MULTNOMAH GROUP, INC.

Form ADV Part 2A Personal Advisory Services Multnomah Group, Inc. 1155 SW Morrison Street, Ste 501 Portland, OR 97205 (888) 559-0159 www.multnomahgroup.com March 20, 2026 This Brochure provides information about the qualifications and business practices of Multnomah Group, Inc. If you have any questions about the contents of this Brochure, you may contact us at (888) 559-0159 or amy.barber@multnomahgroup.com to obtain answers and additional information. Multnomah Group, Inc. is an investment adviser registered with the Securities and Exchange Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or training. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Multnomah Group, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Multnomah Group, Inc. is 132131.  Form ADV Part 2A Personal Advisory Services … 2 ITEM 2 – MATERIAL CHANGES The date of our last annual update to our Brochure was March 24, 2025. Since that time, there have been no material revisions to our Brochure. Our Brochure is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Multnomah Group, Inc. is 132131. We may provide ongoing disclosure information about material changes as necessary and will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Amy Barber, Chief Compliance Officer of Multnomah Group, Inc. at (888) 559-0159 or amy.barber@multnomahgroup.com. Our Brochure is provided free of charge.  Form ADV Part 2A Personal Advisory Services … 3 ITEM 3 – TABLE OF CONTENTS ITEM 2 – MATERIAL CHANGES ................................................................................................................. 2 ITEM 3 – TABLE OF CONTENTS ................................................................................................................ 3 ITEM 4 – ADVISORY BUSINESS ................................................................................................................ 4 ITEM 5 – FEES AND COMPENSATION ...................................................................................................... 5 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ..................................... 6 ITEM 7 – TYPES OF CLIENTS .................................................................................................................... 6 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................... 7 ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................. 10 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....................................... 10 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING ................................................................................ 10 ITEM 12 – BROKERAGE PRACTICES ...................................................................................................... 11 ITEM 13 – REVIEW OF ACCOUNTS ......................................................................................................... 12 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .......................................................... 13 ITEM 15 – CUSTODY................................................................................................................................. 13 ITEM 16 – INVESTMENT DISCRETION.................................................................................................... 13 ITEM 17 – VOTING CLIENT SECURITIES ................................................................................................ 14 ITEM 18 – FINANCIAL INFORMATION ..................................................................................................... 14  Form ADV Part 2A Personal Advisory Services … 4 ITEM 4 – ADVISORY BUSINESS Multnomah Group, Inc. (“Multnomah” “we” or “us”) is an independent Portland, Oregon based SEC registered investment advisory firm providing a variety of services to our Clients. This Brochure has been created to provide information relating to the investment advisory and financial planning services we provide to individuals. The firm has been in business since 2003 and registered as an investment adviser with the SEC since 2005. The principal owners are Erik Daley and Scott Cameron. Amy Barber is the Chief Compliance Officer. Our approach uses broadly diversified portfolios and a systematic strategy to manage investments. We follow fiduciary standards, putting our Clients’ interests before our own and seeking to avoid conflicts of interest with our Clients. We offer investment advisory, portfolio management, and financial planning services to individuals. Our investment recommendations primarily include mutual funds, exchange-traded funds, and separate account managers investing in exchange-listed equity securities. We may also recommend other types of investments such as certificates of deposit, municipal securities, corporate bonds, U.S. government securities and money market funds. If Clients hold other types of investments, we may advise on those investments also. See Item 8 for a description of our investment strategy. Individuals (including small retirement plans) Our advice and services are tailored to the unique objectives of each Client. We work with Clients to formulate an investment strategy after discussing risk tolerance, time horizon, and projected future liquidity needs, current holdings, tax considerations, personal market views and other factors. This strategy provides guidance to formulate suitable investment and financial recommendations. We meet with Clients as needed to review portfolio performance, discuss current issues, and re-assess goals and investments plans. Client input, involvement and decision-making are critical to the planning process and implementation of investment decisions. Financial planning Broad-based, modular, and consultative financial planning services are also available to individual Clients. Advice will typically involve providing a variety of services relating to the management of financial resources based upon an analysis of individual needs. Pertinent information about the Client’s personal and financial circumstances and objectives is collected. We often conduct follow up interviews for the purpose of reviewing and/or collecting financial data. Once information has been studied and analyzed, a financial plan designed to achieve the Client’s expressed financial goals and objectives may be produced and presented to the Client. Financial plans are based on the Client’s financial situation at the time the financial information is disclosed by the Client to us. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. We generally have discretionary authority relating to the investment management services we offer to our individual Clients. We do not accept discretionary authority relating to financial planning recommendations. Clients who engage us  Form ADV Part 2A Personal Advisory Services … 5 for financial planning services are solely responsible for decisions whether to implement our recommendations. See Item 16 below for information regarding discretionary and non-discretionary authority. Regardless of whether our authority is discretionary or non-discretionary, Clients may impose reasonable restrictions on investing in certain securities or types of securities and we consider such restrictions when developing an investment strategy. As of December 31, 2025, we have regulatory assets under management of approximately $2,666,622,258, all of which are managed on a discretionary basis. Our personal advisory services assets under management account for approximately $231,818,799; these assets are included in our regulatory assets under management. We do not participate in or sponsor any wrap-fee programs. ITEM 5 – FEES AND COMPENSATION Discretionary Investment Management Our fees are highly dependent on a variety of factors, including: the size of the portfolio, the specific work required by our agreement, the location of the Client and whether travel is required, and the number