MOLDENHAUER & ASSOCIATES

Form ADV Part 2A Item 1 – Cover Page Buffalo Business & Estate Services LTD d/b/a Moldenhauer & Associates 6195 West Quaker Street Orchard Park, NY 14127 (716) 662-4361 www.moldenhauerassociates.com January 20, 2026 This brochure provides information about the qualifications and business practices of Moldenhauer & Associates. If you have any questions about the contents of this brochure, please contact us at (716) 662-4361 or info@moldenhauerassociates.com The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Moldenhauer & Associates also is available on the SEC’s website at www.adviserinfo.sec.gov. Moldenhauer & Associates is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. 1 Revised January 2026  Item 2 – Material Changes The following is a summary of the changes made to this Brochure since the last update on October 31, 2025: • We have updated Item 4 to reflect the firm’s current assets under management You may request a copy of our current Brochure at any time, without charge, by calling us at (716) 662- 4361 or e-mailing us at info@moldenhauerassociates.com. Additional information about Moldenhauer & Associates is available via the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with the firm who are registered, or are required to be registered, as Investment Adviser Representatives of Moldenhauer & Associates. 2 Revised January 2026  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business .......................................................................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................ 11 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 17 Item 7 – Types of Clients ............................................................................................................................ 17 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 17 Item 9 – Disciplinary Information .............................................................................................................. 25 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 25 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 26 Item 12 – Brokerage Practices .................................................................................................................... 27 Item 13 – Review of Accounts .................................................................................................................... 29 Item 14 – Client Referrals and Other Compensation .................................................................................. 29 Item 15 – Custody ....................................................................................................................................... 30 Item 16 – Investment Discretion ................................................................................................................. 31 Item 17 – Voting Client Securities .............................................................................................................. 31 Item 18 – Financial Information ................................................................................................................. 32 3 Revised January 2026  Item 4 – Advisory Business About Us Buffalo Business & Estate Services LTD d/b/a Moldenhauer & Associates is a registered investment adviser offering financial planning and asset management services to clients. The firm has been in business since 1974, and its principal owners are Richard Moldenhauer and Brett Moldenhauer. This Brochure is designed to provide detailed and clear information relating to each item noted in the table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred to in an effort to be as comprehensive as possible on the broad subject matters discussed. Within this Brochure, certain terms in either upper- or lowercase are used as follows: • • • “We,” “us,” and “our” refer to Moldenhauer & Associates. “Advisor” refers to persons who provide investment recommendations or advice on behalf of Moldenhauer & Associates. “You,” “yours,” and “client” refer to clients of Moldenhauer & Associates and its advisors. Description of Services Available Moldenhauer & Associates offers a suite of investment advisory services and programs to its advisors for use with their clients. Our investment advisory services and programs are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Through these various advisory programs and services, clients have access to a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products (“ETPs”); options and derivatives; unit investment trusts (“UITs”); and variable and fixed-indexed insurance products, as well as other products and services, including a variety of asset allocation services, financial planning, and consulting services. Depending on your individual goals, objectives and risk tolerance, we also offer advice on direct participation programs, private placements, and other alternative investments. Financial Planning Services Our advisors provide advisory consulting services on a wide range of topics, including, but not limited to, comprehensive financial planning, budgeting and cash flow analysis, major purchases, education planning, retirement income/longevity planning, portfolio analysis, estate planning analysis, investment analysis, business succession planning, and fringe benefit analysis. Our financial planning process begins with a consultation to determine your assets, liabilities, investment objectives, present and future foreseeable financial obligations, income, and risk tolerance. Using this information, we will create a financial plan consistent with your needs. When the plan is completed, we will meet with you to present the plan and answer any question you may have. You may also engage us for an annual update of your financial plan. The fees for both the initial plan and subsequent annual updates (if desired) are listed in Item 5 of this brochure. 4 Revised January 2026  Commonwealth Financial Network (“Commonwealth”) makes available certain consulting services programs to our firm as part of our contract with Commonwealth for platform services. These consulting services programs are described below. In such cases where we offer Commonwealth’s consulting services programs to you, Moldenhauer & Associates remains responsible for the suitability and appropriateness of the investment advisory services provided. This arrangement does not create an advisory relationship between Commonwealth and Moldenhauer & Associates or Commonwealth and you. It is our responsibility to comply with all laws, rules, and regulations governing the provision of investment advice to you, including, but not limited to, the Investment Advisers Act of 1940 (“Advisers Act”), as amended, and the rules promulgated thereunder, as well as all applicable state statutes, rules, and regulations that apply to our business. Our firm is responsible for the accuracy of all records that reflect your financial condition, risk tolerance, and investment objectives of your account(s); that the orders that we place with or through Commonwealth on your behalf are suitable for you and consistent with our fiduciary duty to you; and that the investment advice and advisory services provided to you in general are and remain appropriate for you. Commonwealth will provide, or cause to be provided, to clients trade confirmations and custodial account statements. Commonwealth will provide or will otherwise make available to the advisor duplicate trade confirmations and Client custodial account statements. We have entered into an agreement with Commonwealth to offer Commonwealth’s Wealth Management Consulting, Retirement Plan Consulting and Plan Participant Consulting programs. Wealth Management Consulting: We provide advisory consulting services on a wide range of topics, including, but not limited to, comprehensive financial planning, budgeting and cash flow analysis, major purchases, education planning, retirement income/longevity planning, portfolio analysis, estate planning analysis, investment analysis, business succession planning, and fringe benefit analysis. Clients may also elect to enter into consulting or financial planning engagements with advisors separately from, in addition to, or as part of their managed account program, as may be agreed between the client and advisor. Retirement Plan Consulting: We provide a fee-for-service consulting program whereby our advisors offer onetime or ongoing advisory services to qualified retirement plans. Through the Retirement Plan Consulting Program, advisors assist plan sponsors with their fiduciary duties and provide individualized advice based upon the needs of the plan and/or plan participants regarding investment management matters, such as: Investment policy statement support • • Plan menu design and monitoring • Service provider support • Participant advice programs Plan Participant Consulting: We provide a fee-for-service consulting program whereby advisors offer ongoing advisory services to an individual retirement account (“IRA”) formed under a SIMPLE IRA Plan. Through the Plan Participant Consulting Program, advisors can assist a client with a variety of advisory services such as: • Financial planning and portfolio analysis • Education on the options available through the SIMPLE IRA Plan • Recommended asset allocation 5 Revised January 2026  Clients who participate in one or more of Commonwealth’s programs will receive Commonwealth’s Form ADV Part 2 and/or Wrap Fee Brochure, in addition to Moldenhauer & Associates’ Form ADV Part 2. Clients should refer to Commonwealth’s Form ADV Part 2 and/or Wrap Fee Brochure for detailed information about Commonwealth and Commonwealth’s programs. Asset Management Services Through our agreement with Commonwealth, Commonwealth’s PPS Custom Account Program and PPS Select Account Program are offered. PPS Custom: The PPS Custom Program enables an advisor to assist the client in developing a personalized investment portfolio using one or more investment types, including, but not limited to, stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), UITs, variable and fixed-indexed annuities, and alternative investments. The advisor typically acts as portfolio manager with full investment discretion. The PPS Custom Program charges a quarterly platform fee based on the total assets in your account rather than the number of trades. This fee helps support the cost of transactions and annual account maintenance. The advisor has chosen to cover the platform fee on the client’s behalf. Commonwealth does not assess this fee on assets invested in NTF (no-transaction-fee) funds. Because the advisor is paying the platform fee for the client, they have an incentive to favor NTF funds over TF (transaction-fee) funds or other investments that could trigger the fee. This creates a potential conflict of interest. Clients who choose to open a PPS Custom Program account should carefully consider the costs and benefits of whether they or their advisor should pay the platform fee. PPS Custom Program clients should consider the annual fees, administrative and other charges, revenue-sharing arrangements, and other compensation that Commonwealth and the advisor receive in making a fair and reasonable assessment of the total costs associated with their decision to open and maintain a PPS Custom Program account. PPS Select: The PPS Select Program offers a variety of model portfolios from which investors may choose. The PPS Select model portfolios are created and managed on a discretionary basis by Commonwealth’s Investment Management and Research team and in the case of Personalized Indexing, Orion Portfolio Solutions, LLC. The advisor will help the client determine which PPS Select models are best suited for the client based on his or her risk profile, investment objectives, and preferences, leaving the actual trading decisions to the Investment Management and Research team. PPS Select offers a variety of model portfolios with varying investment product types, including mutual fund and ETF portfolios, equity portfolios, fixed income portfolios, and variable annuity subaccount portfolios. We also offer clients access to certain Third-Party Asset Manager (“TPAM”) programs, which provide access to professional third-party money managers. TPAM programs offer clients access to a variety of portfolio managers that create and implement model portfolios with varying levels of risk from which investors may choose in consultation with their advisor. TPAM program accounts are not managed by Moldenhauer & Associates or the client’s advisor. Rather, TPAM Program accounts are managed by one or more third-party portfolio managers on a discretionary basis, and they may consist of a variety of different security types, including stocks, bonds, ETFs, mutual funds, and derivatives. Account minimums for TPAM Program accounts generally range between $25,000 and $50,000, although lower or higher account minimums exist in certain programs or models. 