NORTHWEST FINANCIAL ADVISORS LLC

Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 Item 1: Cover Page Form ADV Part 2A: Firm Brochure Northwest Financial Advisors LLC 200 Spring Street, Suite 120 Herndon, VA 20170 Office: (703) 810-1072 Fax: (703) 810-1079 www.nwfllc.com March 2025 This brochure provides information about the qualifications and business practices of Northwest Financial Advisors LLC (“NWFA”). You should review this Brochure in conjunction with our separate brochure supplement (“Supplement”). The Supplement has been prepared for the purpose of providing information about the qualifications and background of the supervised person(s) working with you on our behalf or who may otherwise participate in the advisory services provided to you. Throughout this brochure the words “we”, “us” and “our” refer to NWFA. For more information on the disclosure requirements required for Part 2A see the “General Instructions for Part 2 of Form ADV” by visiting www.sec.gov/rules/final/2010/ia-3060.pdf. If you have any questions about the contents of this brochure, please contact our Chief Compliance Officer, Nicole Davis at 703-810- 1072 or email ndavis@NWFLLC.com. Additional information about us is also available on the SEC’s website at: www.adviserinfo.sec.gov by searching CRD #166769. We are registered as an investment adviser with the United States Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”). Registration as an investment adviser with the SEC does not imply a certain level of skill or training. In addition, the information in this brochure has not been approved or verified by the SEC or by any state securities authority. 1  Item 2: Material Changes Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 Since the previous annual amendment, submitted in March 2024, NWFA has made the following material changes to its Form ADV Part 2A: • Item 8 Methods of Analysis, Investment Strategies and Risk of Loss has been updated to include the risks associated with new investments that can now be included in advisory accounts. NWFA can now recommend different types of securities including BDCs, private equity, REITs, and structured products, in addition to the securities previously recommended. Item 3: Table of Contents Item 1: Cover Page .............................................................................................................................................................................. 1 Item 2: Material Changes ................................................................................................................................................................. 2 Item 3: Table of Contents ................................................................................................................................................................. 2 Item 4: Advisory Business ............................................................................................................................................................... 2 Item 5: Fees and Compensation .................................................................................................................................................... 8 Item 6: Performance Based Fees and Side-by-Side Management ................................................................................ 13 Item 7: Types of Clients & Account Requirements ............................................................................................................. 13 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................ 14 Item 9: Disciplinary Information ............................................................................................................................................... 16 Item 10: Other Financial Industry Activities and Affiliations ......................................................................................... 17 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................... 17 Item 12: Brokerage Practices ...................................................................................................................................................... 18 Item 13: Review of Accounts ....................................................................................................................................................... 20 Item 14: Client Referrals and Other Compensation ........................................................................................................... 21 Item 15: Custody ............................................................................................................................................................................. 22 Item 16: Investment Discretion................................................................................................................................................. 23 Item 17: Voting Client Securities ............................................................................................................................................... 23 Item 18: Financial Information................................................................................................................................................... 23 Item 4: Advisory Business NWFA was established in 2013 and is wholly owned by NW Capital Management LLC, which is a wholly- owned subsidiary of Northwest Federal Credit Union. As of December 31, 2024, our firm’s Assets Under Management totaled approximately $1,924,736,060 on a discretionary basis. The focus of our business is helping clients plan and manage their investments. This typically involves working with our clients to arrive at a target allocation of their financial assets amongst different asset classes, and then implementing that allocation within the determined advisory program account. Clients are assigned to an investment adviser representative (“IAR”) and each IAR considers the client’s time horizon, risk tolerance, cash flow needs and other personal preferences when designing an investment portfolio. IARs design more conservative investment allocations for clients who are more risk adverse or more aggressive investment allocations for clients that desire a more growth- oriented portfolio. IARs analyze existing holdings and make recommendations for purchases and sales based on market conditions so as to maximize the probability of achieving the client’s goals and objectives while minimizing risks and expenses. Clients may impose restrictions on investing in certain securities or types of securities within their portfolio. NWFA will refer clients to an accountant, attorney, trust company or other specialist, as necessary for non-advisory related services. 2  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 NWFA generally provides advisory services through certain programs custodied and/or sponsored by LPL Financial LLC (“LPL”), a qualified custodian, registered investment adviser and broker-dealer. LPL is independently owned and operated and not affiliated with us or Northwest Federal Credit Union. NWFA offers client both wrap-fee programs and non-wrap fee programs. A wrap fee program is an advisory program under which a specified fee not based directly upon transactions in a client's account is charged for the execution of client transactions and investment advisory services (which advisory services may include portfolio management or may include advice concerning the selection of other investment advisers). From a management perspective, there is not a fundamental difference in the way we manage wrap and non-wrap accounts. The only significant difference is the way in which transaction charges are paid. In addition, not all securities are allowed to be purchased in a wrap program account. Below is a description of the advisory programs offered by NWFA. Strategic Wealth Management Program (SWM) SWM offers clients an asset management account that allows the IAR to direct and manage specified client assets. NWFA employs a Portfolio Analyst who is responsible for the review, analysis and due diligence of various investment vehicles. The Portfolio Analyst presents information on these investment vehicles to the NWFA’ Investment Committee. The Investment Committee has created different models to be used by the IARs depending on the client’s investment objective. The Investment Committee meets monthly, or more frequently as needed, to review the models and determine what, if any, changes may be needed based on market conditions, performance, etc. The IARs can choose to use these models within the SWM program; however, they still have the flexibility to deviate from the model to suit the individual client’s needs. Below is a brief description of some of the LPL advisory programs available to us. The fees we charge for these programs are included in the overall fee charged by LPL. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the conflicts of interest presented by the programs please see the program account packet, which includes LPL’s Form ADV disclosure brochure for the program, the account application forms, and the account agreement. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. NWFA will obtain the necessary financial data from the client, assist the client in determining the suitability of OMP and assist the client in setting an appropriate investment objective. We will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed asset allocation program. NWFA will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP 3  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 program and assist the client in setting an appropriate investment objective. We will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio of funds designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategist is responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFS in the account and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. Manager Access Select Program Manager Access Select offers clients the ability to participate in the Separately Managed Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA Platform, NWFA will assist client in identifying a third party portfolio manager (SMA Portfolio Manager) from a list of SMA Portfolio Managers made available by LPL, and the SMA Portfolio Manager manages client’s assets on a discretionary basis. NWFA will provide initial and ongoing assistance regarding the SMA Portfolio Manager selection process. In the MP Platform, clients authorize LPL to direct the investment and reinvestment of the assets in their accounts, in accordance with the selected model portfolio provided by LPL’s Research Department or a third- party investment advisor. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through LPL Account View, a web-based, interactive account management portal (“Account View”). The program generates investment recommendations based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through Account View), although NWFA will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Proposal Tool”) is provided to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL and NWFA by enrolling in the advisory service (the “Advisory Service”). Users must select from one of the following goals for each account: retirement, major purchase or general investing. Based on the user’s profile, the Proposal Tool generates sample asset allocation recommendations to assist users in determining whether to utilize the Advisory Service. The Proposal Tool is intended to be used for educational and informational purposes only. The Proposal Tool and Advisory Service are described in more detail in the GWP Program Brochure. Users of the Proposal Tool are not considered to be advisory clients of LPL or NWFA, do not enter into an advisory agreement with LPL or NWFA, do not receive ongoing investment advice or supervision of their assets, and do not receive any trading services. Clients participating in the Advisory Service complete an account application and enter into an account agreement with LPL and NWFA. As part of the account opening process, clients are responsible for providing complete and accurate information regarding, among other things, their age, risk tolerance, and investment horizon. Based on the information provided, NWFA determines the suitability of the Program for clients and LPL determines an appropriate investment allocation track (“Investment Allocation Track”) and Model Portfolio, which must be approved by NWFA and the client. The Model Portfolios have been designed and are maintained by LPL (the “Portfolio Strategist”) and include a list of exchange-traded fund (“ETF”) holding and may in the future include open-end mutual fund holdings and include relative weightings and a list of potential replacement securities for tax harvesting purposes. Only one Model Portfolio is permitted per account. By executing the account 4  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 agreement, client authorizes LPL to have discretion to buy and sell securities in accordance with the Model Portfolio and to liquidate previously purchased non-model securities that are transferred into the account. Client further authorizes LPL to perform tax harvesting. Guidelines for LPL’s Other Account Programs management including rebalancing and tax harvesting are available in the GWP Program Brochure. NWFA may recommend that certain of our clients allocate investment assets among various mutual fund asset allocation models, underlying mutual funds, and/or independent investment manager programs offered through other broker dealers, including SEI Investment Company (“SEI”), or programs sponsored by LPL. Under such arrangements, clients authorize the use of such programs by completing account applications with the broker dealer. The IAR obtains the necessary financial data from the client, assists the client in determining the suitability of the advisory services and assists the client in setting the appropriate investment objective. The IAR provides ongoing investment advice and management that is tailored to the individual needs of the client based on the investment objective chosen by the client. Depending on the specific engagement, the types of securities that the IAR may purchase and sell include mutual funds, ETFs, equities, fixed income securities, and/or variable annuity subaccounts. Clients generally may impose reasonable restrictions on investing in certain securities or groups of securities. The assets managed as part of a customized engagement typically 529 Plan Management are held at the broker dealer selected by the client. NWFA provides discretionary asset management services with respect to certain 529 plan portfolios available through 529 plan sponsor platforms. NWFA will allocate the 529 plan assets among various funds available within the plan, taking into consideration the objectives of the client and the funds made available by the platform. These portfolios will be rebalanced, if needed, once or twice per year, following limitations imposed by the 529 plan sponsor. Financial Planning NWFA typically consults with our clients regarding a broad range of financial issues, such as insurance, estate planning, retirement planning, real estate purchases, charitable giving, and trust services. For clients who require financial planning services, the IAR will collect financial and demographic information from the client. The IAR will prepare and present a financial plan and will be available to help the client implement the recommendations. We will charge a fee for providing financial planning services that is based on the time required to prepare the plan. An estimate will be provided to the client before any services are rendered. The client shall pay us within 30 days from the date of our invoice or upon presentation of the written financial plan. We reserve the right to waive all or any portion of the financial planning fee with respect to any client. Types of Retirement Plan Services NWFA offers (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment Advisory Services and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement plans and their participants. Depending on the type of the Plan and the specific arrangement with the Sponsor, we may provide one or more of these services. Prior to being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2 along with a copy of our Privacy Policy and Retirement Plan Services Agreement ("Agreement") that contains the information required under Sec. 408(b)(2) of the Employee Retirement Income Security Act ("ERISA") as applicable. 