of meetings the Client requires. As a result, we do not have a standard fee schedule that applies to all Clients. We generally require a minimum of $300,000 in investable assets to maintain an account. However, this minimum account balance may be reduced or waived at our discretion. Fees are either asset-based, a flat fee, or a combination of both. Our annual fees for ongoing investment management services are generally calculated using a blended percentage rate which is based upon the applicable percentage fee for the amount of assets in each of the breakpoints listed below: Assets under management Fees First $1 million 1.00% $1 million to $2 million 0.75% $2 million to $3 million 0.50% $3 million to $4 million 0.35% Over $4 million 0.25% Fees based upon a percentage of Assets Under Management (“AUM”) are charged quarterly in advance based upon the market value of the account at the end of the quarter and deducted directly from Client custodial accounts upon submission of an invoice to the custodian. The custodian will provide a quarterly statement to the Client detailing the amount of the fee and the value of the Client's assets on which the fees are based. Payment of fees may result in the liquidation of Client’s securities if there is insufficient cash in the account. Market value means the value of all assets in the account (not adjusted by any margin debit). To determine value, securities and other instruments traded on a market for which actual transaction prices are publicly reported shall be  Form ADV Part 2A Personal Advisory Services … 6 valued at the last reported sale price on the principal market in which they are traded. Other readily marketable securities and other instruments shall be priced using a pricing service or through quotations from one or more dealers. In rare circumstances, less actively traded securities or other assets may not have readily available market quotations. When necessary, Multnomah will take steps to ensure that an appropriate valuation methodology is used to determine the value of the security. Clients pay brokerage transaction costs and other charges directly to the custodian. See Item 12. Client may be required to pay, in addition to Multnomah’s fee, a proportionate share of any Exchange Traded Fund’s (ETF) or mutual fund’s fees and charges. For example, mutual fund operating expenses are paid out of the fund and are an additional expense incurred by the Client. In cases where a separate account manager is utilized for a Client’s portfolio, the separate account manager will charge a fee separate and additive to Multnomah’s fee. Fees include our time to work with a Client's attorney, accountant, or any third party. However, we are not responsible for any fees that may be charged to the Client by those third parties. Clients generally pay advisory fees quarterly, in advance. Fees for a partial quarter at the commencement or termination of an agreement will be prorated based on the number of days the account was open during the quarter. We may modify the terms of the fee agreement by giving Clients 60 days written notice in advance. Hourly rate projects and fixed fee projects are invoiced by us monthly with payment due by Client upon receipt of the invoice. Upon termination of any account or project, any prepaid but unearned fees will be promptly refunded by us. Any fees that have been earned by us but not yet paid by the Client will be immediately due and payable. The Client or Multnomah may generally terminate a service agreement for any reason by providing the other party with written notice. Multnomah does not accept any compensation for the sale of securities or investment products. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Multnomah does not charge any performance-based fees for its services. Accordingly, this item is not applicable to our firm. ITEM 7 – TYPES OF CLIENTS We provide investment advice to individual investors and retirement plans. Specifically, we provide services to the following types of clients: • Individual and high net worth individuals • Pension and profit sharing plans  Form ADV Part 2A Personal Advisory Services … 7 • Charitable organizations • Corporations Generally, a minimum of $300,000 in investable assets is required to open an account with us. In our discretion, we may reduce or waive this minimum. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS The types of investments we recommend, our investment strategies and advice may vary depending upon each Client’s specific financial situation. As such, we determine investments and allocations based upon predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Client restrictions and guidelines may affect the composition of the portfolio. Investment Strategy Multnomah builds broadly diversified portfolios in the global fixed-income and equity markets, combined with periodic rebalancing. Clients may engage us to assist them in developing an investment strategy which outlines the investment philosophy, management procedures, and long-term goals for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences. For example, tax-managed funds and environmentally sustainable funds are available. Our investing is guided by the following beliefs: • We believe in the long-term growth potential of equities and use these to form the core of an investment portfolio. • We believe solid research is fundamental and critical to sound investment decisions. • We believe in a long-term approach. Numerous studies and statistics have shown that a stable investment approach with a long-term perspective yields better long-term result than rapid trading, and we will employ this method to maximize benefit for our Clients. Type of Investments Our recommendations may differ from Client to Client since each Client has different needs and different tolerance for risk. We primarily recommend mutual funds and exchange traded funds (ETF), to maximize diversification and minimize risk. However, we may also utilize individual equity and debt securities, and other suitable securities based on a Client’s needs and objectives. Each type of security has its own unique set of risks associated with it, and it would not be possible to disclose all of the specific risks of every type of investment in this brochure. We strive to keep Clients educated and informed of material risks associated with particular investments. If Clients have any questions regarding the risks associated with a particular investment, they are encouraged to contact us. Mutual funds are professionally managed collective investment companies that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual or exchange traded funds, other securities  Form ADV Part 2A Personal Advisory Services … 8 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 generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. Other fund risks include foreign securities and currency risk, emerging markets risk, small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund expenses and may decrease fund performance. Brokerage and transactions costs incurred by the fund will reduce returns. ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds assets such as stocks, commodities, or bonds and trades at approximately the same price as the net asset value of its underlying assets over the course of the trading day. Most ETFs track an index, such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day-to-day fluctuations associated with any exchange traded security, where fluctuations occur in part based on the perception of investors. Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in numerous ways. Price fluctuations and market risk are the most significant risk concerns. As such, the value of your investment can increase or decrease over time. Furthermore, you should understand that stock prices can be affected by many factors including, but not limited to, the overall health of the economy, the health of the market sector or industry of the issuing company, and national and political events. When investing in stock, it is important to focus on the average returns achieved over a given period of time, across a well-diversified portfolio. Individual debt securities (or “bonds”) "are typically viewed as 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 or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Primarily we invest with a focus on long-term purchases, where securities are purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Sometimes we will employ a short-term purchase strategy where securities are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. short-term trading (in general, selling securities within 30 days of purchasing the same securities) is not a fundamental part of our overall investment strategy. Methods of Analysis We may use one or more of the following methods of analysis when formulating investment advice:  Form ADV Part 2A Personal Advisory Services … 9 Top-down global macro-economic analysis involves a big-picture analysis of the prevailing economic, demographic and social trends followed by a more focused analysis at the country level, then the industry level and ultimately the specific security level. Mutual fund/exchange traded fund analysis involves qualitative analysis looking at factors such as the background and experience of the fund manager and/or the fund company (style, consistency, risk-adjusted performance, management expenses, average daily trading volume, etc.). Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. This type of analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Investment Risk of Loss As indicated in the descriptions above, investing in securities involves risk of loss that any investor should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections or declines. We do not offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Risk factors include: • Interest rate risk involves the risk that a change in interest rate will have an impact on a bond’s value. Generally, rising interest rates have a negative impact on bond prices so in a period of rising interest rates a bond or bond fund may experience losses in value. • Credit risk is the risk that a bond issuer may not be able to make good on their obligations and could potentially be unable to pay back the owner of a bond. • Inflation risk is the risk that inflation may erode an investor’s purchasing power. For a bond investor that owns bonds with a fixed interest rate, higher than expected inflation reduces the real yield of their investment and may cause interest rates to increase, causing a decline in bond prices. • Market risk involves the risk that a securities price may fluctuate up or down based on new market information and the collective market’s perceived value of a security. Markets are inherently volatile and an investor must acknowledge that market risk is present and be willing to accept the volatile nature of their investments. • Business risk is the risk associated with a single company. Business risk is impacted by a company’s industry, management team, product portfolio, financial position, the broad economic outlook. • Currency risk involves the risk that investments made in international securities may fluctuate in value based on exchange rates between the local currency and the investor’s home currency. Currency risk may add volatility and may cause a security’s performance to differ from its underlying fundamentals.  Form ADV Part 2A Personal Advisory Services … 10 Except as may otherwise be provided by applicable law, we are not liable to Clients for any loss that a Client may suffer by reason of any investment decision made or other action taken or omitted in good faith by us with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from our adherence to a Client’s instructions, or the disregard of our recommendations to a Client; or any act or failure to act by a custodian or other third party in relation to a Client’s account. It is the responsibility of each Client to give us complete information and to notify us of any changes in financial circumstances or goals. ITEM 9 – DISCIPLINARY INFORMATION We are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. No Principal or person associated with Multnomah has any information to disclose which is applicable to this Item. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Multnomah Group, Inc., and those associated with our firm, do not materially participate in any other financial industry activities or have any other financial industry affiliations that materially impact our work as a registered investment adviser to our Clients. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING Multnomah has a Code of Ethics which all employees are required to follow. The Code of Ethics outlines our standard of business conduct and fiduciary duty to Clients. The Code of Ethics includes provisions relating to the confidentiality of Client information, a prohibition on insider trading, restrictions on the acceptance of gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. A copy of the Code of Ethics is available to any Client or prospective Client upon request. Our Clients or prospective Clients may request a copy of the firm’s Code of Ethics by contacting Amy Barber at (888) 559-0159 or amy.barber@multnomahgroup.com. Multnomah does not own or manage any companies or investments that we advise our Clients to buy. Multnomah or individuals associated with us may buy and sell some of the same securities for their own account that we buy and sell for Clients. When appropriate we will purchase or sell securities for Clients before purchasing the same for our account or allowing representatives to purchase or sell the same for their own account. In some cases, we or our representatives may buy or sell securities for their own account for reasons not related to the strategies adopted for our Clients. Our employees and other persons associated with us are required to follow the Code of Ethics when making trades for their own accounts in securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed to assure that the personal securities transactions will not interfere with making decisions in the best interest of advisory Clients, while at the same time allowing employees to invest their own accounts. We maintain a list  Form ADV Part 2A Personal Advisory Services … 11 of all reportable securities holdings for ourselves and for anyone associated with our practice with access to advisory recommendations, and an appropriate officer of Multnomah reviews these holdings on a regular basis. We will disclose to advisory Clients any material conflict of interest relating to us, our representatives, or any employees which could reasonably be expected to impair the rendering of unbiased and objective advice. As many advisory situations could present a conflict of interest, we have established certain restrictions in order to support our fiduciary responsibilities: • A director, officer, associated person, or employee of Multnomah shall not buy or sell securities for his or her personal portfolio where the decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. • No person of Multnomah shall prefer his or her own interest to that of the advisory Client. Any individual who violates the above may be subject to discipline, up to and including termination. ITEM 12 – BROKERAGE PRACTICES Our Clients’ assets are held by independent third-party custodians. Except to the extent that the Client directs otherwise, we may use our discretion recommending the custodian or broker-dealer. The Client is not obligated to effect transactions through any custodian or broker-dealer recommended by us. In recommending a custodian or broker- dealer we will comply with our fiduciary duty to seek best execution and with the Securities Exchange Act of 1934 and will take into account such relevant factors as: • Price; • The custodian’s facilities, reliability and financial responsibility; • The ability of the custodian to effect transactions, particularly with regard to such aspects as timing, order size and execution of order; • Any other factors that we consider to be relevant. While we do not require our Clients to establish brokerage accounts with Charles Schwab & Co. Inc. (“Schwab”), we generally recommend Schwab to our Clients for purposes of establishing brokerage accounts so long as Schwab continues to meet the above criteria. We work primarily with Schwab for administrative convenience and, also because Schwab offers a good value to our Clients for the transaction costs and other costs incurred. Schwab is a registered broker-dealer and SIPC member. Schwab provides Multnomah with access to its institutional trading and operations services, which are typically not available to Schwab retail investors. These services are generally available to independent investment advisers at no charge so long as a total of at least $10 million of the adviser’s Clients’ account assets are maintained at Schwab Institutional. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Some services help us manage or administer our clients’ accounts, while others help us manage and grow our business.  Form ADV Part 2A Personal Advisory Services … 12 Schwab’s services include research, brokerage, custody, access to mutual funds and other investments that are otherwise available only to institutional investors or would require a significantly higher minimum initial investment. Schwab Institutional also makes available to Multnomah other products and services that benefit Multnomah but may not directly benefit its Clients’ accounts. Some of these other products and services assist Multnomah in managing and administering Clients’ accounts. These include software and other technology that provide access to Client account data (such as trade confirmation and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple Client accounts), provide research, pricing information and other market data, facilitate payment of Multnomah’s fees from its Clients’ accounts and assist with back-office support, recordkeeping and Client reporting. Many of these services generally may be used to service all or a substantial number of Multnomah’s accounts, including accounts not maintained at Schwab Institutional. Schwab may also provide Multnomah with other services intended to help Multnomah manage and further develop their respective business enterprises. These services may include consulting, publications and presentations on practice management, information technology, business succession, regulatory compliance, and marketing. In addition, Schwab may make available, arrange and/or pay for these types of services to Multnomah by independent third-parties. Schwab may discount or waive fees that it would otherwise charge for some of these services, or pay all or a part of the fees charged by a third-party for providing these services to Multnomah. The availability of the foregoing products and services is not contingent on Multnomah committing to Schwab any specific amount of business (assets in custody or trading). Receiving the above referenced products and services at no cost creates a conflict of interest because we have an incentive to recommend certain custodians to Clients that offer soft dollar arrangements. In order to mitigate this conflict, Multnomah periodically evaluates its custodial relationships to ensure that transaction fees charged to Clients are reasonable in relation to the value of the services provided. Multnomah emphasizes to Clients their unrestricted right to select and choose any custodian, broker, or dealer they wish. In some instances, Multnomah will aggregate transactions (also known as block trading). Aggregating transactions allows the trading of aggregate blocks of securities from multiple client accounts. Generally, aggregating client transactions allows Multnomah to execute transactions in a more timely, efficient, and equitable manner and seeks to obtain better prices and lower execution costs for our clients. ITEM 13 – REVIEW OF ACCOUNTS Accounts are reviewed by Scott Cameron, Principal, or a Senior Financial Advisor with Multnomah Group. Scott Cameron is a Chartered Financial Analyst (CFA) charterholder. Senior Financial Advisors with Multnomah Group are CERTIFIED FINANCIAL PLANNER® professionals.  Form ADV Part 2A Personal Advisory Services … 13 The frequency of reviews is determined based on the Client's investment objectives. Accounts are generally reviewed at least quarterly. More frequent reviews may be triggered by a change in Client's investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases; loss of confidence in corporate management; or, changes in the economic climate. We review Client accounts to ensure continuing compliance with the strategic asset allocation of the investment strategy and to determine if any rebalancing is needed. Clients' accounts are also reviewed at least annually to determine whether the strategic asset allocation is consistent with the Client's objectives and risk tolerance. Investment advisory Clients receive standard written account statements from the custodian of their accounts on basis no less than quarterly. We may also provide Clients with a written report summarizing the account activity and performance generally quarterly, but in any event, no less than annually. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Multnomah Group has no arrangements, written or oral, in which it compensates any third parties for referrals of Clients. ITEM 15 – CUSTODY With the exception of our ability to debit advisory fees, Multnomah does not otherwise have custody of assets in Client accounts. As such, we shall have no liability for any loss or other harm to any property in the account (except as defined by applicable law), including harm to any property in the account resulting from the insolvency of the custodian or any acts of the agents or employees of the custodian whether or not the full amount or such loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which may be carried by the custodian. The Client understands SIPC provides only limited protection for loss of property held by a custodian. Clients generally receive account statements from the custodian of their accounts on a monthly basis, but in any event, no less than quarterly. We may also provide Clients with periodic written reports summarizing account activity and performance. We urge all Clients to carefully review statements from the custodian and compare these to reports that we may provide. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. ITEM 16 – INVESTMENT DISCRETION Clients authorize Multnomah by signing an investment advisory agreement to make investment recommendations on a discretionary basis. Discretionary authority means we have authority to manage the assets in the account allowing us to execute investment recommendations in accordance with the stated investment strategy without the Client’s prior approval of each specific transaction. This authority allows us to purchase and sell securities and instruments in the  Form ADV Part 2A Personal Advisory Services … 14 account(s), select and retain sub-advisers, and act on behalf of the Client in matters necessary or incidental to the management of investments in the account, including monitoring certain assets. Regardless of this discretionary authority, Clients may impose restrictions on investing in certain securities or types of securities. In some circumstances, we will have non-discretionary authority which means Multnomah is responsible to provide investment recommendations and monitor investments, however Clients make the ultimate determination whether to accept or reject such recommendations. ITEM 17 – VOTING CLIENT SECURITIES We do not have the authority and will not accept a delegation of authority to vote proxies on behalf of Clients. Additionally, we do not provide advice on how the Client should vote. Clients will receive proxies and other solicitations directly from the custodian or transfer agent. If any proxy materials are received on behalf of a Client, they will be sent directly to the Client or designated representative who is responsible to vote the proxy. ITEM 18 – FINANCIAL INFORMATION We do require advisory fees to be paid in advance. However, we do not require the prepayment of fees in an amount more than $1,200, more than six months in advance from any Client. We generally do have discretionary authority over Client funds and securities, but we have no financial commitments that impair our ability to meet contractual and fiduciary commitments to Clients. Neither Multnomah, nor any Principal, has ever been the subject of a bankruptcy petition. 