6 Revised January 2026  Should you choose to invest in a TPAM Program account, the firm and your advisor will provide you with portfolio management supervisory services with respect to the TPAM programs you select. That means that we will monitor the TPAM Program’s performance, investment selection, and continued suitability for your portfolio and will advise you accordingly. Your advisor will help you determine your risk tolerance, investment goals, and other relevant guidelines to help you choose a TPAM Program that appears to satisfy your investment needs. Moldenhauer & Associates acts in either a “promoter” or “subadviser” capacity when making TPAM programs available to clients, as described below: • Promoter: When the firm acts as a compensated promoter for the TPAM Program sponsor, neither the firm nor your advisor is appointed by you as an investment adviser in relation to the TPAM Program. Instead, your advisor will assist you in selecting one or more TPAM programs believed to be suitable for you based on your stated financial situation, investment objectives, and financial goals. The firm and your advisor are compensated for referring you to the ongoing advisory services provided to you within the TPAM Program. This compensation generally takes the form of the TPAM sharing with the firm and your advisor a percentage of the advisory fee that you pay to the TPAM Program sponsor. When we act as Promoter for a TPAM Program, you will receive a Promoter disclosure statement describing the nature of our relationship with the TPAM Program, if any; the terms of our compensation arrangement with the TPAM Program, including a description of the compensation that we will receive for referring you to the TPAM Program; and the amount, if any, that you will be charged that is in addition to the advisory fee you will pay to the TPAM as a result of our referral of you to the TPAM Program • Adviser or Subadviser: Under an adviser or subadviser relationship between the firm and the sponsor of the TPAM Program, the firm and your advisor will act as an investment adviser or subadviser to you. We will provide you with portfolio management supervisory services with respect to the adviser or subadviser TPAM programs you select. This means that we will periodically monitor the TPAM Program’s performance, investment selection, and continued appropriateness for your portfolio and will advise you accordingly. Your advisor will help you determine your risk tolerance, investment goals, and other relevant guidelines to help you choose a TPAM Program designed to help you satisfy your investment needs. The specific advisory program you select may cost you more or less than purchasing program services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account; the historical or expected size or number of trades for the account; the types of securities and strategies involved; the amount of fees, commissions, and other charges that apply at the account or transaction level; and the number and range of supplementary advisory and client-related services provided to the account. Lower fees for comparable services may be available from other sources. You are under no obligation to engage us for services and are free to use the firm of your choice. Investment recommendations and advice offered by our firm and its advisors do not constitute legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice they receive from their advisor with their attorney and accountant. Clients should also inform their advisor promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify the advisor of any material changes could result in investment advice not meeting the changing needs of the client. 7 Revised January 2026  IRA Rollover Considerations As part of our financial planning and advisory services, we may provide you with recommendations and advice concerning your employer retirement plan or other qualified retirement account. When appropriate, we may recommend that you withdraw the assets from your employer’s retirement plan or other qualified retirement account and roll the assets over to an individual retirement account (“IRA”) to be managed by our firm or a Third-Party Manager that we recommend. If you elect to roll the assets to an IRA under our management, we will charge you an asset-based fee as described in Item 5. This practice presents a conflict of interest because our Advisory Representative has an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have your IRA assets managed under our program or a Third-Party Managed Program. You have the right to decide whether to complete the rollover and the right to consult with other financial professionals. Some employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer’s (former employer’s) plan. 2. Roll over the funds to a new employer’s retirement plan. 3. Cash out and take a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your financial advisor, CPA and/or tax attorney. Before rolling over your retirement funds to an IRA for us to manage or to a Third-Party Managed Program, carefully consider the following. NOTE: This list is not exhaustive. 1. Determine whether the investment options in your employer’s retirement plan address your needs or whether other types of investments are needed. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Your current plan may have lower fees than our fee and/or the Third-Party Manager’s fee combined. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer’s retirement plan and how the costs of those share classes compare with those available in an IRA. 3. You should understand the various products and services available through an IRA provider and 4. their costs. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. If your plan offers management services, the fee associated with the service may be more or less than our fee and/or the Third- Party Manager’s fee combined. 5. The Third-Party Manager’s or our management strategy may have higher risk than the options provided to you in your plan. 8 Revised January 2026  6. Your current plan may offer financial advice, guidance, management and/or portfolio options at 7. no additional cost. If you keep your assets titled in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 8. Your 401(k) may offer more liability protection than a rollover IRA; each state varies. Generally, Federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies; however, there can be exceptions. Consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 9. You may be able to take out a loan on your 401(k), but not from an IRA. 10. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or a home purchase. 11. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 12. Your plan may allow you to hire us or another firm as the manager and keep the assets titled in the plan name. It is important that you understand your options, their features, and their differences, and decide whether a rollover is best for you. If you have questions, contact us at our main number listed on the cover page of this brochure. In addition to complying with applicable SEC rules, Moldenhauer & Associates is subject to certain regulations adopted by the U.S. Department of Labor (“DOL”) when we provide discretionary investment advice to retirement plan sponsors, plan participants, and IRA owners. To the extent that your advisor exercises discretionary authority with respect to the management of your account, the firm and your advisor will be deemed a “fiduciary” for purposes of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, and the Internal Revenue Code of 1986 (“Code”), as amended under Section 3(21) of ERISA or Section 4975 of the Code, as applicable, with respect to such advisory services. The firm and your advisor will also be deemed a “fiduciary” when we make nondiscretionary account recommendations or otherwise provide “investment advice” as defined under Section 3(21) of ERISA or Section 4975 of the Code with respect to your account. The firm and our advisors may not receive payments that create conflicts of interest when providing fiduciary investment advice to plan sponsors, plan participants, and IRA owners, unless we comply with a prohibited transaction exemption (“PTE”). When providing nondiscretionary investment advice, the firm and its advisors will comply with ERISA and the Code by utilizing PTE 2020-02. As fiduciaries under ERISA and the Code, we render advice that is in plan participants’ and IRA customers’ best interest. The firm’s and its advisors’ status as an ERISA/Code fiduciary is limited to discretionary advisory services as described above and ERISA/Code-covered nondiscretionary advice and recommendations regarding rolling over a retirement account and does not extend to all situations. Individualized Services and Client-Imposed Restrictions The investment advisory services provided by our advisors depend largely on the personal information the client provides to the advisor. In order for our advisors to provide appropriate investment advice to, or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very important that clients provide accurate and complete responses to their advisor’s questions about their financial condition, needs, goals, and objectives and notify the advisor of any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their managed account. 