5  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 The Agreement authorizes NWFA and our IARs to deliver one or more of the following services: Discretionary Investment Management Services These services are designed to allow the Plan fiduciary to delegate responsibility for managing, acquiring and disposing of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974 ("ERISA"). We will perform these investment management services through our IARs and charge fees as described in this Form ADV and the Agreement. If the Plan is subject to ERISA, we will perform these services as an “investment manager” as defined under ERISA Section 3(38) and as a “fiduciary” to the Plan as defined under ERISA Section 3(21). Specifically, the Sponsor may determine that we perform the following services: SELECTION, MONITORING & REPLACEMENT OF DESIGNATED INVESTMENT ALTERNATIVES ("DIAs"): NWFA will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor an IPS that contains criteria from which NWFA will select, monitor and replace the Plan's DIAs. Once approved by Sponsor, NWFA will review the investment options available to the Plan and will select the Plan's DIAs in accordance with the criteria set forth in the IPS. On a periodic basis, NWFA will monitor and evaluate the DIAs and replace any DIA(s) that no SELECTION, MONITORING & REPLACEMENT OF QUALIFIED DEFAULT INVESTMENT longer meet the IPS criteria. ALTERNATIVES ("QDIA(s)") Based upon the options available to the Plan, NWFA will select, monitor and replace the Plan's QDIA(s) in accordance with the IPS. Non-Discretionary Fiduciary Services These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan. We will solely be making recommendations to the Sponsor. We will perform these Non-Discretionary investment advisory services through our IARs and charge fees as described in this Form ADV and the Agreement. If the Plan is covered by ERISA, we will perform these investment advisory services to the Plan as a "fiduciary" defined under ERISA Section 3(21). The Sponsor may engage us to perform one or more of the following Non-Discretionary investment INVESTMENT POLICY STATEMENT ("IPS"): advisory services: NWFA will review with Sponsor the investment objectives, risk tolerance and goals of the Plan. If the Plan does not have an IPS, NWFA will provide recommendations to Sponsor to assist with establishing an IPS. If the Plan has an existing IPS, NWFA will review it for consistency with the Plan's objectives. If the IPS does not represent the objectives of the Plan, NWFA will recommend ADVICE REGARDING DESIGNATED INVESTMENT ALTERNATIVES ("DIAs"): to Sponsor revisions to align the IPS with the Plan's objectives. Based on the Plan's IPS or other guidelines established by the Plan, NWFA will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting DIAs to be offered to Plan participants. Once Sponsor selects the DIAs, NWFA will, on a periodic basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the DIAs. If a DIA is required to be removed, NWFA will provide recommendations to assist Sponsor with replacing the DIA. 6  ADVICE REGARDING QUALIFIED DEFAULT INVESTMENT ALTERNATIVE ("QDIA(s)"): Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 Based on the Plan's IPS or other guidelines established by the Plan, NWFA will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting or replacing the Plan's QDIA(s). PARTICIPANT INVESTMENT ADVICE: NWFA will meet with Plan participants, upon reasonable request, to collect information necessary to identify the Plan participant's investment objectives, risk tolerance, time horizon, etc. Advisor will provide written recommendations to assist the Plan participant with creating a portfolio using the Plan's DIAs or Models, if available. The Plan participant retains sole discretion over the investment of his/her account. Retirement Plan Consulting Services Assist Sponsor in reviewing objectives and options available through the Plan Recommend Plan participant education and communication policies under ERISA 404(c) Deliver fiduciary training and/or education periodically or upon reasonable request Recommend procedures for responding to Plan participant requests Assist fiduciaries with review of Covered Service Providers ("CSP") and fee benchmarking Assist with preparation and review of Requests for Proposals and/or Information Coordinate and assist with CSP replacement and conversion Periodic review of investment policy in the context of Plan objectives Assist the Plan committee with monitoring investment performance Educate Plancommittee members, as needed, regarding replacement of DIA(s) and/or QDIA(s) Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in meeting his/her fiduciary duties to administer the Plan in the best interests of Plan participants and their beneficiaries. Retirement Plan Consulting Services are performed so that they would not be considered “investment advice” under ERISA. The Sponsor may elect for our IARs to assist with Administrative Support any of the following services:     Service Provider Support    Investment Monitoring Support    Participant Services   Facilitate group enrollment meetings and coordinate investment education Assist Plan participants with financial wellness education, retirement planning and/or gap analysis Potential Additional Retirement Services Provided Outside of the Agreement In providing Retirement Plan Services, NWFA and its IARs may establish a client relationship with one or more Plan participants or beneficiaries. Such client relationships develop in various ways, including, without limitation: 1. 2. as a result of a decision by the Plan participant or beneficiary to purchase services from NWFA not involving the use of Plan assets; as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relating to assets 7  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 3. held outside of the Plan; or through a rollover of an Individual Retirement Account ("IRA Rollover"). If NWFA is providing Retirement Plan Services to a plan, IARs may, when requested by a Plan participant or beneficiary, arrange to provide services to that participant or beneficiary through a separate agreement. If a Plan participant or beneficiary desires to affect an IRA Rollover from the Plan to an account advised or managed by NWFA, IAR will have a conflict of interest if his/her fees are reasonably expected to be higher than those paid to NWFA in connection with the Retirement Plan Services. IAR will disclose relevant information about the applicable fees charged by NWFA prior to opening an IRA account. Plan participants are also encouraged to consider all options presented by the Sponsor when considering distribution/rollover options; for example, (i) remain invested under the Plan (may require a minimum balance), (ii) transfer Plan assets to a new employer- sponsored retirement plan (if applicable), (iii) transfer Plan assets to an IRA with a financial institution, or (iv) withdraw assets directly which would be subject to federal and applicable state and local taxes and possibly subject to the IRS penalty of 10% depending on age. Any decision to affect the rollover or about what to do with the rollover assets remain that of the Plan participant or beneficiary alone. In providing these optional services, we may offer employers and employees information on other financial and retirement products or services offered by NWFA and our IARs. Retirement Plan Individually Tailored Services When providing investment fiduciary services, we will tailor our advice or (if applicable) discretion to meet the investment policies or other written guidelines adopted by the Sponsor. When providing Participant Investment Advice, such advice will be based upon the investment objectives, risk tolerance and investment time horizon of each individual Plan participant. Item 5: Fees and Compensation General NWFA typically receives compensation from fees based on a percentage of assets under management. You should review all fees charged by us and others to fully understand the total amount of fees to be paid by you. The advisory fee charged to the client for each advisory program is negotiable, subject to certain maximum fees described herein. Fees are negotiated between the client and the IAR. Account fees are payable quarterly in advance. The first payment will be based on the opening market value of the account and will be pro-rated to cover the period from the date the account is opened through the end of that calendar quarter. Thereafter, the fee will be based on the account value on the last business day of the preceding calendar quarter. If client contributes funds to their account on a date other than the first day on a calendar quarter, then a prorated fee will be charged for that calendar quarter with