Form ADV Part 2A Retirement Plans Multnomah Group, Inc. 1155 SW Morrison Street, Ste 501 Portland, OR 97205 (888) 559-0159 www.multnomahgroup.com March 20, 2026 This Brochure provides information about the qualifications and business practices of Multnomah Group, Inc. If you have any questions about the contents of this Brochure, you may contact us at (888) 559-0159 or amy.barber@multnomahgroup.com to obtain answers and additional information. Multnomah Group, Inc. is an investment adviser registered with the Securities and Exchange Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or training. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Multnomah Group, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Multnomah Group, Inc. is 132131.  Form ADV Part 2A Retirement Plans … 2 ITEM 2 – MATERIAL CHANGES The date of our last annual update to our Brochure was March 24, 2025. Since that time, we have not made any material revisions to our Brochure. Our Brochure is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Multnomah Group, Inc. is 132131. We may provide ongoing disclosure information about material changes as necessary and will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Amy Barber, Chief Compliance Officer of Multnomah Group, Inc. at (888) 559-0159 or amy.barber@multnomahgroup.com. Our Brochure is provided free of charge.  Form ADV Part 2A Retirement Plans … 3 ITEM 3 – TABLE OF CONTENTS ITEM 2 – MATERIAL CHANGES ................................................................................................................. 2 ITEM 3 – TABLE OF CONTENTS ................................................................................................................ 3 ITEM 4 – ADVISORY BUSINESS ................................................................................................................ 4 ITEM 5 – FEES AND COMPENSATION ...................................................................................................... 6 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ..................................... 7 ITEM 7 – TYPES OF CLIENTS .................................................................................................................... 7 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................... 7 ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................... 9 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....................................... 10 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING ................................................................................ 10 ITEM 12 – BROKERAGE PRACTICES ...................................................................................................... 10 ITEM 13 – REVIEW OF ACCOUNTS ......................................................................................................... 11 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .......................................................... 11 ITEM 15 – CUSTODY................................................................................................................................. 11 ITEM 16 – INVESTMENT DISCRETION.................................................................................................... 11 ITEM 17 – VOTING CLIENT SECURITIES ................................................................................................ 12 ITEM 18 – FINANCIAL INFORMATION ..................................................................................................... 12  Form ADV Part 2A Retirement Plans … 4 ITEM 4 – ADVISORY BUSINESS Multnomah Group, Inc. (“Multnomah” “we” or “us”) is an independent Portland, Oregon based registered investment advisory firm providing a variety of investment advisory and consulting services to our Clients. This Brochure has been created to provide information relating to the services we provide to employer sponsored retirement plans. The firm has been in business since 2003 and registered as an investment adviser with the SEC since 2005. The principal owners are Erik Daley and Scott Cameron. Amy Barber is the Chief Compliance Officer. Our approach uses broadly diversified portfolios and a systematic strategy to manage investments. We follow fiduciary standards, putting our Clients’ interests before our own and seeking to avoid conflicts of interest with our Clients. We provide comprehensive investment advisory, consulting, and fiduciary services to defined benefit, defined contribution, and deferred compensation plan sponsors. The typical services we offer are generally described below: Investment Consulting • Assistance with the development of an Investment Policy Statement (“IPS”) • Recommendation for target investment allocation • Recommendation for the structure of a plan’s investment menu • Recommendation of investment vehicles for a plan • Ongoing monitoring of the investments • Analysis and recommendations regarding managed account solutions Our investment recommendations primarily include mutual funds. Additionally, we may provide advice on other types of investments such as collective investment trusts, exchange traded funds, insurance company accounts (separate or fixed), certificates of deposit, U.S. government securities, and money market funds. See Item 8 for a description of our investment strategy. Vendor Search Conducting a vendor search can be a detailed, time-intensive process. Multnomah Group manages the search process by providing the following services: • Conducting interviews with the vendor selection committee to articulate the desired retirement plan structure • Preparation of a Request for Proposal (“RFP”) • Distribution of the RFP to pre-qualified vendors • Management of vendor inquiries • Comprehensive report on the vendor proposals submitted, including projection of current and proposed fees • Recommendation, interviews and site-visits of finalists • Implementation support If the vendor search warrants the selection of a new vendor, the conversion process requires significant planning time and may have a dramatic impact on the participant user experience. However, a properly guided vendor search and implementation may result in: • Improved service at the plan sponsor and participant levels • Enhanced educational strategies and tools • Better investment options • Increased participation • Decreased overall costs • Increased overall participant satisfaction with the plan  Form ADV Part 2A Retirement Plans … 5 Multnomah Group applies objective best practices in order to mitigate inconveniences and result in the selection of the most suitable vendor to the plan. Fiduciary Governance A strong fiduciary governance structure is the bedrock of a successful retirement plan program. A sound framework helps to limit fiduciary liability within the organization and empowers those delegated to proactively manage the plan to help ensure its ongoing benefit to participants. Proper governance is well-documented, identifies the parties involved with the plan, delegates