9 Revised January 2026  It is also important that clients promptly inform their advisor of any changes in their financial condition, investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the management of their account, if any, that may affect their overall investment goals and strategies, or the investment advice provided, or investment decisions made by their advisor. Failure to notify us of any material changes could result in investment advice not meeting the changing needs of the client. Wrap Fee Programs Certain programs offered by Moldenhauer & Associates are considered “wrap fee” programs in which the client pays a specified fee (known as a “wrap fee”) for portfolio management services and trade execution. Wrap fee programs differ from non-wrap fee programs in that the asset management fee structure for wrap programs is intended to be largely all-inclusive, whereas non-wrap fee programs assess trade execution costs that are typically in addition to the asset management fee. The following programs we offer are wrap fee programs: Most TPAM programs, as well as Commonwealth’s PPS Custom and PPS Select are considered “wrap fee” programs in which the client pays specified fees for portfolio management services and trade execution. TPAM model portfolio wrap fee programs or model strategies available through Commonwealth are managed in accordance with the investment methodology and philosophy used by the respective third- party portfolio manager, investment adviser, or strategist. The PPS Select Program is managed in accordance with the investment methodology and philosophy of Commonwealth’s own Investment Management and Research team. The PPS Custom program is managed by your advisor in accordance with his or her own investment methodology and philosophy. For the investment advisory services provided to you by Commonwealth and your advisor, Commonwealth and your advisor receive a portion of the wrap fees you pay when you participate in any wrap fee program through Commonwealth. Commonwealth receives a higher portion of the wrap fees you pay when you participate in Commonwealth’s PPS Select programs to compensate for the investment management and research services provided by the Commonwealth Investment Management and Research team. Assets Under Management As of December 31, 2025 Moldenhauer & Associates manages $764,911,009.89 in assets on a discretionary basis. Program Choice Conflicts of Interest Clients should be aware that the compensation to the firm and your advisor will differ according to the specific advisory programs or services provided and the account custodians used for your accounts. This compensation to the firm and your advisor may be more than the amounts we would otherwise receive if you participated in another program, used a different custodian, or paid for investment advice, brokerage, or other relevant services separately. Lower fees for comparable services may be available through our firm or from other sources. The firm and your advisor have a financial incentive to recommend advisory programs services and custodians that provide us higher compensation over other comparable programs or services available from our firm or elsewhere that may cost you less. For example, the costs you will incur to have your account managed by our firm may be more than what other similar firms may charge. It’s important to understand all the associated costs and benefits the program and services you select so you can decide which programs and services are best suited for your unique 10 Revised January 2026  financial goals, investment objective, and time horizon. We encourage you to review our Form CRS and to discuss your options with your advisor. We offer advisors a choice of advisory programs to recommend to clients, including, for example, PPS Custom and PPS Select. In PPS Custom, the advisor provides the investment management services directly and therefore receives a greater percentage of the total client fee when compared to PPS Select and other third-party managed advisory programs. This creates an incentive for advisors to recommend to clients that they manage accounts directly, even in a situation when the client may benefit from the investment management services of a third party or outsourcing services to Commonwealth. Item 5 – Fees and Compensation Asset Management Programs Clients who elect to receive asset management services through one or more of our asset management programs or TPAM programs will generally pay the firm and their advisor for those services with an annual asset management fee based on a percentage of assets under management, including cash and money market positions. The standard account management fee charged in any of our firm’s managed account program is listed below. The fee schedules for TPAM programs are provided in the respective TPAM sponsor’s Form ADV Part 2A and advisory client agreements. Certain managed account programs have lower maximum annual fee amounts, and fee schedules will vary among programs but will not exceed 1.25%. Clients are urged to carefully review and discuss the contents of this Brochure with their advisor, including descriptions of the various programs and services offered, the fees and charges clients will pay, the means by which the firm and your advisor are compensated, and the conflicts of interest that exist between the client and the firm and your advisor in respect to each program or service offered, to determine the most appropriate programs or services for your specific needs. The fee schedule offered by Moldenhauer & Associates is generally referred to as a “breakpoint” schedule. Breakpoint Schedule A breakpoint schedule looks at the account value and compares it to a set fee schedule. Based upon the value of the account at the end of the billing period, the billable fee rate will decline as the value of the account reaches the next fee rate, or “breakpoint.” The total value of the account is compared against the fee rate for the respective value range that corresponds with the account value to determine the total account fee for that period. For example, assume the advisor and client negotiate the following breakpoint fee schedule: Account Value $0-$999,999 $1,000,000-$2,500,000 $2,500,000 and over Management Fee 1% 0.85% 0.72% Also, assume the account value at the end of the billing period is $200,000. In this hypothetical example, and assuming an advanced quarterly billing cycle is applied, the account fee for the upcoming quarter 11 Revised January 2026  would be assessed as follows: The $200,000 account value falls within the fee schedule value range of $0 to less than $1,000,000which corresponds with a fee rate of 1 percent. Therefore, $200,000 x 1 = $2,000; $2,000 ÷ 4 = an $500 advance quarterly account fee. Commonwealth PPS Program Fee Schedules PPS Custom Program Unless otherwise agreed between the client and the advisor, clients participating in the PPS Custom Program will pay a total account fee that consists of a combination of a management fee, which is negotiable, and a platform fee. Depending upon the mutual fund families selected, transaction charges will also apply. The standard total account fee schedule for a new PPS Custom Program account is: Account Value $0-$999,999 $1,000,000-$2,500,000 $2,500,000 and over Management Fee 1% 0.85% 0.72% Transaction charges of $15 for buys and sells and a maximum of $3 for periodic investment plans and systematic withdrawal plans will apply in the following mutual fund families: Dodge & Cox, Vanguard, and Dimensional Fund Advisors (DFA), except that DFA sells are $0. For trader-assisted transactions, an additional $5 fee is charged which can be paid by the firm if the firm is covering transaction fees or by the client if the client is being charged transaction fees. A transaction charge of $1 per contract for purchases and sales of options will apply. A $5 quarterly paper document fee will apply account by account to all accounts not enrolled in electronic delivery of statements and confirmations. PPS Select Program Clients participating in the PPS Select Program will pay a total account fee that consists of a combination of an advisor fee and a program fee. The standard advisor fee for a new account in the PPS Select Program is as follows: Account Value $0-$999,999 $1,000,000-$2,500,000 $2,500,000 and over Management Fee 0.75% 0.60% 0.47% In addition to the annual advisor fee, all clients participating in PPS Select will pay an annual program fee. There are several different PPS Select model portfolios with program fees that vary; however, the 12 Revised January 2026  maximum fee within the PPS Select program is as follows: 1 The maximum annual advisor fee for certain account sizes and types may be negotiated. 2 Commonwealth will charge a minimum annual program fee of $600 ($150 quarterly) for certain accounts, which may exceed the maximum annual program fee percentage based on account size. Commonwealth performs fee billing on our firm’s behalf. In most cases, the annual account management fees are payable quarterly in advance and are computed as one quarter of the annual fee based on the account’s AUM on the last business day of the previous calendar quarter. To the extent that you hold positions in your account for which pricing data is not readily available, Commonwealth receives quarter-end values from alternative investment issuers or other service providers which are used when calculating billable AUM for our clients. Neither our firm nor Commonwealth engages in an independent valuation of your account assets and relies on valuations provided by the investment issuers or other service providers. We (via Commonwealth and further via the account custodian) will provide periodic account statements which include the market value of the alternative investment based on information received from the investment issuer or other service provider. In providing these account statements, or any other valuation information to you, (i) we rely on the valuation information provided by the manager of the alternative investment or other service provider, (ii) the valuation information used to determine the billing fee is based on estimates that may be outdated as of the dates of the account statements, (iii) the products final valuations may be higher or lower than the values reflected in the periodic account statements and (iv) while Commonwealth will adjust material estimated fee billings on our behalf, neither we nor Commonwealth is under no obligation to provide notice or compensation to you for differences in estimated alternative investment valuations. *Account values in the Commonwealth reporting system will be used for our firm’s quarterly fee calculations for advisory accounts custodied at National Financial Services (NFS). Although account holdings and asset valuations should generally match, month-end market values reflected in Commonwealth's Practice 360 reporting system sometimes differ from those provided by NFS on their month-end statements. The three most common reasons why these values may differ are (i) differences in the manner in which accrued interest is calculated, (ii) differences in the date upon which "as of" dividends and capital gains are reported, and (iii) differences in whether settlement date valuations or trade date valuations are used. If you have any questions or believe there are material discrepancies between your NFS custodial statement and Commonwealth's reporting system, please contact us. The Commonwealth report valuations are available online via your Investor360 account or you may request a copy from your advisory representative. Clients who elect to open a margin account acknowledge and agree that margin may be exercised against their account for purposes including, but not limited to, covering debits, management fees, and/or other billing and administrative costs. Management fees on margin accounts will be assessed on the equity (e.g., ownership) portion of the account and not on the account’s total market value. 