respect to such contribution based on the number of days remaining in that calendar quarter. If a client withdraws assets on any date other than the last day of the calendar quarter then a prorated refund will be made based on the number of days left in the quarter prior to the withdrawal. The fee structure is explained and agreed with the clients in advance before any services are rendered. Fees will generally be automatically deducted from your managed account. As part of this process, clients must understand and acknowledge the following: • • The custodian sends statements at least quarterly to the client showing all disbursements for their account, including the amount of the advisory fees paid to us; The client provides authorization permitting fees to be directly paid by the terms outlined in the advisory agreement; and 8  • Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 The custodian calculates the advisory fees and deducts it from the client’s account. Some of the programs used by us are referred to as wrap fee programs. Typically, a wrap fee program provides a bundle of investment services, including asset allocation, portfolio management, custody of client funds and securities, execution of client transactions, and monitoring of portfolio manager performance for a single "wrap" fee, generally a percentage of assets under management. The wrap fee client is not charged brokerage commissions on a transactional basis. On the other hand, there are programs that do not charge a wrap fee. The fees may be higher under a wrap fee arrangement versus a non-wrap fee arrangement. Our firm does not manage wrap fee accounts in a different fashion than non-wrap fee accounts. All accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. In addition to the advisory program fees outlined above, in certain programs you will also be subject to other fees and expenses charged by the custodian including account maintenance fees, custodial fees, and transaction charges. A schedule of the applicable fees and expenses will be provided with the account application. The custodian may also receive other compensation (direct or indirect) from other third parties in connection with client holdings or transactions. NWFA does not receive any portion of the custodian fees and expenses or other compensation. Clients are encouraged to carefully review all disclosures provided by the custodian in the account opening application. In addition to the program fees, clients may also incur the management fees and any other expenses of any mutual funds or other investment vehicles that we select for a client’s portfolio. Since these fees and expenses are typically deducted directly from the investment vehicle, they are not necessarily obvious to shareholders but they represent a real cost to our clients. The custodian typically imposes transaction or annual charges on certain types of investments that may be considered structured products or alternative investments. These charges are paid by the account owner and not NWFA, SWM, MWP, OMP and Manager Access Select The level of advisory fees for SWM, MWP, OMP and Manager Access Select is set based on negotiation between the IAR and client and is based on a percentage of the market value of the client accounts, including cash holdings. The maximum annual advisory fee is 2.00% and will be as stated in the written investment advisory agreement. Advisory fees are due and charged quarterly in advance to the client’s account. The advisory fee may be higher than the fee charged by other investment advisors for similar services. Client accounts opened prior to the date of this Brochure may be subject to different fee structures in place at the time the accounts were opened. In addition to the advisory fee that clients pay to NWFA for management services within SWM, clients will pay transaction charges for trade execution. The transaction charges are paid to LPL, vary based on the type of transaction (e.g., mutual fund, ETF, equity or option), and are communicated to clients at account opening. NWFA does not receive any portion of the transaction charges. For clients that have a wrap program account, IAR bears the SWM transaction charges. When IAR bears transaction charges for an account, the client should understand that this presents a conflict of interest. The cost to the IAR of the transaction charges may be a factor that the IAR considers when deciding which securities, ETFs or mutual funds to select and whether or not to place transactions in client’s account. In particular, the IAR will have a financial incentive to recommend transactions in securities that carry lower fees (e.g., transactions involving equity securities may be recommended over fixed income securities because of the lower transaction charge) or to limit the overall number of transactions it recommends to client. The client should also note that the advisory fee being charged may take the payment of transaction charges into consideration. That is, the advisory fee charged to other accounts may be lower than the advisory fee charged to accounts for which the IAR 9  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 agrees to bear transaction charges. If the IAR agrees to bear transaction charges, the client should also understand that engaging in a “buy and hold” strategy would not capitalize on any higher advisory fee being charged in light of the IAR paying charges for transactions in certain securities. In addition, these conflicts may also have an impact on the performance of the client’s account. Within the SWM account, the advisory fee is shared between NWFA and its IARs. Within the MWP and OMP accounts, the advisory fee is shared among NWFA, IARs, LPL, and any third-party portfolio strategist. Within the Manager Access Select account, the advisory fee is shared among NWFA, IARs, LPL, and the SMA Portfolio Manager. For additional information regarding LPL program fees and third- party portfolio strategist fees within the MWP, OMP or Manager Access Select account, clients should refer to the LPL Form ADV disclosure brochure for the appropriate program. When providing services within SWM accounts, we use mutual funds that the custodian makes available. Mutual funds offer multiple share classes which can be titled, for example, Class A, Class I, institutional, fee-based, investor, retail, service, administrative or platform share classes. The mutual funds are no-load or load-waived share classes and therefore not subject to any upfront sales charge. However, different mutual fund share classes have different expense structures (i.e., some higher and some lower) and in some cases the mutual fund share classes pay a 12b-1 fee, administrative fee, recordkeeping fee, and/or revenue sharing fee to the custodian. You should understand that the mutual fund share class we select for purchase in your account in some cases will not be the least expensive share class that the mutual fund makes available. We select mutual fund share classes based on a variety of different considerations, including but not limited to: the advisory fee that is charged; the amount of the transaction charges applied to the purchase or sale of the mutual fund; the anticipated frequency of transactions; the holding period for the mutual funds; the overall cost structure of the advisory program; share class eligibility requirements; and potential tax consequences. You should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM accounts. Guided Wealth Portfolios (GWP) GWP Advisory Service clients are charged an account fee consisting of an LPL program fee of 0.35% and an NWFA advisory fee of up to 1.00%. Account fees are payable quarterly in advance. GWP accounts valued at less than $10,000 will also incur a small account fee of $20.00 per year payable to LPL. NWFA does not receive any portion of the small account fee. The GWP Proposal Tool provides access to sample recommendations at no charge to users. Other Account Programs The maximum advisory fee for other account programs is 1% annually. Within other advisory account programs, the advisory fee is shared between NWFA, IARs and any applicable third-party advisor. 