Services, as described below. Clients who wish to participate in the Program will enter into an agreement with Klaas (KIP Client Agreement). Financial Planning Services We may use one or more Program Strategies and allocate assets into, between, or among the Program Strategies. Klaas has established a Portfolio Management Group (Klaas PMG) consisting of qualified investment professionals dedicated to portfolio management, research, and trade administration functions. The Program Strategies may be developed by and managed by the Klaas PMG, or by third- (Asset party asset managers or separate account managers Managers) selected by Klaas PMG. As part of the Program, we provide financial planning services. Through discussions, interviews, and questionnaires, we will gather sufficient information to develop a financial plan and investment recommendations. The items covered in your financial plan are based on your financial circumstances and needs. The financial plan may consider such items as the following:   Klaas has the discretion to determine which Program Strategies are available in the Program. Klaas has the discretion to change the Program Strategies available through the Program, to change the selection of any Program Strategy, to add one or more additional Program Strategies to those previously selected, and to reallocate assets among Program Strategies at any time. Klaas also has the discretion to hire, replace, or terminate Asset Managers as it deems necessary at any time.    A variety of investment products and vehicles may be used, including, but not limited to, exchange-traded funds (ETFs), mutual funds, equity and fixed-income instruments. When appropriate based on a client’s financial circumstances, Klaas may recommend a Program Strategy that includes an investment-only Managed Variable Annuity (MVA). The MVA is an insurance product offered by a licensed insurance carrier that includes an investment component.  Your personal financial circumstances, such as assets and liabilities, net worth, cash flow, spending analysis, budgeting, family situations, and personal obligations. Payment of past, present, and future debts, such as loans, education expenses, health expenses. Your current and future tax liabilities, and an analysis of how to mitigate tax liabilities with your investments. Your attitudes towards investments, including your risk tolerance, financial goals, and investment objectives. Your cash needs in the event of your disability, incapacity, or death, including the income needs of your dependents, and estate planning. Your current retirement assets, potential future savings, planned retirement age, income needs and spending in retirement.  Other specific financial concerns you may have. We base our investment recommendations on the information that you provide to us. Inaccurate or incomplete information may result in an inaccurate or incomplete investment recommendations. We must make certain assumptions with respect to interest and inflation rates, past trends, and future projections of the performance of the market and economy. Changes to your personal financial circumstances, goals, or objectives may cause our investment recommendations to change. We recommend you notify us promptly of any changes so that your strategy can be updated if necessary. investment professionals Although the financial plan may consider your estate plan, we do not provide legal advice. We recommend you work closely with your attorney, accountant, or other in implementing your plan. We are happy to work with your professionals to coordinate your financial plan with your estate planning and tax planning. For our Clients who wish to make charitable contributions, we offer a Managed Charitable Program (MCP). Through MCP, clients may participate in a third-party charitable program which offers charitable accounts such as donor advised funds, endowments, and foundations. These third-party charitable programs are charitable trusts as described in Section 501(c)(3) and Section 509(a)(1) of the Internal Revenue Code. Clients may make irrevocable charitable contributions of assets to the charitable program. We help to facilitate the transfer of Client’s funds. The Client may receive an income tax benefit for the tax year in which the contribution is made. Clients may appoint us to manage the funds in their charitable program on a discretionary basis, consistent with the specific investment policies and guidelines of the third-party charitable program. Once the contribution is made to the charitable program, the Client no longer has ownership of the funds. Contributions are irrevocable and non-refundable. The Client may make recommendations to the sponsor of the charitable program on qualified charitable organizations to receive funds, and the amount of funds to be distributed. Clients may also authorize us to communicate these recommendations to the charitable program sponsor on Client’s behalf. However, the sponsor reviews each recommendation and has the discretion to approve or reject any grant. Grants may only be given to charitable organizations organized under Section 501(c)(3) of the Internal Revenue Code. In some cases, your financial plan may recommend an insurance product. Some of our Investment Adviser Representatives are also licensed insurance agents. If you choose to purchase a recommended insurance product through your Investment Adviser Representative, he or she will earn a commission. You may choose to purchase any insurance products through any licensed agent. Discretionary Portfolio Management Services Please note that client assets are primarily managed by Klaas PMG. Asset Managers, MVAs, and accounts within the MCP are only used in limited circumstances and only where appropriate based on the unique financial circumstances of each client. In addition, we provide discretionary portfolio management services. Based on the information