13 Revised January 2026  All Moldenhauer & Associates advisory program fees are negotiable. This means that advisors can negotiate lower fees with certain clients when similar services are provided to other clients at a higher fee rate. Program and/or platform fees (if applicable), transaction charges and other account-related fees assessed by the account custodian or Commonwealth are not negotiable. We may waive all or a portion of the advisory program and/or platform fee, whether on an ongoing or a one-time basis, in our sole discretion. In the event a client terminates an advisory agreement with the firm, any unearned fees resulting from payments made by clients in advance will be refunded to the client. Likewise, in the event the firm bills clients in arrears for services that have already been rendered, we will prorate such fees up to the termination date of the advisory agreement. Financial Planning Programs Our standard fee schedule for financial planning services is as follows: Wealth Management Consulting: The program provides clients with the option of paying an annual fee for ongoing services, a flat or fixed fee, or an hourly rate not to exceed $500. The fee amount a client will pay is negotiable between the client and his or her advisor and may either be paid at the time of service, in advance of service, or after services have been rendered (“in arrears”). Annual fees may be paid in monthly, quarterly, semiannual, or annual installments as agreed between the client and the advisor. Retirement Plan Consulting: The program provides clients with the option of paying an annual fee for ongoing services based on a percentage of assets under advisement or a flat fee. The fee amount a client will pay is negotiable between the client and the advisor and will be associated with all services provided by the advisor under the Retirement Plan Consulting Agreement. It is the responsibility of the plan sponsor to ensure that these fees are reasonable. Fees may be paid directly from qualified plan assets or may be direct billed, as agreed between the client and the Advisor. Plan Participant Consulting: The program calls for clients to pay an annual flat percentage fee according to the following fee schedule: Managed Account Fee Collection Process Managed account fees are typically automatically charged to the client’s account pursuant to instructions provided to the account custodian by the firm or a TPAM. Managed account clients will generally pay fees quarterly, in advance, based on the specific program selected. Consulting clients will pay fees at time of service or in advance of service, as well as in monthly, quarterly, semiannual, or annual installments, as agreed to between the client and the advisor. The initial quarterly fee will be prorated based on the number of billing days in the initial quarter. Fees are based on account value and account type and are negotiable. Other methods of fee calculation exist or are possible, depending on the specific program, the services provided, client circumstances, and the account size. These methods include, but are not limited to, hourly, flat, breakpoint, and blended fee billing. Additional deposits of funds and/or securities during a particular calendar quarter are subject to billing on a pro rata basis. Clients who withdraw funds from a managed account during a billing period are 14 Revised January 2026  not generally entitled to a pro rata refund unless they are terminating their managed account program client agreement. We aggregate assets among a client’s “related” managed accounts for purposes of determining the value of AUM and the applicable advisory fee to be paid by a client. We reserve the right to determine whether client accounts are “related” for purposes of aggregating a client’s accounts together for a reduction in the percentage fee amount. Other Fees and Costs Clients incur certain charges in connection with certain investments, transactions, and services in your account. In many cases, Commonwealth will receive a portion of these fees and charges or add a markup to the charges clients would otherwise pay to generate additional revenue for Commonwealth. The actual fees and charges that clients will incur are dependent upon the type of account and the nature and quantity of the transactions that occur, the services that are provided, or the positions that are held in the account. Additional fees and charges that clients will typically pay include, but are not limited to: • Mutual fund or money market 12b-1 fees, subtransfer agent fees, and distributor fees • Mutual fund and ETF money market management fees and administrative expenses • Mutual fund transaction and redemption fees • Certain deferred sales charges on mutual funds purchased or transferred into the account • Other transaction charges and service fees • IRA and qualified retirement plan fees • Other charges that may be required by law • Brokerage account fees and charges Information describing the brokerage fees and charges that are applicable to a Commonwealth brokerage or Moldenhauer & Associates managed account is provided on Commonwealth’s Schedule of Miscellaneous Account and Service Fees, which is available on Commonwealth’s website at www.commonwealth.com/for-clients in the For Clients section on the right side of the page. In most cases, mutual fund companies offer multiple share classes of the same mutual fund. 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 or other share classes that are 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 that the fund considers qualified fee-based programs. The lowest-cost mutual fund share class for a fund may not be offered through our clearing firm or made available by our firm for purchase within our managed accounts. The firm conducts periodic reviews to ensure clients are invested in the share class with the lowest possible expense ratio or cost. We urge clients to discuss with their advisor whether lower-cost share classes are available in their program account. Clients should also ask their advisor why the funds or other investments that will be purchased or held in their managed account are appropriate for them in consideration of their expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, trading frequency, the amount of the advisory fee charged, whether the client will pay transaction charges 15 Revised January 2026  for fund purchases and sales, whether clients will pay higher internal fund expenses in lieu of transaction charges that could adversely affect long-term performance, and relevant tax considerations. Your advisor may recommend, select, or continue to hold a fund share class that charges you higher internal expenses than other available share classes for the same fund. The purchase or sale of transaction-fee funds available for investment through our firm will result in the assessment of transaction charges to your advisor, the firm or Commonwealth. Although no-transaction- fee funds do not assess transaction charges, most NTF funds have higher internal expenses than funds that do not participate in an NTF program. These higher internal fund expenses are assessed to investors who purchase or hold NTF funds. Depending upon the frequency of trading and hold periods, NTF funds may cost you more, or may cost our firm, Commonwealth or your advisor less, than mutual funds that assess transaction charges but have lower internal expenses. In addition, the higher internal expenses charged to clients who hold NTF funds will adversely affect the long-term performance of their accounts when compared to share classes of the same fund that assess lower internal expenses. Prorated Rebate of Fees Paid in Advance In the event a client terminates an advisory agreement with the firm and his or her advisor, any unearned fees resulting from advanced payments will be refunded to the client. Likewise, in the event the firm bills clients in arrears for services that have already been rendered, we will prorate such fees up to the termination date of the advisory agreement. Other Forms of Compensation As mentioned above, an ongoing asset management fee, billed quarterly in advance, is the most common method of payment for the client and compensation to Moldenhauer & Associates and the advisor. In some cases, the annual account fee may be payable monthly in advance, and certain managed account programs charge fees in arrears or will have differing methods of fee calculation. Please refer to the respective program description in this Brochure, to the respective client agreement, and to the respective TPAM Program Brochure (if applicable) for specific information about the maximum fee allowed, the varying fee schedules of each program, and the methods of fee billing for the program(s) you select. Clients should be aware that, when assets are invested in shares of mutual funds, variable insurance products, and certain alternative investments within a managed account program, clients will pay investment advisory fees to the firm and to the advisor for their advisory services in connection with the investments. In addition to the payments received by the firm and the advisor, clients will also pay management fees, mutual fund and money market 12b-1 fees, subtransfer agent fees, mutual fund and money market administrative expenses, mutual fund transaction fees, certain deferred sales charges and redemption fees on previously purchased mutual funds, annuity internal expenses and fees, and other fees charged by the investment company, insurance product, or alternative investment sponsor, which are typically charged to clients as an internal expense of the product. These internal expenses are described in the prospectus or offering document for the specific product. Clients may be able to invest directly in the investment company, insurance product, or alternative investment without incurring the investment advisory fees, platform fees, or transaction charges assessed by the firm or their advisor. If a client’s assets are invested in a fee-based annuity, the client will pay both the direct management fee to the firm and their advisor for the advisory services provided by the firm and the advisor in connection with that investment and, indirectly, the management and other fees charged by the underlying annuity investment options, as well as the charges assessed by the insurance company for the product. Of course, clients should also be aware of the tax implications of investing, as well as of the existence of deferred 16 Revised January 2026  sales charges or redemption fees charged by some product sponsors for positions the client subsequently sells in the firm’s managed accounts. For California Residents: Subsection (j) of Rule 260.238 of the California Code of Regulations requires that all investment advisers disclose to their advisory clients that lower fees for comparable services may be available from other sources. Special Disclosures for ERISA Plans: In this Brochure, Moldenhauer & Associates has disclosed conflicts of interest, such as receiving additional compensation from third parties for providing marketing, recordkeeping, or other services in connection with certain investments. the firm has taken steps to identify and address the conflict of interest associated with our or our advisors’ receipt of compensation for services provided to ERISA plans. Item 6 – Performance-Based Fees and Side-By-Side Management Moldenhauer & Associates does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients Moldenhauer & Associates generally provides advisory services to the following types of clients: Individuals (other than high net worth individuals) • • High net worth individuals • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses not listed above Moldenhauer & Associates’ managed account programs