529 Plan Management The maximum advisory fee for NWFA’s management of 529 plan assets held directly on a 529 plan platform is 1.00% annually based on the market value of the assets, including cash holdings. The advisory fee for 529 plan management is payable [quarterly][semi-annually] in advance based on the value of the portfolio as of the last day of the previous billing period. The first payment is due and payable upon execution of the written investment advisory agreement and will be assessed pro-rata for partial billing periods. Fees are payable through check made payable to NWFA or written authorization from the client to have the fees paid through another account belonging to the client and managed by NWFA. 10  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 The advisory fees noted above are for the 529 plan management and education planning only. Client should be aware that the 529 plan sponsor will charge separate fees, including but not limited to, initial set up fees and annual maintenance fees. As the 529 plan invests in mutual funds, clients will also pay the fund a management fee and sub-transfer agency fee. NWFA does not have any control over the level of these fees and does not receive any portion of these fees and charges. Clients should also be aware that tax considerations related to purchasing a 529 plan can be complex. For example, if your state of residence offers any tax benefit for purchasing an in-state 529 plan, you would be foregoing those tax benefits by purchasing an out-of-state 529 plan. If realizing tax benefits is important to the client, the client should consult with their tax advisor or the 529 plan sponsor for additional information. In evaluating the 529 plan management services provided by NWFA, the client should consider the total value of all the services received for the fee charged, including the amount of portfolio activity in the client’s account, the value of reporting and other services which are provided under the arrangement, and other factors. The total fee may or may not exceed the aggregate cost of such services if they were provided separately. Financial Planning NWFA charges on a flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Flat fees range from $750 to $5,000. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6months. Retirement Plan Services Fees for the Retirement Plan Services ("Fees") are negotiable. A description of the different types of fees for Retirement Plan Services appears in the fee schedule below: Fee Range Fee Type Assets Under Management 1.25% Maximum Depending upon the capabilities and requirements of the Plan’s recordkeeper or custodian, we may collect our fees in arrears or in advance. Typically, Sponsors instruct the Plan’s recordkeeper or custodian to automatically deduct our Fees from the Plan account; however, in some cases a Sponsor may request that we send invoices directly to the Sponsor or recordkeeper/custodian. Sponsors receiving Retirement Plan Services may pay more than or less than a client might otherwise pay if purchasing the Retirement Plan Services separately or through another service provider. There are several factors that determine whether the costs would be more or less, including, but not limited to, the size of the Plan, the specific investments made by the Plan, the number of or locations of Plan participants, the Retirement Plan Services offered by another service provider, and the actual costs of Retirement Plan Services purchased elsewhere. In light of the specific Retirement Plan Services offered by NWFA, the Fees charged may be more or less than those of other similar service providers. In determining the value of the Account for purposes of calculating any asset-based Fees, Advisor will rely upon the valuation of assets provided by Sponsor or the Plan’s custodian or recordkeeper without independent verification. If, however, there are circumstances which, in the Advisor’s judgment, render the custodian’s valuation inappropriate in which case Advisor will value securities listed on any national securities exchange at the closing price on the principal exchange on which they are traded and will value any other securities in a manner determined in good faith by Advisor to reflect fair market value. 11  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 In all events, any such valuation will not be any guarantee of the market value of any of the assets in the Plan. Unless we agree otherwise, no adjustments or refunds will be made in respect of any period for (i) appreciation or depreciation in the value of the Plan account during that period or (ii) any partial withdrawal of assets from the account during that period. If the Agreement is terminated by us or by Sponsor, we will refund certain Fees to Sponsor to the extent provided in Section 8 of the Agreement. Unless we agree otherwise, all Fees shall be based on the total value of the assets in the account without regard to any debit balance. All Fees paid to NWFA for Retirement Plan Services are separate and distinct from the fees and expenses charged by mutual funds, variable annuities and exchange traded funds to their shareholders. These fees and expenses are described in each investment's prospectus. These fees will generally include a management fee, other expenses, and possible distribution fees. If the investment also imposes sales charges, a client may pay an initial or deferred sales charge. The Retirement Plan Services provided by NWFA may, among other things, assist the client in determining which investments are most appropriate to each client's financial condition and objectives and to provide other administrative assistance as selected by the client. Accordingly, the client should review both the fees charged by the funds, the fund manager, the Plan's other service providers and the fees charged by NWFA to fully understand the total amount of fees to be paid by the client and to evaluate the Retirement Plan Services being provided. While not necessarily related to the Retirement Plan Services, various vendors, product providers, distributors and others may provide non-monetary compensation by paying some expenses related to training and education, including travel expenses, and attaining professional designations. We might receive payments to subsidize our own training programs. Certain vendors may invite us to participate in conferences, on-line training or provide publications that may further IARs and employees' skills and knowledge. Some may occasionally provide us with gifts, meals and entertainment of reasonable value consistent with industry rules and regulations. If applicable, and in the event the payments are received in connection with or as a result of the Retirement Plan Services, we will disclose such fees to Sponsors in accordance with ERISA and Department of Labor regulations. No increase in the Fees will be effective without prior written notice. Termination & Refunds In the event a client wants to terminate our services, we will refund the unearned portion of our advisory fee. The client must provide notice of termination as outlined in the advisory agreement. Upon receipt of such notice, we will proceed to close out the client’s account and process a pro-rata refund of unearned advisory fees. Commissionable Securities Sales All of our IARs are licensed with LPL and can receive a commission for the sale of securities. However, we and our IARs will not accept commissions for the sale of securities when providing investment advisory services to advisory clients. For non-advisory accounts, our IARs will accept compensation for the sale of securities or other investment products, including distribution or service (“trail”) fees from the sale of investment products offered by LPL. The receipt of compensation from the sale of securities or insurance products presents a conflict of interest since IARs have an incentive to effect 12  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 securities transactions or recommend insurance products for the purpose of generating commissions rather than solely based on a client’s needs. However, you are under no obligation, contractually or otherwise, to purchase securities or insurance products through our IARs. ERISA and Retirement Accounts If client is a qualified plan subject to the Employee Retirement Income Security Act of 1974 (ERISA) or a plan within the meaning of Section 4975(e) of the Internal Revenue Code of 1986 (the Code), NWFA is acting as a fiduciary under ERISA as defined in Section (21) of ERISA or Section 4975 of the Code with respect to services listed in Item 4 of this Brochure. There is a conflict of interest for individuals that currently invest in an employer-sponsored