Nollenberger McCullough Investment Advisors LLC

FORM ADV PART 2A FIRM BROCHURE Nollenberger McCullough Investment Advisors LLC 220 Newport Center Drive, #11-375 Newport Beach, CA 92660 415-287-5100 www.nollmac.com IARD/CRD No. 165451 March 11, 2026 This brochure provides information about the qualifications and business practices of Nollenberger McCullough Investment Advisors LLC (“NOLLMAC,” “we,” “our,” or “us”). If you have any questions about the contents of this brochure, please contact us at 415-287-5100. The information in this brochure has not been approved or verified by the California Department of Financial Protection and Innovation. Additional information about Nollenberger McCullough Investment Advisors LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Registration with the California Department of Financial Protection and Innovation does not imply a certain level of skill or training.  2 IARD/CRD No. 165451 12/31/2025 Item 2 – Material Changes This brochure will be updated at least annually and whenever material changes occur. Material Changes Since the Last Update Effective January 1, 2026, Nollenberger McCullough Investment Advisors LLC withdrew its registration with the U.S. Securities and Exchange Commission and became registered as an investment adviser with the State of California. A complete copy of this brochure is available upon request by contacting 415-287-5100 or emailing mharrison@nollmac.com.  3 IARD/CRD No. 165451 12/31/2025 Item 3 – Table of Contents Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Business Item 5 – Fees and Compensation Item 6 – Performance-Based Fees Item 7 – Types of Clients Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Item 9 – Disciplinary Information Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics Item 12 – Brokerage Practices Item 13 – Review of Accounts Item 14 – Client Referrals and Other Compensation Item 15 – Custody Item 16 – Investment Discretion Item 17 – Voting Client Securities Item 18 – Financial Information Item 19 – Requirements for State-Registered Advisers  4 IARD/CRD No. 165451 12/31/2025 Item 4 – Advisory Business Nollenberger McCullough Investment Advisors LLC is a California limited liability company registered as an investment adviser with the State of California. The firm provides discretionary investment management services to individuals, trusts, estates, retirement plans, Associations, corporations, and other business entities. The firm’s principal owner is Bruce Weston Nollenberger. NOLLMAC works with clients to develop an investment strategy based on the client’s objectives, time horizon, risk tolerance, liquidity needs, and tax considerations. Investment Policy Statements may be prepared when appropriate. Investment strategies may include equity portfolios, dividend-oriented strategies, growth strategies, value strategies, exchange-traded funds (ETFs), mutual funds, and fixed income securities. As of December 31, 2025, NOLLMAC manages approximately $81,822,279 in assets on a discretionary basis and $0 on a non-discretionary basis. Item 5 – Fees and Compensation NOLLMAC is compensated based on a percentage of assets under management according to the following annual fee schedule: Assets Under Management Annual Fee Up to $2,500,000 $2,500,001 – $4,000,000 $4,000,001 – $10,000,000 Over $10,000,000 2.75% 2.20% 1.10% 0.825% Fees are calculated quarterly in advance based on the market value of assets as of the last business day of the previous calendar quarter. Fees are generally deducted directly from client accounts held at the qualified custodian pursuant to written client authorization.  5 IARD/CRD No. 165451 12/31/2025 Clients may terminate the advisory agreement upon 30 days’ written notice. Upon termination, fees are prorated and any unearned portion is refunded promptly. Firms minimum fee is $5000/year. Fees are negotiable at the firm’s discretion. Clients may incur brokerage commissions, transaction fees, and other custodial expenses charged by the custodian. Item 6 – Performance-Based Fees NOLLMAC does not charge performance-based fees. Item 7 – Types of Clients Clients include individuals, high-net-worth individuals, trusts, estates, pension and profit-sharing plans, associations, corporations, and other business entities. The firm generally requires a minimum account size of $1,000,000, although this minimum may be waived at the firm’s discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss NOLLMAC utilizes fundamental, technical, cyclical, and charting analysis when formulating investment recommendations. Investment strategies include long-term equity investing, dividend income strategies, growth investing, value investing, diversified ETF allocations and fixed income investing. Investing in securities involves risk of loss, including possible loss of principal. Market fluctuations, economic conditions, interest rate changes, issuer risk, and other factors may negatively affect investment performance. Clients should be prepared to bear the risk of loss.  6 IARD/CRD No. 165451 12/31/2025 Item 9 – Disciplinary Information NOLLMAC and its management persons have not been involved in any legal or disciplinary events that are material to a client’s evaluation of the firm or the integrity of its management. Item 10 – Other Financial Industry Activities and Affiliations NOLLMAC provides investment advisory services exclusively. The firm is not registered as a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. Item 11 – Code of Ethics NOLLMAC maintains a written Code of Ethics describing standards of conduct and fiduciary obligations. The Code addresses: • Personal trading policies • Conflicts of interest • Confidentiality • Compliance with applicable laws Clients may request a copy of the Code of Ethics. Item 12 – Brokerage Practices Client assets are maintained with the qualified custodian: Charles Schwab & Co., Inc.  7 IARD/CRD No. 165451 12/31/2025 Schwab provides execution, custody, and related services. Schwab generally does not charge separately for custody but may be compensated through transaction-based and asset-based fees. NOLLMAC does not receive soft dollar benefits and does not share in brokerage commissions. The firm may aggregate trades for multiple client