generally require a minimum investment of $100,000. The firm retains the ability to waive this requirement for any reason in its sole discretion. In some cases, account balances may be combined at the household level to satisfy the account minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that investors should be sure they understand and should be prepared to bear. Our firm primarily serves retail investors Our advisors have the independence to take the approach he or she believes is most appropriate when analyzing investment products and strategies for clients. There are several sources of information that the firm and the advisor may use as part of the investment analysis process. These sources include, but are not limited to: • Prospectuses and offering materials • Product and sponsor sales materials • Sponsor due diligence meetings and product presentations • Financial publications • Research, software, and materials prepared by third parties • Corporate rating services 17 Revised January 2026  • SEC filings (annual reports, prospectus, 10-K, etc.) • Company press releases As a firm, we do not favor any specific method of analysis over another and, therefore, would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a few common approaches that may be used by the firm or your advisor, individually or collectively, in the course of providing advice to clients. It is important to note that there is no investment strategy that will guarantee a profit or prevent loss. Following are some common strategies employed by advisors in the management of client accounts: • Dollar Cost Averaging (“DCA”): The technique of buying a fixed dollar amount of a particular investment on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single investment at higher price. DCA strategies are not effective and do not prevent loss in declining markets. • Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes—equities (stocks), fixed income (bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes are often further divided into domestic and foreign investments, and equities are often divided into small, intermediate, and large capitalization. The general theory behind asset allocation is that each asset class will perform differently from the others in different market conditions. By diversifying a portfolio of investments among a wide range of asset classes, advisors seek to reduce the overall volatility and risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or protect against loss. • Fundamental Analysis: A method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis. • Technical Analysis (aka “Charting”): A method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with the company’s future stock price. It is important to understand that past performance does not guarantee future results. 18 Revised January 2026  • Qualitative Analysis: Securities analysis that uses subjective judgment based on non-quantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however, are often used together. • Tax harvesting: Commonwealth, on behalf of our firm, accommodates requests in certain PPS Select and PPS Direct strategies to perform tax harvesting, with the intention to offset gains or losses in the client’s account to reduce tax liabilities. All PPS Select Personalized Indexing accounts utilize tax harvesting. PPS Select Methods of Analysis and Investment Strategies Commonwealth’s PPS Select Program is based on asset allocation concepts and modern portfolio theory. The PPS Select portfolios are designed to provide long-term, risk-adjusted returns for investors across the risk/return spectrum. Depending on the program and model selected by a client, the program may invest in open-end mutual funds, closed-end funds, ETFs, individual municipal fixed income securities, and individual equity securities managed by Commonwealth’s Investment Management and Research team and in the case of Personalized Indexing, Orion Portfolio Solutions, LLC. When selecting investments for inclusion or removal from the PPS Select portfolios, the Investment Management and Research team conducts extensive due diligence. Commonwealth’s investment philosophy process has five steps: (1) screening, (2) evaluation, (3) analysis, (4) portfolio construction, and (5) ongoing monitoring: • Step 1—Screening: An initial screening process based on quantitative criteria is used as a starting point for further research. Its purpose is to narrow down the universe of investments that meet Commonwealth’s objective criteria. • Step 2—Evaluation: After screening, the investment (or group of investments) under consideration is evaluated by applying a scoring system based on returns that are adjusted to take into account quantifiable risk. The investment is also evaluated based on its peer group ranking, benchmark relative performance, and consistency of investment management style. • Step 3—Analysis: The objective of this step is to build a solid understanding of how the investment operates. During this stage, the Investment Management team spends a great deal of time evaluating the investment’s philosophy and process to ensure that they are consistent. After the in-depth quantitative and qualitative analysis is complete, the team meets with the potential investment’s key decision makers—either on-site or over the phone—to gain a greater understanding of their process for managing the portfolio. • Step 4—Portfolio Construction: After Commonwealth’s portfolio managers have determined that the investment is attractive on a stand-alone basis, they assess how well the investment complements and fits with other PPS Select portfolio holdings. A review of certain metrics, such as excess-return correlation, is performed to reasonably ensure that holdings will perform as expected in different market environments. • Step 5—Ongoing Monitoring: The PPS Select portfolios are monitored on an ongoing basis. The Investment Management and Research team continually conducts performance reviews, holdings-based attribution analysis, firm commentary reviews, and conference calls and meetings to determine whether a portfolio is meeting the team’s risk-adjusted return expectations and an investment’s stated objective. Risks of Loss 19 Revised January 2026  Regardless of what investment strategy or analysis is undertaken, investing in securities involves risk of loss that clients must be prepared to bear; in fact, some investment strategies could result in total loss of your investment. Some risks may be avoided or mitigated, while others are completely unavoidable. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all inclusive but should be considered carefully by a prospective client before retaining our services. Some of the common risks you should consider prior to investing include, but are not limited to: Market risks: The prices of, and the income generated by, the common stocks, bonds, and other securities you own may decline in response to certain events taking place around the world, including those directly involving the issuers; conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic instability; governmental or governmental agency responses to economic conditions; and currency, interest rate, and commodity price fluctuations. Interest rate risks: The prices of, and the income generated by, most debt and equity securities will most likely be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call,” or refinance a security before its stated maturity date, which would typically result in having to reinvest the proceeds in lower-yielding securities. Credit risks: Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Risks of investing outside the U.S.: Investments in securities issued by entities based outside the United States are often subject to the risks described above to a greater extent. Margin transactions: Securities transactions in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan, inherently have more risk than cash purchases. If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a “margin call.” An investor’s overall risk in accounts utilizing margin includes the amount of money invested plus the amount that was loaned to them. Pledging Assets: Pledging assets in an account to secure a loan involves additional risks. The bank holding the loan has the authority to liquidate all or part of the securities at any time without prior notice in order to maintain required maintenance levels, or to call the loan at any time, and this may cause you to sell assets and realize losses in a declining market. In addition, because of collateral requirements imposed by the bank, investment decisions for the account may be restricted. These restrictions, or a forced liquidation, may interfere with your long-term investment goals and/or result in adverse tax consequences. Tax considerations: Our strategies and investments may have unique and significant tax implications. Unless specifically agreed otherwise, and in writing, however, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, it 20 Revised January 2026  is strongly recommended that you consult with a tax professional regarding the investing of your assets. Custodians and broker/dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to average-cost for mutual fund positions and the first-in, first-out (“FIFO”) accounting method for calculating the cost basis of your equity investments or, for PPS Select Personalized Indexing, the short-term tax sensitive accounting method. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and Commonwealth will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of loss: Investing in securities involves risk of loss that you should be prepared to bear. Commonwealth and your advisor do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Liquidity risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. Certain structured products, interval funds, and alternative investments are less liquid than securities traded on an exchange, and you should be aware of the fact that you may not be able sell these products outside of prescribed time periods. You should consult your advisor prior to purchasing products considered illiquid and in instances where changes in your financial situation and objectives may increase your need for liquidity. Inflation risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Time horizon and longevity risk: Time horizon risk is the risk that your investment horizon is shortened because of an unforeseen event (e.g., the loss of your job). This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or nearing retirement. Recommendation of particular types of securities: We will recommend various types of securities and do not primarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. In very general terms, however, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Descriptions of the types of securities we may recommend to you and some of their inherent risks are provided below: • Money market funds: A money market fund is technically a security, and, as such, there is a risk of loss of principal, although it is generally rare. In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation (“FDIC”) insured savings account (money market funds are not FDIC insured). Next, money 21 Revised January 2026  market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. If it goes down, however, and you earn less than you expected to, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long- term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. • Municipal securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. • Bonds: Also known as corporate debt securities, bonds are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. • Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or “stocks”). In very broad terms, the value of a stock depends on the financial health of the company issuing it. Stock prices, however, can be affected by many other factors, including, but not limited to, the class of stock (e.g., preferred or common), the health of the market sector of the issuing company, and the overall health of the economy. In general, larger, more well-established companies (i.e., large-caps) tend to be safer than smaller start-up companies (i.e., small-caps), but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. • Mutual funds and ETFs: Mutual funds and ETFs are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) 29 rather than balancing the fund with different types of securities. ETFs differ from mutual funds in that they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are “no load,” meaning there’s no fee to buy into or sell out of the fund, other types of mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be “closed-end” or “open-end.” Open-end mutual funds continue to allow new investors indefinitely, whereas closed-end funds have a fixed number of shares to sell, which can limit their availability to new investors. ETFs are investment companies that are usually classified as open- end or UITs. Some ETFs, particularly those that invest in commodities, are not registered as an investment company and may be closed and liquidated at the discretion of the issuing company. 