gathered in the financial planning process, Page 2 of 8 Rev. 08-26-2025  clients. This creates a conflict of interest for us. We nonetheless strive to act in your best interests at all times. Custodians may not charge separately for holding our client accounts, but may be compensated by you through other transaction-related fees with the securities transactions they execute for your account. We rely upon you to notify us of any changes in your objectives, goals and risk tolerances, as well as any other material changes in your personal circumstances (such as your employment, marital status, financial condition, etc.). In addition, notify us if you wish to impose any reasonable restrictions on the management of your account. Please notify us promptly of any changes, as these changes may require changes in the Program Strategies employed. Brokerage Practices Commissions and other fees for transactions executed through the custodians we recommend may be higher than commissions and other fees available if you use another custodian firm to execute transactions and maintain custody of your account. We believe, however, that the overall level of services and support provided to our clients by our recommended custodians outweighs the benefit of possibly lower transactions cost which may be available under other brokerage arrangements. Program assets are maintained with a qualified custodian. We do not have physical custody of your assets, but we are deemed to have custody when you authorize us to deduct advisory fees directly from your account. You will receive account statements from the custodian on at least a quarterly basis. We recommend you carefully review those statements to verify the transactions are consistent with your investment goals and objectives. Many of the services described above may be used to benefit all or a substantial number of our accounts, including accounts not maintained through our recommended custodians. We do not attempt to allocate these benefits to specific clients. Aggregation of Client Trades Klaas PMG may aggregate trades in a single order (a block trade). Aggregated trading allows for the purchase or sale of a security for the accounts of multiple clients in a single transaction. Block orders are generally completed or filled on the same day the trade is placed. If a block order is filled (full or partial fill) at several prices through multiple trades, an average price will be calculated for all trades executed, and all participants in the block trade will receive the average price. The objective of the aggregated orders will be to allocate the executions in a manner deemed equitable to the accounts involved. While the occurrence of partial fills (i.e., a block order which is not fully executed within the same day) is rare, all partial fills shall be allocated to client accounts on a pro rata basis. We do not have the discretion to select the broker-dealer or custodian used for your accounts, although we may suggest broker-dealers and custodians and assist with new account paperwork. Because of our established relationship, we will generally recommend Fidelity Institutional Wealth Services (Fidelity) to you for custody and brokerage services. Fidelity, a member FINRA/SIPC, is an unaffiliated SEC-registered broker-dealer. Fidelity provides brokerage and custody through its affiliates, National Financial Services, LLC, or Fidelity Brokerage Services, LLC, which are also SEC-registered broker-dealers and members FINRA/SIPC. You may direct us in writing to use a particular custodian to execute some or all of the transactions for your account. If you do so, you may be responsible for negotiating the terms and arrangements for the account with that custodian. We may not be able to negotiate commissions, obtain volume discounts, or best execution with custodians with which we do not have an existing relationship. A difference in transaction fees and expenses may also exist between those charged to clients who direct us to use a particular custodian and other clients who do not. In addition, some Asset Managers may require the use of certain custodians. Please refer to the Brokerage Practices sections of their respective disclosure brochures for more information. Because our compensation in connection with the Program may vary depending on the broker- dealer or custodian selected, we may have a conflict of interest in recommending Fidelity. We may aggregate trades when operationally efficient, or when we reasonably believe the combination of the transactions provides better prices for clients than had individual transactions been placed for clients. We are not obligated to include all or any client transaction in an aggregated block trade. Trading practices, including trade aggregation practices, of Asset Managers (if applicable) are disclosed in their respective disclosure brochures. Klaas PMG has established procedures to reasonably ensure trade execution will not favor or discriminate against any client or group of clients, and trades executed for the accounts of our Investment Adviser Representatives or employees will not be favored over transactions for client accounts. Fees and Compensation In addition to brokerage and custody services, Fidelity provides access to investments generally available to institutional investors; research; software; and, educational opportunities. Fidelity also makes available or arranges for discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third party vendors. Thus, we receive economic benefits as a result of our relationship with Fidelity, because we do not have to produce or purchase the products and services listed above. These services are not contingent upon us committing any specific amount of business to the custodians in trading commissions. Klaas does not enter into any soft dollar arrangements with custodians and broker- dealers through which we receive research or other