responsibilities to the appropriate parties, and creates a process to make decisions about vendors, services, fees, and investments. Fiduciary governance structures are as unique as the organizations that utilize them. Multnomah Group assists clients with the development of structures, documentation, and processes in: • Initial fiduciary assessment • Committee charter • Board resolution • Fiduciary governance education program • Investment policy statement Employee Engagement We believe traditional retirement plan education has failed to move the needle in helping participants achieve a successful retirement outcome. Group education is economical but generally ineffective in its current form and participant advice is underutilized by the participants who need it the most. A successful employee engagement program focuses on helping participants achieve sufficient income in retirement. Multnomah Group supports better retirement outcomes by working with sponsors to design plans that are: • Easy to start • Leak-proof • Safe to leave Fee Benchmarking The topic of fee reasonableness has become a critical Department of Labor focal point since the late 2000s, making it extremely important for plan sponsors to be able to clearly articulate the process by which fiduciaries conclude that all plan fees are reasonable considering relevant facts and circumstances. The concept of fee reasonableness has grown so pervasive that many plan sponsors not covered under ERISA also seek to ensure fee reasonableness as a best practice. Multnomah Group provides plan specific fee benchmarking analysis to assist our clients in meeting the fee reasonableness standard. We use proprietary market pricing data to estimate the fee range specified in our analysis report. Multnomah Group’s goals in providing the annual fee benchmarking analysis to our clients are as follows: • Assist ERISA covered clients in meeting ERISA’s fee reasonableness standard • Assist ERISA exempt clients in maintaining a fee reasonableness best practice by providing meaningful comparison • Assist clients in understanding applicable plan services fees by discussing the current fee structure • Provide a discussion springboard for related topics such as the duty to prudently monitor the plan’s vendors • Recommend potential next steps (e.g. renegotiate service provider fees and/or service levels, launch formal request for proposal process) depending upon where current fees fall Plan Design  Form ADV Part 2A Retirement Plans … 6 In our work with clients, we have found that it is the design of the retirement plan that is the primary determinant of a plan’s effectiveness. Unfortunately, many employers focus nearly exclusively on the rate and methodology of the employer contribution while neglecting other factors that may have an equivalent impact. Features such as automatic enrollment, automatic escalation, and plan leakage affect participant success as much as contribution rate and methodology. Plan sponsors should evaluate the design of their plan with a lens focused on all the aspects of design that impact their employee population. Multnomah Group’s consultants and Technical Group have experience in designing qualified and non-qualified retirement benefit and incentive programs including: • 401(a) • 401(k) • 403(b) • 457(b) • 457(f) • Profit Sharing • Defined Benefit • Cash Balance Our consulting services are provided under an agreement and within parameters set forth between us and the plan sponsor(s). If a plan sponsor engages us to provide advice to participants, such advice will be limited to general retirement planning issues, fund selection, and asset allocation of plan assets. As of December 31, 2025, we have regulatory assets under management of approximately $2,666,622,258, all of which are managed on a discretionary basis. We also provide non-discretionary fiduciary investment advisory services to retirement plan clients with approximately $49,831,525,809 in plan assets. We do not participate in or sponsor any wrap-fee programs. ITEM 5 – FEES AND COMPENSATION Fees are generally calculated as a flat fee, asset-based fee, or a combination of both. We also provide hourly consulting services for other projects. Our fees are highly dependent on a variety of factors, including: the size of the portfolio, the scope of work required by the agreement, the location of the Client and whether travel is required, and the number of meetings the Client requires. As a result, we do not have a standard fee schedule that applies to all Clients. Client fees are typically billed quarterly in advance. Clients receive an invoice and they alternately elect to pay that fee directly or instruct their custodian to pay the fee from plan assets. AUM fees are charged quarterly in advance based upon the market value of the account at the end of the quarter. Fees for a partial quarter at the commencement or termination of an agreement will be prorated based on the number of days the account was open during the quarter. We may modify the terms of the fee agreement upon mutual agreement of Client and Multnomah. Market value means the value of all assets in the account (not adjusted by any margin debit). To determine value, securities and other instruments traded on a market for which actual transaction prices are publicly reported shall be valued at the last reported sale price on the principal market in which they are traded. Other readily marketable securities and other instruments shall be priced using a pricing service or through quotations from one or more dealers. In rare circumstances, less actively traded securities or other assets may not have readily available market quotations. When necessary, Multnomah will take steps to ensure that an appropriate valuation methodology is used to determine the value of the security.  Form ADV Part 2A Retirement Plans … 7 Hourly fees typically range between $150 - $500 per hour depending on the personnel utilized, and the scope and complexity of the work to be performed. We generally invoice Clients monthly for hourly rate services/projects. A price for a fixed-fee project is quoted at the start of a project. Clients are typically billed monthly based on our hourly rate until the quote is reached. Payment is due by Clients upon receipt of the invoice. Clients pay brokerage transaction costs and other charges directly to the custodian. See Item 12. Clients may be required to pay, in addition to our fee, a proportionate share of any investment product’s (i.e. mutual fund, exchange-traded fund, variable annuity, etc.) fees and charges. For example, mutual fund operating expenses are paid out of the fund and are an additional expense incurred by the Client. Fees include our time to work with a Client’s attorney, accountant, or any third party. However, we are not responsible for any fees that may be separately charged to a Client by those third parties. Upon termination of any account or project, any prepaid but unearned fees will be promptly refunded by us. Any fees that have been earned by us but not yet paid by the Client will be immediately due and payable. The Client or Multnomah may generally terminate a service agreement for any reason by providing the other party with 60 days prior written notice. Neither Multnomah, nor any supervised person associated with us, accepts any compensation for the sale of securities or investment products. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Multnomah does not charge any performance-based fees for its services. Accordingly, this item is not applicable to our firm. ITEM 7 – TYPES OF CLIENTS We provide comprehensive investment advisory, consulting, and/or fiduciary services to both qualified and non-qualified defined benefit, defined contribution, and deferred compensation plan sponsors. Specifically, we provide services to the following types of clients: • Individual and high net worth individuals • Pension and profit sharing plans • Charitable organizations • Corporations ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS The types of investments we recommend, our investment strategies and advice may vary depending upon each Client’s specific financial situation. As such, we determine investments and allocations based upon predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Client restrictions and guidelines may affect the composition of the portfolio. Investment Strategy  Form ADV Part 2A Retirement Plans … 8 Multnomah builds broadly diversified portfolios in the global fixed-income and equity markets, combined with periodic rebalancing. Clients may engage us to assist them in developing an Investment Policy Statement (or similar document used to establish suitability) which outlines their investment philosophy, management procedures, and long-term goals. Portfolio design is tailored to each Client’s risk tolerance and preferences. For example, socially responsible and environmentally sustainable funds are available. Our investing is guided by the following beliefs: • We believe in the long-term growth potential of equities and use these to form the core of an investment portfolio. • We believe solid research is fundamental and critical to sound investment decisions. • We believe in a long-term approach. Numerous studies and statistics have shown that a stable investment approach with a long-term perspective yields better long-term result than rapid trading, and we will employ this method to maximize benefit for our Clients. Type of Investments Our recommendations may differ from Client to Client since each Client has different needs and different tolerance for risk. We primarily recommend mutual funds to maximize diversification and minimize risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to disclose all of the specific risks of every type of investment in this brochure. We strive to keep Clients educated and informed of material risks associated with particular investments. If Clients have any questions regarding the risks associated with a particular investment, they are encouraged to contact us. Mutual funds are professionally managed collective investment companies that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual or exchange traded 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 generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. Other fund risks include foreign securities and currency risk, emerging markets risk, small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund expenses and may decrease fund performance. Brokerage and transactions costs incurred by the fund will reduce returns. We may also recommend the use of exchange traded funds (“ETF”). ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds assets such as stocks, commodities, or bonds and trades at approximately the same price as the net asset value of its underlying assets over the course of the trading day. Most ETFs track an index, such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to day fluctuations associated with any exchange traded security, where fluctuations occur in part based on the perception of investors. Primarily we invest focusing on a long-term purchase strategy, where securities are purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Sometimes we will employ a short-term purchase strategy where securities are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Trading (in general, selling securities within 30 days of purchasing the same securities) is not a fundamental part of our overall investment strategy. Methods of Analysis We may use one or more of the following methods of analysis when formulating investment advice: Top-down global macro-economic analysis involves a big-picture analysis of the prevailing economic, demographic and social trends followed by a more focused analysis at the country level, then the industry level and ultimately the specific security level.  Form ADV Part 2A Retirement Plans … 9 Mutual fund/exchange traded fund analysis involves qualitative analysis looking at factors such as the background and experience of the fund manager and/or the fund company (style, consistency, risk-adjusted performance, management expenses, average daily trading volume, etc.) Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. This type of analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below perceived value. The risk is that the market will fail to reach expectations of perceived value. Investment Risk of Loss As indicated in the descriptions above, investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Risk factors include: • Interest rate risk involves the risk that a change in interest rate will have an impact on a bond’s value. Generally, rising interest rates have a negative impact on bond prices so in a period of rising interest rates a bond or bond fund may experience losses in value. • Credit risk is the risk that a bond issuer may not be able to make good on their obligations and could potentially be unable to pay back the owner of a bond. • Inflation risk is the risk that inflation may erode an investor’s purchasing power. For a bond investor that owns bonds with a fixed interest rate, higher than expected inflation reduces the real yield of their investment and may cause interest rates to increase, causing a decline in bond prices. • Market risk involves the risk that a securities price may fluctuate up or down based on new market information and the collective market’s perceived value of a security. Markets are inherently volatile and an investor must acknowledge that market risk is present and be willing to accept the volatile nature of their investments. • Business risk is the risk associated with a single company. Business risk is impacted by a company’s industry, management team, product portfolio, financial position, the broad economic outlook. • Currency risk involves the risk that investments made in international securities may fluctuate in value based on exchange rates between the local currency and the investor’s home currency. Currency risk may add volatility and may cause a security’s performance to differ from its underlying fundamentals. Except as may otherwise be provided by applicable law, we are not liable to Clients for any loss that a Client may suffer by reason of any investment decision made or other action taken or omitted in good faith by us with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from our adherence to a Client’s instructions, or the disregard of our recommendations to a Client; or any act or failure to act by a custodian or other third party in relation to a Client’s account. It is the responsibility of each Client to give us complete information and to notify us of any changes in financial circumstances or goals. ITEM 9 – DISCIPLINARY INFORMATION We are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. No principal or person associated with Multnomah has any information to disclose which is applicable to this Item.  Form ADV Part 2A Retirement Plans … 10 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Multnomah Group, Inc., and those associated with our firm, do not materially participate in any other financial industry activities or have any other financial industry affiliations that materially impact our work as a registered investment adviser to our retirement plan Clients. Additionally, while Multnomah Group does recommend and select other investment advisers for Clients when necessary to serve their needs, we do not receive any direct or indirect compensation from those advisers. Accordingly, we believe there are no material conflicts of interest present in this type of situation. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING Multnomah has a Code of Ethics which all employees are required to follow. The Code of Ethics outlines our standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes provisions relating to the confidentiality of Client information, a prohibition on insider trading, restrictions on the acceptance of gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. A copy of the Code of Ethics is available to any Client or prospective Client upon request. Our Clients or prospective Clients may request a copy of the firm’s Code of Ethics by contacting Amy Barber at (888) 559-0159 or amy.barber@multnomahgroup.com. Multnomah does not own or manage any companies or investments that we advise our Clients to buy. Multnomah or individuals associated with us may buy and sell some of the same securities for their own account that we buy and sell for Clients. When appropriate we will purchase or sell securities for Clients before purchasing the same for our account or allowing representatives to purchase or sell the same for their own account. In some cases, we or our representatives may buy or sell securities for their own account for reasons not related to the strategies adopted for our Clients. Our employees and other persons associated with us are required to follow the Code of Ethics when making trades for their own accounts in securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed to assure that the personal securities transactions will not interfere with making decisions in the best interest of advisory Clients, while at the same time allowing employees to invest their own accounts. We maintain a list of all reportable securities holdings for ourselves and for anyone associated with our practice with access to advisory recommendations, and an appropriate officer of Multnomah reviews these holdings on a regular basis. We will disclose to advisory Clients any material conflict of interest relating to us, our representatives, or any employees which could reasonably be expected to impair the rendering of unbiased and objective advice. As many advisory situations could present a conflict of interest, we have established certain restrictions in order to support our fiduciary responsibilities: • No Employee of Multnomah shall buy or sell securities for his or her personal portfolio where the decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. • No person of Multnomah shall prefer his or her own interest to that of the advisory Client. Any individual who violates the above may be subject to discipline, up to and including termination. ITEM 12 – BROKERAGE PRACTICES Our retirement plan Clients’ assets are held by independent third-party custodians. We do not exercise discretion in recommending a recordkeeper, custodian, or broker-dealer. The Client is not obligated to effect transactions through any recordkeeper, custodian, or broker- dealer recommended by us. In assisting the Client with their decision related to a recordkeeper, custodian, and/or broker-dealer, we help them take into account relevant factors such as: price; the custodian’s facilities, reliability, and financial responsibility; the ability of the custodian to  Form ADV Part 2A Retirement Plans … 11 effect transactions, particularly with regard to such aspects as timing, order size, and execution of order; and/or any other factors that we consider to be relevant. We generally do not aggregate the purchase or sale of securities for Client accounts. Most transactions involve mutual funds and exchange traded funds where trade aggregation does not provide any benefit to our Clients. ITEM 13 – REVIEW OF ACCOUNTS For discretionary Clients, accounts are reviewed by Multnomah Group’s Investment Committee, which includes Chartered Financial Analyst (“CFA”) charterholders. Accounts for discretionary Clients are generally reviewed quarterly, but in any event, no less than annually. The frequency of reviews is determined based on the Client’s investment objectives. More frequent reviews may be triggered by a change in Client’s investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases; loss of confidence in fund managers; or, changes in the economic climate. Clients receive standard written account statements from the custodian of their accounts on basis no less than quarterly. We may also provide Clients with periodic written reports summarizing the account activity and performance. For our non-discretionary retirement or other plan Clients, we provide Clients a written report that reviews the investment managers utilized in the trust and the asset levels in each fund to help ensure continuing compliance with the investment strategy. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Multnomah Group has no arrangements, written or oral, in which it compensates any third parties for referrals of Clients. ITEM 15 – CUSTODY Multnomah does not have custody of assets in Client retirement plan accounts. We shall have no liability to the Client for any loss or other harm to any property in the account, including harm to any property in the account resulting from the insolvency of the custodian or any acts of the agents or employees of the custodian whether or not the full amount or such loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which may be carried by the custodian. The Client understands SIPC provides only limited protection for loss of property held by a custodian. Clients generally receive account statements from the custodian of their accounts on a monthly basis, but in any event, no less than quarterly. We may also provide Clients with periodic written reports summarizing account activity and performance. We urge Clients to carefully review statements from the custodian and compare those to reports that we may provide, as reports may vary based on accounting procedures, reporting dates, or valuation methodologies of certain securities. ITEM 16 – INVESTMENT DISCRETION Generally, retirement plan Clients authorize Multnomah under a consulting services agreement to make investment recommendations on a non-discretionary basis. Non-discretionary authority means Multnomah Group is responsible to provide investment recommendations and monitoring of investments, however Clients make the ultimate determination whether to accept or reject such recommendations. In some circumstances, we will have discretionary authority to manage the assets in the account, allowing us to execute investment recommendations in accordance with the stated investment strategy without the Client’s prior approval of each specific transaction. This authority allows us to purchase and sell securities and instruments in the account(s), select and retain sub-advisers, and act on behalf of the  Form ADV Part 2A Retirement Plans … 12 Client in matters necessary or incidental to the management of investments in the account, including monitoring certain assets. Regardless of this discretionary authority, Clients may impose restrictions on investing in certain securities or types of securities. The determination as to whether we have discretion or not will be documented in a consulting services agreement for all Clients. ITEM 17 – VOTING CLIENT SECURITIES We do not have the authority and do not accept authority to vote Client securities on behalf of Clients. Additionally, we do not provide advice on how the Client should vote. Clients will receive proxies and other solicitations directly from the custodian or transfer agent. If any proxy materials are received on behalf of a Client, they will be sent directly to the Client or designated representative who is responsible to vote the proxy. ITEM 18 – FINANCIAL INFORMATION We do require advisory fees to be paid in advance. However, we do not require the prepayment of fees in an amount more than $1,200, more than six months in advance from any Client. In certain circumstances, we do have discretionary authority over Client funds and securities, but we have no financial commitments that impair our ability to meet contractual and fiduciary commitments to Clients. Neither Multnomah, nor any of the principals, have been the subject of a bankruptcy petition at any time in the past.