22 Revised January 2026  Active ETFs are different from traditional passive index ETFs in that there is a portfolio manager who makes buy/sell decisions on the underlying holdings. Certain ETF sponsors also offer actively managed mutual funds with different fees and expenses even though they have the same or substantially similar objective, strategies, and holdings. The impact of such fees and expenses will vary depending on whether you invest in an ETF or mutual fund based on the size of your initial investment, the length of time you hold the investment, and other factors. In certain situations, mutual fund fees and expenses you pay will be more than in a significantly similar ETF. • Variable annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single-payment annuity) or a series of regular payments (regular-payment annuity). The payment stream from the issuer to the annuitant has an unknown duration based principally upon the date of death of the annuitant. At this point, the contract will terminate, and the remainder of the funds accumulated will be forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable annuities pay amounts that vary according to the performance of a specified set of investments, typically bond and equity mutual funds. Many variable annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges, such as mortality and expense risk charges, administrative fees, underlying fund expenses, and charges for special features, all of which can reduce the return. • Real estate: Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. In fact, real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. The asset class still bears a considerable amount of market risk, however. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or by property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. • Limited partnerships: A limited partnership is a financial affiliation that includes at least one general partner and a number of limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner has management authority and unlimited liability. The general partner runs the business and, in the event of bankruptcy, is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks is dependent on the nature of the partnership and disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities; however, like privately placed 23 Revised January 2026  limited partnerships, their tax treatment is under a different tax regime from equities. You should speak to your tax adviser in regard to their tax treatment. • Private Equity: Private equity investments are speculative and involve significant risks. These investments offer limited diversification, use leverage, and have limited liquidity. The investment timeline for private equity can be a decade or more. Some issuers or general partners may penalize limited partners who redeem before holding units for a specified amount of time or may disallow redemptions entirely. • Leveraged/inverse ETFs, ETNs, and mutual funds: Leveraged products seek to deliver multiples (e.g., 2x) of the performance of the index or benchmark they track. Some leveraged products are inverse or short funds, meaning they seek to deliver the opposite of the performance of the index or benchmark they track. They can track broad indices, sector-specific, or are linked to commodities or currencies. Leveraged and inverse products have unique characteristics and can be riskier than traditional ETFs, ETNs, and mutual funds. Most leveraged and inverse products “reset” daily, meaning they are designed to achieve their stated objectives on a daily basis. To accomplish these objectives, these products may not be diversified and use a range of strategies, including swaps, future contracts, and other derivatives. Due to fund expenses, continuous resetting of returns and other factors, these products may not be able to replicate the index or benchmark they are tracking, also known as tracking error. In addition, for leveraged products, compounding of the returns can produce a divergence over time, which could be amplified in a volatile market with large positive and negative swings. • Value-based investing risk: Value-based investing is also sometimes referred to as “environmental, social, and governance (ESG) investing,” “socially responsible investing,” or “sustainable investing.” These types of strategies may seek to achieve value-based outcomes to achieve exposure to particular goals or themes, and/or to screen out certain companies and industries. Advisors may consider social or environmental goals, including but not limited to corporate governance structures and international, domestic or industry agreements, when determining which securities to include in a portfolio. These investment strategies may reduce or increase a portfolio’s exposure to certain companies or industries and the portfolio may forego certain investment opportunities as a result. Investing in value-based investments or strategies may underperform the market as a whole or underperform other strategies that employ a different type of focus or screening methodology. Fund managers, portfolio managers, advisors, and investors likely define the criteria for a particular value-based goal, such as ESG, differently. Review fund prospectuses and other materials to gain an understanding of how the term is being used in connection with their investment offerings. Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs when governments take away a private business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. These risks may be heightened in connection with investments in developing countries. Investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Any of the common risks described above could adversely affect the value of your portfolio and account performance, and you can lose money. Even though these risks exist, the firm and your advisor will still 24 Revised January 2026  earn the fees and other compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that they may lose principal while the firm and your advisor continue to earn fees and other forms of compensation. Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and as such may lose value. Item 9 – Disciplinary Information Neither Moldenhauer & Associates, its management personnel, nor affiliated advisors have any disciplinary events requiring reporting in this section. Item 10 – Other Financial Industry Activities and Affiliations Our advisors are Registered Representatives and Investment Adviser Representatives of Commonwealth Financial Network, an SEC-registered investment adviser and FINRA-registered broker dealer. As such, they spend less than 5% of their time offering securities products on a commission or fee basis with Commonwealth. Our advisors are also licensed insurance agents and offer various insurance products for which they will be paid a commission. Advisors spend less than 5% of their time offering insurance products. Should you choose to purchase an insurance product on which our advisor is paid a commission, there will be no advisory fee associated with the product. The remainder of the advisor’s time is spent acting in the capacity of an investment adviser representative for Moldenhauer & Associates. Clients are under no obligation to purchase or sell securities through our advisors. However, if you choose to invest with us, commissions may be earned in addition to any fees paid for advisory services depending on the type of account you choose to invest in. Commissions may be higher or lower at Commonwealth than at other broker dealers. Our advisors have a conflict of interest in recommending clients purchase securities and/or insurance related products in that as their production with Commonwealth rises, they receive a higher payout on compensation earned. Depending on the type of account you open, Commonwealth and/or your advisor may receive transaction-based commissions, mutual fund 12b-1 fees, distributor fees, service fees, due diligence fees, marketing reimbursements, revenue sharing, or other payments relating to your investment in or otherwise supporting Commonwealth’s or your advisor’s activities regarding the securities and insurance products recommended, purchased, or held within your account. To the extent Commonwealth is the investment adviser, sponsor, or other service provider to your investment advisory program, Commonwealth receives compensation for its services. Clients should be aware that Commonwealth’s, the firm’s or your advisor’s receipt of commissions, fees, payments, and other compensation presents a conflict of interest because Commonwealth, the firm or your advisor has an incentive to make available or to recommend those products or programs, or make investment decisions regarding investments, that provide such compensation to Commonwealth, the firm or your advisor. Further, our advisors are restricted to only offering those products and services that have been reviewed and approved for sale to the public through Commonwealth pursuant to Commonwealth policy. Moldenhauer & Associates is not and does not have a related company that is a broker dealer, investment company or pooled investment vehicle, other investment adviser or financial planner, futures commission merchant or commodity pool operator, banking or thrift institution, accountant or accounting firm, lawyer 25 Revised January 2026  or law firm, insurance company or agency, pension consultant, real estate broker, or sponsor or syndicator of a limited partnership. Moldenhauer & Associates has chosen to partner with Commonwealth to provide certain services, including but not limited to fee billing and account performance reporting, to our firm and our clients. For the services it provides, Commonwealth charges our advisors an administrative fee at the same time clients are charged asset-based management fees. The administrative fee is charged to and paid by the advisor rather than the advisor’s clients. and is calculated as a percentage of the total account assets, including cash and money market positions, held by the advisor’s clients. In the same manner as we offer asset management fee discounts as your account value grows, Commonwealth offers our advisors discounts on administrative fees based on their total assets under management within our asset management program or Commonwealth’s PPS programs. As these advisors grow their assets in these programs, Commonwealth’s economies of scale are shared with the advisors by reducing the percentage amount of administrative fees that would otherwise be charged to the advisors. These discounts in administrative fees and higher payouts for reaching various AUM levels present a conflict of interest because they provide a financial incentive for advisors who receive the discounts to recommend Commonwealth’s PPS programs or our own asset management program over other available managed or wrap account programs that do not offer such discounts or higher payouts to advisors. On the other hand, because Commonwealth does not assess administrative fees to advisors when they use advisory programs outside of PPS or our own asset management program, depending upon the costs and fees of a particular outside program, advisors may have a financial incentive to use one or more outside programs rather than PPS or our own program, which also creates a conflict of interest. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Pursuant to Rule 204A-1 under the Advisers Act, the firm has adopted a Code of Ethics that governs a number of conflicts of interest we have when providing our advisory services to you. Our Code of Ethics is designed to ensure that we meet our fiduciary obligations to you and to foster a culture of compliance throughout our firm. Our Code of Ethics is comprehensive and is designed to help us detect and prevent violations of securities laws and to help ensure that we keep your interests first at all times. We distribute our Code of Ethics to each supervised person at the time of his or her initial affiliation with our firm; we make sure it remains available to each supervised person for as long as he or she remains associated with our firm; and we communicate updates to our Code of Ethics as changes are made. Our Code of Ethics sets forth certain standards of conduct and addresses conflicts of interest between our firm, our employees, our agents, our advisors, and our advisory clients. Clients and prospective clients of the firm may request a copy of our Code of Ethics at any time. The firm and its advisors often invest in the same securities that we recommend to clients. The firm and its advisors also recommend securities to, and buy and sell securities for, client accounts at or about the same time that we buy or sell the same securities for our own accounts. These activities create a conflict of interest between us and our clients. Our firm policy prohibits “trading ahead” of clients’ transactions 26 Revised January 2026  to the detriment of clients. When the firm and its advisors are purchasing or selling securities for their own accounts, priority will be given to client transactions, or trades will be aggregated together to obtain an average execution price for the benefit of all parties. The firm has implemented surveillance and exception reports that are designed to identify and correct situations in which firm or advisor transactions are intentionally placed ahead of client transactions to the detriment of clients. Item 12 – Brokerage Practices As disclosed previously in this brochure, our advisors are dually registered with Commonwealth Financial Network. Commonwealth policy restricts its advisors from conducting securities transactions away from Commonwealth unless Commonwealth provides the advisor with written authorization. Therefore, clients are advised that our advisors are substantially always limited to conducting securities transactions through Commonwealth and its clearing firms, National Financial Services LLC (“NFS”) and Pershing. Substantially all of the firm’s clients must select Commonwealth as the broker/dealer of record and NFS as the clearing firm for their managed accounts. In all cases, the account custodian will be identified in the respective managed account client agreement. Client transactions will be charged according to Commonwealth's then-current commission schedule and clients may pay higher commission rates and other fees than otherwise available. The client may be assessed transaction or other fees charged by Commonwealth, custodians and/or product sponsors, in addition to normal and customary commissions, all of which are fully disclosed to the client. These fees and expenses are separate and distinct from any fee(s) charged by the firm. This additional compensation received by Commonwealth creates a conflict of interest. Additionally, by using Commonwealth as the broker/dealer for the firm’s managed account program(s), the firm may be unable to achieve most favorable execution of client transactions, which may cost clients more money. The firm attempts to mitigate this conflict of interest by engaging in a regular review of our relationship with Commonwealth to ensure that the costs incurred are reasonable in comparison to industry norms, and by advising our clients that you are not obligated to open an account with the firm or Commonwealth; you may open an account and implement advice provided by the firm with the firm of your choice. Our clients do not generally have the option to direct securities brokerage transactions to other broker/dealers or other account custodians. If, however, a client should request, and Commonwealth approve, the use of a broker/dealer other than NFS or Pershing for securities transaction execution, the client should be aware that the firm will generally be unable to negotiate commissions or other fees and charges for the client’s account, and the firm would not be able to combine the client’s transactions with those of other clients purchasing or selling the same securities (“batched trades”), as discussed further below. As a result, the firm would be unable to ensure that the client receives “best execution” with respect to such directed trades. The firm may also be unable to provide timely monitoring of transaction activity or provide the client with quarterly performance reporting. Block Trading Policy The firm may aggregate (“bunch”) transactions in the same security on behalf of more than one client in an effort to strive for best execution and to possibly reduce the price per share. However, aggregated or bunched orders will not reduce the transaction costs to participating clients. The firm conducts aggregated transactions in a manner designed to ensure that no participating client is favored over another client. Participating clients will obtain the average share price per share for the security executed that day. To the extent the aggregated order is not filled in its entirety and when possible, securities purchased or sold in an aggregated transaction will be allocated pro-rata to the participating client accounts in proportion 27 Revised January 2026  to the size of the orders placed for each account. The amount of securities maybe increased or decreased to avoid holding odd-lot or a small number of shares for particular clients. It should be noted, the firm does not receive any additional compensation or remuneration as a result of aggregation. Soft Dollars The firm does not use commissions to pay for research and brokerage services (i.e., soft dollar transactions). Research, along with other products and services other than trade execution, are available to us on a cash basis from various vendors. institutions The Core Account Sweep Programs (“CASPs”) Through our relationship with Commonwealth, our firm has access to a core account sweep program (“CASP”). CASP is the core account investment vehicle for eligible accounts used to hold cash balances while awaiting reinvestment. The cash balance in your eligible accounts will be deposited automatically or “swept” into interest-bearing FDIC-insurance eligible deposit accounts at one or more FDIC-insured financial interest rates for your eligible accounts may be obtained from at www.commonwealth.com/clients/deposit-sweep-program.aspx. Specific features and account eligibility of CASP are further explained in the Disclosure Document provided to clients that participate in CASP. A current version of the CASP Disclosure Document is available at https://www.commonwealth.com/for- clients/disclosure/core-account-sweep-programs. Clients should note that, though the default options for cash held in accounts are the core account investment vehicles, clients may at any time seek higher yields in other available investment options. Commonwealth keeps a portion of the interest paid by the bank(s) participating in CASP as a fee for providing bank sweep services. This fee reduces the rate of interest you receive on your cash in the bank sweep program. The firm receives no financial benefits from the CASP program. We encourage our clients to review CASP program details to understand how Commonwealth and the program banks get paid for the sweep program and to discuss other available investment options should you wish to do so. NTF Program Additionally, NFS offers an NTF program composed of no-load mutual funds. Participating mutual fund sponsors pay a fee to NFS to participate in this program, and a portion of this fee is shared with Commonwealth. None of these additional payments is paid to the firm or any advisors who sell these funds. NTF mutual funds may be purchased within an investment advisory account at no charge to the client. Clients, however, should be aware that funds available through the NTF program often contain higher internal expenses than mutual funds that do not participate in the NTF program. Commonwealth’s receipt of a portion of the fees associated with the NTF program creates a conflict of interest because Commonwealth has an incentive to make available those products that provide such compensation to NFS and Commonwealth over those mutual fund sponsors that do not make such payments to NFS and Commonwealth. While Moldenhauer & Associates does not receive additional compensation from NFS or Commonwealth based on the particular investment (potentially including one or more NTF funds), our menu of investment options is limited to investments made available by Commonwealth. Thus, clients may be impacted by the conflict of interest previously described in this paragraph. As stated previously, the firm regularly evaluates our relationship with Commonwealth to ensure it remains appropriate for the firm and our clients. 