services based on commissions generated in your account or the number transactions effected in your account. Our standard fee schedule may change over time, and some clients are subject to legacy fee schedules which may be higher or lower than our current fee schedule. Fees may be negotiable in certain circumstances. In addition, we reserve the right to reduce or waive fees under certain circumstances at our discretion. All fees are discussed with you at the time of the engagement, and are described in the KIP Client Agreement and Terms and Conditions, as amended from time to time. Our recommendation of specific custodians may be based in part on the economic benefit to us and not solely on the nature, cost or quality of custody and brokerage services provided to you and our other As of the date of this Wrap Fee Program Brochure, we are updating our fee structure. Existing clients will remain on their current fee Page 3 of 8 Rev. 08-26-2025  described persons. However, Klaas may include or exclude accounts at Klaas’s discretion. schedule through September 30, 2025. As of October 1, 2025, the below fee structure will apply to existing clients, through an amendment to their KIP Client Agreement/Terms and Conditions. Your fee will be deducted from your brokerage account and paid directly to us by the qualified custodian that holds your account, upon your authorization. Program Fees are calculated based on the account valuation provided by the custodian of the assets managed. Any party at any time upon written notice may terminate the KIP Client Agreement. Program Fee payments will be assessed and due upon notification of the account termination or closure date. Our current fee for the program (Program Fee) is a percentage of assets under management in the Program (including cash and cash equivalents, MVAs, and accounts within the MCP, if applicable), charged on a quarterly basis, in arrears. Fees are calculated on the average daily balance of your account during the prior calendar quarter. The average daily balance is calculated by summing the ending account balance each day during the calendar quarter and dividing the total by the number of days in the quarter. Through the use of average daily balance calculations, fees for partial periods (for new accounts and upon termination) are prorated based on the number of days in the billing period that your account was under management. The Program fee is subject to a minimum annual fee of $1,500, and is calculated according to the fee schedule below The Program Fee is a single wrap fee, and covers the financial planning and consulting services provided by Klaas, the portfolio management services provided by Klaas PMG (or Asset Manager, if applicable), and brokerage and custodial fees. Klaas will generally pay the broker-dealer a transaction charge for each trade in the account. Thus, Klaas will earn more compensation if fewer transactions are executed for the accounts. Broker-dealers may waive transaction fees for some types of investments or based on other circumstances (for example, if you enroll in electronic statements for your account). Some investment options (such as mutual funds, ETFs, or investments in MVA subaccounts) may be available with no transaction fees. We potentially have an incentive to choose investments with lower or no transaction fees. However, as a fiduciary, we are required to act in your best interest and have an obligation to manage your portfolio in a prudent matter, regardless of the transaction charges assessed in your account. Assets Under Management From $0 up to $249,999.99 From $250,000 up to $499,999.99 From $500,000 up to $999,999.99 From $1,000,000 up to $1,999,999.99 From $2,000,000 up to $2,999,999.99 From $3,000,000 up to $3,999,999.99 From $4,000,000 up to $4,999,999.99 From $5,000,000 up to $9,999,999.99 From $10,000,000 up to $24,999,999.99 From $25,000,000 up to $49,999,999.99 Over $50,000,000 Annual Fee 1.20% 1.10% 1.00% 0.90% 0.80% 0.70% 0.60% 0.50% 0.40% 0.35% 0.30% for a $2,500,000 portfolio, the annual This is a blended tier fee schedule, which means that different fees are applied to the different levels of assets under management. For example, fee would approximately be calculated as follows: Rate 1.20% 1.10% 1.00% 0.90% 0.80% Assets First $250,000 Next $250,000 Next $500,000 Next $1,000,000 Final $500,000 Total: $2,500,000 Annual Fee $3,000 $2,750 $5,000 $9,000 $4,000 $23,750 The Program Strategies make significant use of ETFs to gain exposure to various asset classes while attempting to minimize costs. Over 2,000 ETF products are available with differing methods and characteristics, including passive, hybrid, and actively managed ETFs. When evaluating ETFs for use in the Program Strategies, selection criteria include characteristics such as assets under management, ETF liquidity, how closely the ETF tracks its underlying index, and other criteria depending on the specific asset class and implementation approach of the ETF. The selection criteria help pare down the large universe when selecting ETFs for use in the Program Strategies. Fidelity has made available a subset of more than 500 ETFs for purchase commission-free. Because we bear the transaction costs in the Program, we have an incentive to select ETFs with no transaction fee, which is a potential conflict of interest. However, we seek to mitigate this conflict of interest by applying selection criteria other than transaction costs to filter the ETF universe. We use both transaction fee and commission-free ETFs in the Program Strategies. The Program Fee does not cover: This results in an effective rate of 0.95% ($23,750/$2,500,000). Please note that this is example is provided for illustration only. Because account values typically fluctuate on a daily basis, your fee will also fluctuate based on your account values.   