accounts when consistent with best execution and fair allocation principles. Item 13 – Review of Accounts Accounts are reviewed at least quarterly by Chief Compliance Officer Maryann Harrison. Clients receive account statements directly from the custodian at least quarterly. Additional reports may be provided upon request. Item 14 – Client Referrals and Other Compensation NOLLMAC does not receive compensation for client referrals and does not compensate non- employees for referrals. Item 15 – Custody NOLLMAC is deemed to have custody of client funds solely because it deducts advisory fees directly from client accounts. Clients provide written authorization permitting fee deduction. Client assets are maintained with Charles Schwab & Co., Inc., which sends account statements directly to clients at least quarterly. At the time of fee deduction, NOLLMAC sends clients an invoice detailing: • The advisory fee deducted • The account value used to calculate the fee  8 IARD/CRD No. 165451 12/31/2025 • The billing period covered Clients are encouraged to compare invoices to custodian statements. NOLLMAC does not otherwise maintain custody of client assets. Item 16 – Investment Discretion NOLLMAC generally has discretionary authority to buy and sell securities on behalf of clients pursuant to a signed advisory agreement. Discretion does not extend to withdrawing client funds other than authorized fee deductions. Item 17 – Voting Client Securities NOLLMAC votes proxies on behalf of clients when authorized. Proxy voting decisions are made in the best interests of clients. Clients may request information regarding how proxies were voted. Item 18 – Financial Information As a state-registered adviser with custody solely due to fee deduction authority, NOLLMAC is required to maintain a minimum net worth of $35,000 under California regulations. NOLLMAC meets this requirement. The firm has no financial condition reasonably likely to impair its ability to meet contractual commitments. NOLLMAC has not been the subject of a bankruptcy proceeding. The firm does not require prepayment of fees more than six months in advance.  9 IARD/CRD No. 165451 12/31/2025 Item 19 – Requirements for State-Registered Advisers Bruce Weston Nollenberger is the firm’s principal executive officer. His education and business background are described in the Form ADV Part 2B Brochure Supplement. Neither the firm nor Mr. Nollenberger has been involved in any arbitration award, civil proceeding, or administrative proceeding requiring disclosure under this Item. Mr. Nollenberger has not been the subject of a bankruptcy petition.  10 IARD/CRD No. 165451 12/31/2025 FORM ADV PART 2B BROCHURE SUPPLEMENT Nollenberger McCullough Investment Advisors LLC 220 Newport Center Drive, #11-375 Newport Beach, CA 92660 415-287-5100 www.nollmac.com IARD/CRD No. 165451 March 11, 2026 This brochure supplement provides information about Bruce Weston Nollenberger that supplements the Nollenberger McCullough Investment Advisors LLC Form ADV Part 2A brochure. You should have received a copy of that brochure. Please contact us at 415-287-5100 if you did not receive the firm brochure or if you have any questions about the contents of this supplement. Additional information about Bruce Weston Nollenberger is available at www.adviserinfo.sec.gov. Registration with the California Department of Financial Protection and Innovation does not imply a certain level of skill or training.  11 IARD/CRD No. 165451 12/31/2025 Item 2 – Educational Background and Business Experience Name: Bruce Weston Nollenberger Year of Birth: 1951 Education Bachelor of Science (B.S.), University of Colorado Business Experience (Past Five Years) Nollenberger McCullough Investment Advisors LLC Principal Owner: October 2020 – Present Mr. Nollenberger is responsible for portfolio management, investment strategy, client relationship management, and oversight of compliance functions. Item 3 – Disciplinary Information Mr. Nollenberger has not been involved in any legal or disciplinary events that are material to a client’s evaluation of his integrity or professional qualifications. He has not: • Been convicted of or pled guilty or nolo contendere to any felony • Been convicted of any misdemeanor involving investments, fraud, false statements, theft, bribery, perjury, forgery, counterfeiting, or extortion • Been the subject of any investment-related civil or administrative proceeding • Been the subject of any order denying, suspending, or revoking authorization to act in an investment-related business • Been barred or suspended by any regulatory authority or self-regulatory organization  12 IARD/CRD No. 165451 12/31/2025 Item 4 – Other Business Activities Under certain circumstances, Mr. Nollenberger may provide expert witness testimony when retained by attorneys in matters relating to investment management or financial issues. Such activity is conducted separately from the firm’s investment advisory services. Item 5 – Additional Compensation Mr. Nollenberger does not receive economic benefits from any person other than advisory clients in connection with providing advisory services. If he is retained as an expert witness, he may receive compensation for those services. Such compensation is not related to investment advisory activities. Item 6 – Supervision Mr. Nollenberger is the Principal Owner of Nollenberger McCullough Investment Advisors LLC and considered a supervised Person. Compliance procedures include: • Ongoing review of client accounts • Monitoring adherence to client investment guidelines • Review of billing calculations • Annual compliance review Clients may contact Mr. Nollenberger at 415-287-5100 regarding supervision matters. Item 7 – Requirements for State-Registered Advisers In addition to the information provided above, Mr. Nollenberger:  13 IARD/CRD No. 165451 12/31/2025 • Has not been found liable in any arbitration claim alleging damages in excess of $2,500 involving investment-related activities, fraud, false statements, theft, bribery, or dishonest practices. • Has not been found liable in any civil, self-regulatory organization, or administrative proceeding involving investment-related activities or misconduct. • Has not been the subject of a bankruptcy petition.