28 Revised January 2026  The investment advisory services provided by the firm may cost the client more or less than purchasing similar services separately. Clients should consider whether the appointment of Commonwealth as the sole broker/dealer may result in certain costs or disadvantages to the client as a result of possibly less favorable executions. Factors to consider include the type and size of the account and the client’s historical and expected account size or number of trades. Item 13 – Review of Accounts All asset management client accounts are reviewed by an Investment Advisor Representative (IAR) of the firm on a quarterly basis, or when changes in client circumstances or market conditions warrant. Securities held in managed accounts are regularly reviewed by the firm’s investment committee. Clients will be provided statements at least quarterly directly from account custodian where your assets are maintained. Additionally, you will receive confirmations of all transactions directly from account custodian. All non-retirement accounts and retirement accounts for those clients taking distributions will receive an annual tax reporting statement. In addition, at least once a year, all managed account clients will receive a performance report. You should compare the report with statements received directly from the account custodian(s). Should there be any discrepancy; the account custodian’s report will prevail. Item 14 – Client Referrals and Other Compensation Our firm receives non-cash benefits from Commonwealth in the form of the support, products and services Commonwealth makes available to us and other investment advisors whose clients maintain their accounts on Commonwealth’s platform. These products and services, how they benefit us, and the related conflicts of interest are described in Item 12 of this brochure. Our access to Commonwealth’s products and services is not conditioned on our firm or our advisors giving particular investment advice, such as buying particular securities for our clients. Product vendors recommended by the firm may provide monetary and non-monetary assistance for the purposes of funding marketing, distribution, business and client development, educational enhancement and/or due diligence reviews incurred by the firm or our advisors relating to the promotion or sale of the product vendor’s products or services. We do not select products as a result of the receipt or potential receipt of any monetary or non-monetary assistance. Our due diligence of a product does not take into consideration any assistance it may receive. While the receipt of products or services is a benefit for you and us, it also presents a conflict of interest. We attempt to mitigate this conflict of interest by: Informing you of conflicts of interest in our disclosure document and agreement; • • Maintaining and abiding by our Code of Ethics which requires us to place your interests first and foremost; • Advising you of the right to decline to implement our recommendations and the right to choose other financial professionals for implementation. Commonwealth offers our firm and our firm’s advisory representatives one or more forms of financial benefits based on our advisory representatives’ total AUM held at Commonwealth or financial assistance for advisory representatives transitioning from another firm to Commonwealth. The types of financial benefits Commonwealth provides include, but may not be limited to forgivable or unforgivable loans provided at below-market rates, equity ownership investments into our firm’s business, discounts or waivers on transaction, platform, and account fees, technology fees, research package fees, financial 29 Revised January 2026  planning software fees, administrative fees, brokerage account fees, account transfer fees, licensing and insurance costs, referral fees for recruiting new advisors to Commonwealth, and the cost of attending conferences and events. The financial benefits that our firm or our advisory representatives may receive from Commonwealth are a conflict of interest and provide a financial incentive for our firm and our advisory representatives to select Commonwealth as broker/dealer for your accounts over other broker/dealers from which we may not receive similar financial benefits. We attempt to mitigate this conflict of interest by disclosing the conflict in this brochure and engaging in a regular review of our relationship with Commonwealth to ensure the relationship continues to be appropriate in all respects for our firm’s clients. In connection with the acquisition of Commonwealth by LPL Financial Holdings, Inc. (“LPLH”), on August 1, 2025, Moldenhauer & Associates advisors received loans that are forgiven over a multi-year term subject to continued affiliation with Commonwealth, LPL Financial, LLC (“LPL”), a subsidiary of LPLH, or LPLH’s affiliates after the acquisition. The existence of the loans presents a conflict of interest in that our firm and/or our advisors have a financial incentive to maintain our relationship with LPL and/or Commonwealth. However, to the extent we direct clients to LPL and/or Commonwealth for services, it is because the firm believes that it is in that client’s best interest to do so given our regular review of the firm’s relationship with Commonwealth and/or LPL . Item 15 – Custody Moldenhauer & Associates does not maintain physical custody of your assets. Under SEC rules, we are deemed to have custody of your assets if you authorize us to instruct your account custodian to deduct our advisory fees directly from your account, or if you provide us with authorization to transfer funds from your account to a third party. The firm maintains a relationship with Commonwealth who, as described previously in this brochure, maintains a primary clearing relationship for the execution of client transactions with NFS as the account custodian, and a secondary clearing relationship for the execution of client transactions with Pershing as the account custodian. Substantially all of our advisory clients must select Commonwealth as the broker/dealer of record and NFS as the clearing firm for their managed accounts. In all cases, the name and address of the account custodian will be identified in the respective managed account client agreement. Clients who establish a managed account with the firm utilizing Commonwealth as the broker/dealer of record will receive custodial account statements directly from the respective custodian that holds those assets, such as NFS, Pershing, or a direct product sponsor. Clients should carefully review the statements they receive from their account custodians and should promptly report material discrepancies to us at (716) 662-4361. Our clients may also receive portfolio summary or performance reporting for their managed accounts from the firm or their advisor that are in addition to the account statements clients receive directly from the respective account custodian. We urge you to compare the account statements you receive from your account custodian with any account summary statements or reports you receive from us or your advisor. Although account holdings and asset valuations should generally match, for purposes of calculating performance and account valuations on your account, our summary or performance reporting month-end market values sometimes differ from custodial account statement month-end market values. The three most common reasons why these values may differ are differences in the manner in which accrued interest is calculated, the date upon which “as of” dividends and capital gains are reported, and settlement date versus trade date valuations. 30 Revised January 2026  If you believe there are material discrepancies between your custodial statement and the summary statements or reports you receive from the firm or your advisor, please contact us directly at (716) 662- 4361. Item 16 – Investment Discretion We render investment advice to the vast majority of its managed account clients on a discretionary basis, pursuant to written authorization granted by the client to the firm. This authorization grants to Moldenhauer & Associates and your advisor the discretion to buy, sell, exchange, convert, or otherwise trade in securities and/or insurance products, and to execute orders for such securities and/or insurance products with or through any distributor, issuer, or broker/dealer as the firm or your advisor may select. Your advisor may, without obtaining your consent, determine which products to purchase or sell for your managed account, as well as when to purchase or sell such products, and the prices to be paid. Neither the firm nor your advisor, however, is granted authority to take possession of your assets. Clients may impose reasonable restrictions on their managed account, including, but not limited to, the type, nature, or specific names of securities to be bought, sold, or held in their managed account, as well as the type, nature, or specific names of securities that may not be bought, sold, or held in their managed account. Clients generally grant the firm and their advisor discretionary trading authority over their managed accounts. If not specifically requested otherwise by the client, discretionary authority will be established at the time the account is first opened. As a matter of firm policy, neither the firm nor its advisors have or will accept the authority to file class action claims on behalf of clients. This policy reflects our recognition that we do not have the requisite expertise to advise clients with regard to participating in class actions. Our firm and its advisors have no obligation to determine if securities held by the client are subject to a pending or resolved class action settlement or verdict. The firm and its advisors also have no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, the firm and its advisors have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. The decision to participate in a class action or to sign a release of claims when submitting a proof of claim may involve the exercise of legal judgment, which is beyond the scope of services provided to clients by the firm or your advisor. In all cases, clients retain the responsibility for evaluating whether it is prudent to join a class action or to opt out. Item 17 – Voting Client Securities As a matter of firm policy, and in accordance with this Brochure and our advisory client agreements, neither the firm nor our advisors have or will accept the authority to vote proxies on behalf of advisory clients in any situation where the firm or the adviser acts as investment adviser to the client. We or our advisors may, but are not obligated to, provide advice to clients regarding the clients’ voting of proxies. In all cases, clients must either retain the responsibility for receiving and voting proxies for any and all securities maintained in their managed accounts, or they must appoint a third-party investment adviser or other person who is not associated with the firm to vote proxies for their managed accounts. 31 Revised January 2026  In the event the advisor chooses to provide advice to clients designed to assist the client in making a decision as to how to vote their proxies, the advisor has a fiduciary duty to disclose to the client any material conflicts of interest the advisor may have with respect to such advice. In all cases, our firm or the advisor will send, or will cause to be sent, all such proxy and legal proceedings information and documents it receives to the client, so that the client may take whatever action the client deems advisable under the circumstances. Item 18 – Financial Information Moldenhauer & Associates does not require prepayment of more than $1,200 in fees six (6) months or more in advance. The firm also maintains custody of certain client assets and in certain instances, as defined in SEC Rule 206(4)-2. Additionally, pursuant to the trading authorization granted by the firm’s managed account clients to the firm and their advisor, the firm has discretionary trading authority over the funds and securities of clients. The firm neither has a financial commitment that would impair its ability to meet its contractual and fiduciary commitments to clients, nor has it been the subject of a bankruptcy proceeding. 32 Revised January 2026