Although new deposits or increases in account value may be managed at lower rates, the total value of assets in the earlier tiers are managed at a higher rate. Higher fees may have an adverse effect on client returns and client portfolios over time. Because fees are based on total assets under management, we have an incentive to encourage you to increase assets in your investment accounts.   Fees associated with MVAs and accounts within the MCP, such as Brokerage commissions or other charges resulting from transactions not effected through the broker- dealer named in your KIP Client Agreement. Administrative fees charged by the third-party charitable program sponsor for accounts within MCP, which is based on the percentage of assets under management, as outlined in the agreement between you and the sponsor of the third-party charitable program. Any internal management operating fees or expenses imposed or incurred by a mutual fund or other pooled investment vehicle. Any additional custodial services contracted for directly by the client with the custodian. At our discretion, we may aggregate your related accounts into a “household” for purposes of calculating the total assets under management to meet the breakpoints shown in the schedule above. Generally, a household would include your accounts, accounts of your spouse or partner and minor children residing at your residence, and the accounts of any trust whose beneficiaries are any of the above- Page 4 of 8 Rev. 08-26-2025   Mark-ups and mark-downs or dealer spreads broker-dealers may Item 5. Account Requirements and Types of Clients   lot differentials, receive when acting as principal in certain transactions. Variable annuity account fees imposed by insurance carriers. Certain costs or charges that may be imported by the broker- dealer or custodian named in your KIP Client Agreement or third parties, including costs associated with exchanging foreign currencies, odd- IRA fees, transfer taxes, exchange fees, wire transfer fees, postage fees, and other fees or taxes required by law. We typically do not require a minimum amount of assets to open an account in the Program; however, we generally require clients to have a household investment balance of $100,000. This minimum balance requirement may be waived, or may vary depending on the Program Strategy selected. Some Asset Managers (if applicable) may impose minimum account balances. If so, those restrictions are disclosed in their respective disclosure brochures. These minimums may be waived under certain circumstances. If the market value of the assets in a Program Strategy falls below the stated minimum, you may be required to deposit additional funds to meet the required account minimum, or close the Program Strategy account. Further, to the extent that cash used for investment through Program comes from redemptions of the client’s mutual fund or other investments outside of Program, there may be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Program Fee on those assets. The Program is available to individuals, including high net worth individuals, business entities, trusts, and non-profit and charitable organizations. Item 6. Portfolio Manager Selection and Evaluation investment selection, thoughtful and Klaas PMG conducts due diligence and selects the Program Strategies available in the Program. This due diligence and selection process is an ongoing process of broad discovery, and may entail an assessment of investment organizations, people, professional culture, operational processes, key vendors, size of asset base and client types (e.g., institutional, retail, distribution channels used), as well as management and ownership structure. When conducting due diligence and thorough qualitative evaluation are the most critical decision inputs, not past performance. We may also rely on due diligence information provided by portfolio managers, as well as information available from other sources, such as disclosure brochures and independent databases. Among the types of information analyzed are historical performance, investment philosophy, investment style, historical volatility and correlation across asset classes. In most cases, multiple share classes of the same mutual fund are available for purchase. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares and other share classes that may be eligible for purchase in an advisory account. Mutual funds that offer institutional share classes, advisory share classes, and other share classes with lower expense ratios are available to investors who meet specific eligibility requirements that are described in the mutual fund’s prospectus or its statement of additional information. These eligibility requirements include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts the fund considers qualified fee-based programs. It is also possible the lowest cost mutual fund share class for a particular fund may not be offered through the Program or available for purchase within specific types of accounts. Clients should not assume they will be invested in the share class with the lowest possible expense ratio or cost. The share class available for client accounts may be restricted at the custodian or within an account program. The custodian will receive payments from certain mutual funds (including money market funds) pursuant to a Rule 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund’s total assets. These fee arrangements will be disclosed upon request of a client and are available in the applicable fund’s prospectus. The fees received by the custodian create a conflict of interest. In addition, the custodian receives compensation in connection with cash held in the account. Klaas PMG monitors the performance of Program Strategies on an ongoing basis. Program Strategies that underperform relative to the applicable asset class and or style for an extended period of time will likely be modified or removed from the Program. Klaas practices careful judgment and discretion when determining whether to include each Program Strategy in the Program. Factors that would cause us to replace a Program Strategy may include, but are not limited to, underperformance, a change in management personnel or a change in their strategy or discipline that is deemed no longer beneficial to the client, the determination of significant risk or impairment as discovered through due diligence, or a significant regulatory deficiency. The Program may cost a client more or less than purchasing such services separately depending on the frequency of trading in the Program accounts, commissions charged at other broker-dealers for similar products, fees charged for like services by other advisers and broker-dealers, the fee structure of the account and other factors. Assets Under Management When appropriate based on a client’s financial circumstances, Klaas may recommend a Program Strategy that includes an investment-only managed variable annuity (MVA). The MVA is an insurance product offered by a licensed insurance carrier that includes an investment component. In this case, the client grants Klaas the discretion to manage the subaccount investments within the MVA according to the client’s investment objectives. In offering an MVA, we seek out reputable insurance carriers that offer competitively-priced solutions. Investment options available in the subaccount are limited by the insurance carrier. As of June 30, 2025, within the KIP Wrap Fee Program, we provided discretionary asset management on approximately $699 million in client assets for more than 1,000 client households. Discretionary asset management means we have the authorization to make investment decisions on behalf of our clients. Finally, when appropriate based on a Client’s financial circumstances and at the Client’s request, Klaas may assist the Client in establishing a charitable account with a third-party charitable program through a Page 5 of 8 Rev. 08-26-2025  Asset allocation is the strategic combination of asset classes, such as stocks and bonds, to seek the highest long-term returns given an investor’s acceptable level of risk. The methodology applied to the Program Strategies is based upon the belief that it is generally not in the investor’s best interest to attempt to determine investment security purchase or sale points based on short-term economic information, market timing, forecasts, and prediction models. Managed Charitable Program (MCP). Clients may appoint us to manage the funds in their MCP account on a discretionary basis, consistent with the specific investment policies and guidelines of the third-party charitable program. In this case, we receive an investment management fee for assets in the MCP account paid by the sponsor of the third-party charitable program. This management fee creates a conflict of interest, as we have an economic interest to advise Clients to contribute assets to and keep funds in the MCP account. However, we support the charitable intentions of our Clients, and will honor any grant recommendations made by the Client and approved by the third-party charitable program sponsor. Both quantitative and qualitative inputs are used to assess, design, and monitor investment portfolios and holdings. Evaluation parameters vary depending upon the asset, investment type or vehicle. Assessment and analysis include, but are not limited to: Individual Needs of Clients and Restrictions     investment objectives, risk The impact of fees and expenses; Taxes and turnover; Liquidity and frictional costs for the asset or security type; and Potential to capture incremental return in a transparent and repeatable manner. As described in Services, Fees and Compensation above, through discussions, interviews, and questionnaires, we will assist you in determining your tolerance, and investment time horizon, and any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, we select Program Strategies for the client. to assist in formulating Klaas PMG uses outside vendors and/or third-party software, and research as needed, investment recommendations. Vendor services used include: market analysis and manager research subscription datasets, public databases, software and tools related to asset allocation and portfolio optimization, as well as portfolio reconciliation, reporting, and rebalancing tools. filings, company press releases, You may place reasonable restrictions on your portfolio prohibiting particular investments or types of investments from being held portfolio. We will make a reasonable attempt to honor any reasonable restrictions you wish to impose, but in the case of pooled investment vehicles such as mutual funds or ETFs where underlying holdings change frequently, we cannot guarantee restrictions will always be enforced. In addition, please note that imposing such restrictions may cause Klaas PMG to deviate from the investment decisions it would otherwise make in managing your account. In some cases, we may not be able to accommodate restrictions if they do not allow us to manage your portfolio in a prudent manner. In addition to quantitative evaluation, qualitative analysis and due diligence can encompass many sources of assessment, data, and analysis, such as: conference calls, academic journals, economic and market research materials prepared by others, annual reports, financial prospectuses, ADV publications, as well as discussion and interaction with other investment professionals. Other Services Investment Strategies investment consulting In addition to the KIP Wrap Fee Program, Klaas provides non- discretionary financial planning and consulting through its Klaas 360 service, non-discretionary to brokerage customers, tax preparation services, and also investment consulting and education services to plan sponsors and participants of qualified retirement plans through its Klaas 401K service. Information on these additional services is provided in our Form ADV Part 2A Disclosure Brochure, which is available upon request. Performance-Based Fees Our Program Strategies seek to efficiently and effectively capture targeted risk and return characteristics of your investment objective using broad asset allocation exposures, incorporating diversification across sources of risk and return, asset classes, countries, and sectors. Although Program Strategies generally deploy similar approaches for asset allocation, the number and mix of ETFs, mutual funds, and other security types used in accounts, individual client portfolios will vary depending on account size and other practical limitations to implement cost-effective and efficient discretionary portfolio management services in accounts. Asset allocation and diversification are strategies designed to reduce risk, but they do not protect against losses. We do not charge performance-based fees for the Program. Performance-based fees are generally based on a percentage of the capital gains and/or appreciation of the client account assets. Risks Methods of Analysis individual Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Investing carries the risk of loss of principal. Investments in securities are not guaranteed or insured by the FDIC or any other government agency. Past performance is no indication of future performance, and we cannot offer any guarantees or promises that your goals and objectives will be met. As part of our discretionary portfolio management services, Klaas PMG designs, supervises, and manages investment accounts. In general, Program Strategies employ a structured and disciplined approach to investing. Our methodology is anchored in the academically rigorous investment principles of Modern Portfolio Theory and Asset Allocation as the key determinant of portfolio returns. Foundational to this philosophy is:  Recognition of an integral relationship between risk and return;  Diversification across asset classes and portfolio risk sources; and  Time-tested effectiveness of a long-term investment strategy. Although our Program Strategies seek to limit risk through broad diversification among asset classes, all investments involve risk. Asset allocation and diversification are investment strategies used to manage risk, but they do not guarantee a profit nor protect against a Page 6 of 8 Rev. 08-26-2025  loss. Losses can occur by investing in any security, asset class, or investment strategy, including conservative Program Strategies. Even for longer investment time horizons, there is no assurance your investment objectives can be achieved, positive returns cannot be guaranteed as investing in securities necessarily involves a risk of loss. or the government’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign), and currency risk. If bonds have maturities of 10 years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and currency risk. Corporate Debt securities are not guaranteed or insured by the FDIC or any other government agency. In addition to general market risks, investment strategies may be subject to the risk of loss arising from direct or indirect exposure to catastrophic or geopolitical events, such as global pandemics, natural disasters, acts of terrorism, war, sanctions, cyber-attacks, or network outages. The extent and impact of any such event on investment strategies will depend on many factors, including the duration and scope of the event, the extent of any governmental restrictions, the effect on the supply chain, overall consumer confidence, and the extent of the disruption to global and domestic markets. Risks of Specific Securities Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank, and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity. Our Program Strategies typically invest in ETFs and mutual funds. However, we may use a variety of security types: Municipal Securities – Municipal securities carry different risks than those of corporate government and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal level, but can be taxable in individual states other than the state in which both the investor and municipal issuer are domiciled. Municipal securities are not guaranteed or insured by the FDIC or any other government agency. Equity Securities – Investing in individual stock positions involves inherent risk, including the potential for greater concentration risk related to a single company or business enterprise. Significant risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk, and liquidity risk. Equity securities are not guaranteed or insured by the FDIC or any other government agency. U.S. Government Securities – U.S. government securities include securities issued by the U.S. Treasury and by U.S. government agencies and instrumentalities. U.S. government securities may be supported by the full faith and credit of the United States. Voting Client Securities Klaas does not accept voting authority for client proxies, and does not provide advice to clients on how to vote proxies. In addition, we do not take any action on behalf of clients or provide advice to clients with regard to any class action lawsuit or bankruptcy related to securities held in client accounts. In instances where an Asset Manager is used, proxy voting policies will be set forth in its respective disclosure brochure. Item 7. Client Information Provided to Portfolio Managers Mutual Fund Securities – Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. Active mutual funds have higher fees and costs that can result in lower investment returns. Mutual funds are not guaranteed or insured by the FDIC or any other government agency. investment objectives, risk As described in Services, Fees and Compensation above, through discussions, interviews, and questionnaires, we will assist you in determining your tolerance, and investment time horizon, and any applicable investment policies, guidelines, or reasonable restrictions. Your investment portfolio is generally managed internally by Klaas PMG. In rare instances, if we select an Asset Manager to manage all or a portion of your investment portfolio, we will provide the Asset Manager with basic information about you, including any reasonable restrictions you impose on your investment portfolio. Item 8. Client Contact with Portfolio Managers Exchange Traded Fund (ETF) Securities – Exchange-traded funds are investment companies with shares that are bought and sold on a securities exchange. Generally, an ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, Powershares® and iShares®. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Certain ETFs or ETNs employ leverage, which creates additional volatility and price risk. ETFs are not guaranteed or insured by the FDIC or any other government agency. Clients are encouraged to contact us to discuss any questions you have regarding your investment portfolio. If an Asset Manager is used, you may contact us to arrange for a consultation with the Asset Manager, or you may contact the Asset Manager directly. Corporate Debt Securities, Commercial Paper, and Certificates of Deposit – Fixed income securities carry different risks than those of equity securities described above. These risks include the company’s Page 7 of 8 Rev. 08-26-2025  Item 9. Additional Information tolerance level. Rebalancing may generate a taxable transaction for you. Disciplinary Information There are no legal or disciplinary events that are material to an evaluation of Klaas’s advisory business. Other Financial Industry Activities and Affiliations We will periodically review each client’s financial plan, goals, and constraints to determine if risk/return and/ or investment portfolio allocation need revision as a result of changes in the client’s financial circumstances. If changes are necessary, we will update investment policy guidelines and implement the Program Strategies as deemed appropriate. fixed insurance products through various Reviews may be triggered by material market, economic or political events, or by changes in client’s financial situations (such as retirement, termination of employment, physical move, or inheritance). Investment Adviser Representatives with Klaas are insurance licensed to offer insurance companies. Clients are not obligated to execute insurance purchases through these individuals. However, should clients choose to execute securities transactions through these individuals, then clients are advised they will pay a commission to them and a conflict of interest exists. Code of Ethics and Personal Trading Klaas provides clients with reviews of Program accounts on at least an annual basis. Account reviews are not a substitute for periodic account statements received from the custodian or Form 1099. Account reviews should not be used to calculate fees or to complete income tax returns. required of our Client Referrals and Other Compensation We have adopted a Code of Ethics (Code) to address the standards Investment Adviser of business conduct Representatives and employees. The Code includes policies and procedures designed to protect your interests. The Code includes, but is not limited to, the following provisions:   We do not currently compensate any unaffiliated persons or entities for referring clients to us. In the event we enter into such an agreement for receiving client referrals, we will update this item as necessary. Any referral arrangements we may enter into will comply with applicable rules governing the nature of the referral arrangement, the fees to be paid, and the disclosure of the arrangement to clients.     To uphold our fiduciary duty to put your interest ahead of ours at all times. To comply with all applicable laws and to maintain a standard of conduct. To avoid actual or potential conflicts of interest where possible, and to fully disclose any actual or potential conflicts that may exist. To conduct all personal securities transactions of our Investment Adviser Representatives and employees in a manner consistent with the Code. To avoid giving or receiving gifts that may influence decisions. To prevent any abuse of our position of trust and responsibility, including the use of inside information we may obtain. You may obtain a complete copy of our Code upon request. Review of Accounts Clients occasionally seek recommendations for third-party service providers such as insurance agents, estate planning attorneys, or accountants (Service Providers), for assistance with carrying out our financial planning recommendations. We have developed the Klaas Professional Network (KPN), which is a list of Service Providers with whom Klaas has worked in the past and who we believe provide quality services to their clients. KPN is provided as a convenience to clients only, and clients are encouraged to perform their own due diligence on qualified professionals before engaging their services. Klaas and Service Providers agree to share information with each other, as authorized by the client, as necessary to provide coordinated services to clients. No monetary compensation is provided by either Klaas or Service Providers to participate in KPN. Financial Information Klaas PMG conducts regular and ongoing monitoring, review, and due diligence of client accounts, Program Strategies, underlying investment products, and Asset Managers. rebalance the discretionary Because we do not require prepayment of advisory fees six months or more in advance, we are not required to provide a balance sheet. We have not been the subject of any bankruptcy proceedings. investment We will periodically management account holdings within your account. The primary goal is to ensure the market value of the investments in asset class and allocation parameters remain aligned with the percentage of the total market value of the entire client account, within a reasonable Page 8 of 8 Rev. 08-26-2025