retirement plan or individual retirement account that are considering a roll out of assets from the retirement plan or account. A conflict of interest exists because we will be compensated only if the individual rolls over the proceeds into an IRA that we then manage. As a result, it can be construed that we have a financial incentive to recommend one option over another. The individual considering the roll out of assets into an IRA should understand that certain IARs associated with NWFA maintain an education-only policy with respect to rollovers and certain other IARs will make a recommendation with respect to a rollover. To the extent the IAR maintains an education-only policy, NWFA and its IAR will not make a recommendation and the individual is solely responsible for considering all relevant services, fees, and conflicts of interest applicable to the management services by NWFA. To the extent an IAR makes a rollover recommendation, the recommendation to roll out assets into an IRA will only be made if it is determined to be in the individual’s best interest. Regardless, we encourage each individual to include in his/her decision making process, a thorough review of all options available; for example (i) remain invested in the current retirement plan or account (if available), (ii) transfer assets to a new employer-sponsored retirement plan (if available), (iii) transfer assets to an IRA with a financial institution, or (iv) withdraw assets directly, which would be subject to federal and applicable state and local taxes and possibly subject to the IRS penalty of 10% depending upon the age of the individual. When considering these options, NWFA encourages individuals to consider the advantages and disadvantages of each option, including any applicable fees and all features of each option. A decision to roll over assets should reflect consideration of various factors, the importance of which will depend on the individual’s needs and circumstances. Item 6: Performance Based Fees and Side-by-Side Management Performance based fees are fees based on a share of capital gains on or capital appreciation of the assets of a client. An adviser charging performance fees to some accounts faces a variety of conflicts because the adviser can potentially receive greater fees from its accounts having a performance- based compensation structure than from those accounts it charges a fee unrelated to performance (e.g., an asset-based fee). As a result, the adviser may have an incentive to direct the best investment ideas to, or to allocate or sequence trades in favor of, the account that pays a performance fee. We do not charge any performance-based fees. Item 7: Types of Clients & Account Requirements • NWFA primarily provide customized investment supervisory services to individuals, trusts, estates, or charitable organizations, pension and profit sharing plans, and corporations or business entities. We do not impose a minimum account size to become an advisory client; however certain programs offered by LPL and other broker dealers may require a minimum amount of investable assets to open and maintain an account: • A minimum initial account value of $25,000 is suggested for SWM. In certain instances, NWFA will permit a lower minimum account size. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit 13  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 • • • • a lower minimum account size. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. A minimum account value of $50,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. A minimum account value of $5,000 is required to enroll in the GWP Managed Service. Our Retirement Plan Services are available to clients that are sponsors or other fiduciaries to plans, including 401(k), 457(b), 403(b) and 401(a) plans. Plans include participant-directed defined contribution plans and defined benefit plans. Plans may or may not be subject to ERISA. We do not require a minimum asset amount for Retirement Plan Consulting Services. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss NWFA use a long term investment philosophy and provide individual advice based on each client's risk tolerance. We review our client’s long-term and short-term financial needs and objectives, and risk tolerance or risk-aversion. Investment recommendations are based on information provided to us by our clients, financial records, responses to our questionnaires or personal interviews. We design each client’s investment strategy based on a thorough evaluation of the individual goals and objectives of each client. After analyzing a client’s financial situation and understanding their individual investment objectives, we will recommend investment programs sponsored by third party financial institutions including LPL. Following client approval, we will implement each aspect of the strategy, as appropriate. Account supervision is guided by the stated objectives of the client, and all managed accounts will be maintained with an independent custodian broker-dealer. Our investment strategy involves recommending an asset allocation mix to our clients based on their individual needs by selecting an appropriate mix of mutual funds, exchange traded funds, equities, fixed income or Portfolio Managers to manage your assets. We monitor the asset allocation mix and performance of the investments, and make periodic adjustments to the account, as necessary to meet client objectives. In the event we recommend Portfolio Managers, we will monitor manager performance and various investment markets to determine if the allocation among investment options is appropriate or if changes to those options are necessary due to changes in the market or client’s needs. NWFA can recommend many different types of securities, including mutual funds, unit investment trusts (“UITs”), closed end funds, ETFs, ETNs, variable annuity subaccounts, equities, fixed income securities, interval funds, options, hedge funds, managed futures, BDCs, private equity, REITs, and structured products. LPL determines the types of investments that are eligible to be purchased in program accounts. Described below are some risks associated with investing and with some types of investments that are available. The description provided above is a brief overview of the investment category and is not intended to be complete. Investing in securities is inherently risky. An investment in individual securities or in a portfolio of securities could lose money. We cannot give any guarantee that we will achieve your investment objectives or that any client will receive a return of its investment. The description below is an overview of the risks entailed in our investment strategy and is not intended to be complete. All investing involves a risk of loss and the investment strategy offered by us could lose money over short or long periods. Performance could be hurt by a number of different market risks including but not limited to: 14  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 Stock Market Risk. Stock market risk, which is the chance that stock prices overall will decline. An investment in individual securities or in a portfolio of securities could lose money. We cannot give any guarantee that we will achieve the client’s investment objectives or that any client will receive a return of its investment. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Alternative Strategy Mutual Funds. Certain mutual funds invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities are not registered as an investment company. Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions are magnified over time. Because of these distortions, these products should be actively monitored, as frequently as daily, and may not be appropriate as an intermediate or long-term holding. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. LPL imposes limitations on accounts purchasing leveraged or inverse ETFs, ETNs, and mutual funds. Structured Products. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is 15  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. Business Development Companies (BDCs). BDCs are types of closed-end investment companies, which are available to clients meeting certain qualification standards. Generally, BDCs invest primarily in the debt and equity of private and/or small U.S. companies and may offer distribution rates generated through potentially significant credit and liquidity risk exposures amplified through leverage. As with other high-yield investments, such as floating-rate/leveraged loan funds, private REITs and limited partnerships, investors are exposed to significant market, credit, interest rate and liquidity risks. In addition, BDCs run the risk of over-leveraging their relatively illiquid portfolios. Due to the illiquid nature of non-traded BDCs, investors’ exit opportunities may be limited only to periodic share repurchases by the BDC. A tender offer pursuant to a share redemption program may be oversubscribed so that the BDC accepts only a pro rata portion of the shares a client tenders during a redemption program. In such cases, a client may experience significant delays (including, potentially, indefinite delays) to exit from the investment. In addition, share redemption programs may be shut down at any time at the discretion of the issuer’s board. Also, BDCs may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to make investments. In some cases, there may be an additional cost to investors who redeem before holding the shares for a specified number of years. REITs. REITs invest in real estate, and there are special risks associated with investing in real estate, including, but not limited to, sensitivity to changes in real estate values, the risk of investment loss due to the use of leveraging and other speculative investment practices, interest rate risk, lack of liquidity and performance volatility. Non-Traded REITs are not required to provide annual valuations until two years and 150 days after reaching the minimum capital raise required to begin purchasing properties. This threshold is generally outlined in the product’s prospectus. Non-Traded REITs, which are available to clients meeting certain qualification standards, may fund distributions from offering proceeds or borrowings, which may constitute a return of capital and reduce the amount of capital available to invest in new assets. Clients should be aware that these securities may not be liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the security, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the security during the repurchase offer. Issuers may repurchase shares at a price below net asset value. The repurchase program may also be suspended under certain circumstances. Private Equity Funds. Private equity investments are speculative and involve significant risks. It is possible that investors may lose some or all of their investment. The risks associated with private equity include: limited diversification, the use of leverage, and 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. Item 9: Disciplinary Information 16  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or investor’s evaluation of the adviser or the integrity of the adviser’s management. Neither we nor any of our officers, directors, or other management persons, have been involved in any legal or disciplinary events in the past 10 years that would require disclosure in response to this Item. Item 10: Other Financial Industry Activities and Affiliations Northwest Financial Advisors is a separately capitalized company that is indirectly owned by Northwest Federal Credit Union (the “Credit Union”). We will have relationships and clients may utilize the services of certain entities affiliated with the Credit Union. The particular services involved will depend on the types of services offered by the affiliated company. Affiliated companies will be engaged on an arms-length basis for services it provides our client. Services provided by affiliated companies may include, without limitation, banking, tax advice, insurance advice, estate planning, retirement planning, real estate purchases, and other specialized advisory services. Broker Dealer Northwest Financial Group LLC (“NWFG”) is a member of the Financial Industry Regulatory Authority (FINRA). NWFG receives commission-based compensation from LPL for the sale of investment products. The compensation is earned by IARs in their capacity as registered representatives of LPL. If a client desires to purchase investment products offered by LPL through an IAR acting as a registered representative of LPL then LPL and NWFG will receive brokerage- related compensation for those services, such as commissions and/or trail fees. Information regarding the amount of brokerage compensation will be provided to the client before the transaction is completed. Clients are advised that investment products provided through LPL are available from other financial institutions. LPL is a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. Our IARs are licensed as registered representatives of LPL and will receive commissions for selling investment products to clients. A conflict of interest exists since an IAR has an incentive to recommend products that pay commissions. IARs do not receive commissions when providing investment advisory services through us. Credit Union Northwest Federal Credit Union offers traditional credit union services and products to its members, including checking and savings accounts and consumer loans. Employees of the Credit Union may refer banking customers who are in need of investment advisory services to us. Insurance Company NW Insurance Agency LLC (“NWIA”) is a licensed insurance agency offering insurance products. IARs may be licensed as insurance agents of NWIA and receive commission when selling insurance products. The receipt of commissions on the sale of insurance products creates an incentive for the IAR. Whether or not to use the insurance services from or through our affiliated Insurance Agency is at the discretion of the client. To the extent that advisory clients use the insurance services from or through our IARs, commissions will be paid to them as an appropriately licensed agent. Clients are advised that similar insurance services are available elsewhere. Item 11: Code of Ethics, Participation or Interest in Client Transactions and 17  Personal Trading Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 Code of Ethics NWFA have adopted a written Code of Ethics (the “Code”) predicated on the principal that we owe a fiduciary duty to our clients. The Code establishes guidelines for professional conduct and personal trading procedures, including certain pre-clearance and reporting obligations. We require pre-clearance before purchasing an IPO or limited offering (i.e., private placement); require periodic reporting of personal securities transactions and all holdings; and require prompt internal reporting of Code violations to our Chief Compliance Officer. A copy of our Code is available upon request by contacting our Chief Compliance Officer at 703-810-1072. Our employees may purchase, sell, or hold the same securities that are recommended to clients. Trades by employees are executed in a manner consistent with our fiduciary obligations to our clients. Employee trades must not be timed to precede orders placed for any client, nor should trading activity be so excessive as to conflict with the employee’s ability to fulfill daily job responsibilities. All employees are required to sign a statement acknowledging their understanding of the rules, which are designed to prevent potential compliance-related concerns and mitigate potential conflicts, on an annual basis. The Chief Compliance Officer monitors employee trading, relative to client trading, to ensure that employees do not engage in improper transactions. Item 12: Brokerage Practices Recommendation of LPL Financial NWFA will generally recommend that clients establish a brokerage account with LPL Financial to maintain custody of clients’ assets and to effect trades for their accounts. LPL Financial provides brokerage and custodial services to independent investment advisory firms, including NWFA. For NWFA’s accounts custodied at LPL Financial, LPL Financial generally is compensated by clients through commissions, trails, or other transaction-based fees for trades that are executed through LPL Financial or that settle into LPL Financial accounts. For IRA accounts, LPL Financial generally charges account maintenance fees. In addition, LPL Financial also charges clients miscellaneous fees and charges, such as account transfer fees. NWFA does not have discretionary authority to select the broker/dealer and custodian used for transactions, or to set transaction charges. While LPL Financial does not participate in, or influence the formulation of, the investment advice NWFA provides, certain supervised persons of NWFA are Dually Registered Persons. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or executing client transactions in such client accounts through any broker-dealer or custodian that is not approved by LPL Financial. As a result, the use of other trading platforms must be approved not only by NWFA, but also by LPL Financial. Clients should also be aware that for accounts where LPL Financial serves as the custodian, NWFA is limited to offering services and investment vehicles that are approved by LPL Financial, and may be prohibited from offering services and investment vehicles that may be available through other broker- dealers and custodians, some of which may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL Financial. Clients should understand that not all investment advisers require that client’s custody their accounts and trade through specific broker-dealers. 18  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 Clients should also understand that LPL Financial is responsible under FINRA rules for supervising certain business activities of NWFA and its Dually Registered Persons that are conducted through broker-dealers and custodians other than LPL Financial. LPL Financial charges a fee for its oversight of activities conducted through these other broker-dealers and custodians. This arrangement presents a conflict of interest because NWFA has a financial incentive to recommend that you maintain your account with LPL Financial rather than with another broker-dealer or custodian to avoid incurring the oversight fee. When appropriate and based upon the needs of each sponsored-plan, we may recommend that a plan use a certain retirement plan platform or service provider (such as a recordkeeper, administrator or broker-dealer). That recommendation may include using our custodian, LPL Financial, to serve as broker-dealer in connection with the sale of securities or insurance products to the Plan. Benefits Received by NWFA Personnel LPL Financial makes available to NWFA various products and services designed to assist NWFA in managing and administering client accounts. Many of these products and services may be used to service all or a substantial number of NWFA’ accounts, including accounts not held with LPL Financial. These include software and other technology that provide access to client account data (such as trade confirmation and account statements); facilitate trade execution (and aggregation and allocation of trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of NWFA’ fees from its clients’ accounts; and assist with back- office functions; recordkeeping and client reporting. LPL Financial also makes available to NWFA other services intended to help NWFA manage and further develop its business. Some of these services assist NWFA to better monitor and service program accounts maintained at LPL Financial, however, many of these services benefit only NWFA, for example, services that assist NWFA in growing its business. These support services and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include practice management-related publications; consulting services; attendance at conferences and seminars, meetings, and other educational and/or social events; marketing support; and other products and services used by NWFA in furtherance of the operation and development of its investment advisory business. Where such services are provided by a third party vendor, LPL Financial will either make a payment to NWFA to cover the cost of such services, reimburse NWFA for the cost associated with the services, or pay the third party vendor directly on behalf of NWFA. The products and services described above are provided to NWFA as part of its overall relationship with LPL Financial. While as a fiduciary NWFA endeavors to act in its clients’ best interests, the receipt of these benefits creates a conflict of interest because NWFA’s recommendation that clients custody their assets at LPL Financial is based in part on the benefit to NWFA of the availability of the foregoing products and services and not solely on the nature, cost or quality of custody or brokerage services provided by LPL Financial. NWFA’s receipt of some of these benefits may be based on the amount of advisory assets custodied on the LPL Financial platform. Transition Assistance Benefits 19  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 LPL Financial provides various benefits and payments to Dually Registered Persons that are new to the LPL Financial platform to assist the representative with the costs (including foregone revenues during account transition) associated with transitioning his or her business to the LPL Financial platform (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the Dually Registered Person’s business, satisfying any outstanding debt owed to the Dually Registered Person’s prior firm, offsetting account transfer fees (ACATs) payable to LPL Financial as a result of the Dually Registered Person’s clients transitioning to LPL Financial’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. Transition Assistance payments and other benefits are provided to associated persons of NWFA in their capacity as registered representatives of LPL Financial. However, the receipt of Transition Assistance by such Dually Registered Persons creates conflicts of interest relating to NWFA’ advisory business because it creates a financial incentive for NWFA’ representatives to recommend that its clients maintain their accounts with LPL Financial. In certain instances, the receipt of such benefits is dependent on a Dually Registered Person maintaining its clients’ assets with LPL Financial and therefore NWFA has an incentive to recommend that clients maintain their account with LPL Financial in order to generate such benefits. NWFA attempts to mitigate these conflicts of interest by evaluating and recommending that clients use LPL Financial’ s services based on the benefits that such services provide to our clients, rather than the Transition Assistance earned by any particular Dually Registered Person. Clients should be aware of this conflict and take it into consideration in making a decision whether to custody their assets in a brokerage account at LPL Financial. Transactions for each client account generally will be effected independently. However, on occasion we will aggregate transactions for clients that we have discretionary trading authority. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple clients’ accounts. Block trading may allow us to execute trades in a more timely and equitable manner. Item 13: Review of Accounts We review the performance of managed accounts on a periodic, ongoing basis. On at least an annual basis, we review the account’s rebalancing activity, review the fees charged to the account, review trading in the account against any client-directed restrictions, and review the performance of the account. We communicate with the client at least annually or more frequently to review any changes in their financial goals or profile which would require any changes in their asset allocation. Clients receive account statements directly from the custodian on at least a quarterly basis. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. Our firm does not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately engage our firm for a post- financial plan meeting or update to their initial written financial plan. We will contact you at least once a year to review our Retirement Plan Services. It is important that you 20  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 communicate any changes in the Plan's demographic information, investment goals, and objectives with your IAR. Plans may receive written reports directly from their IAR based upon the services being provided, including any reports evaluating the performance of Plan investment manager(s) or investments. Item 14: Client Referrals and Other Compensation LPL Financial NWFA and/or its Dually Registered Persons are incented to join and remain affiliated with LPL Financial and to recommend that clients establish accounts with LPL Financial through the provision of Transition Assistance (discussed in Item 12 above). LPL also provides other compensation to NWFA and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards and other benefits. The receipt of any such compensation creates a financial incentive for your IAR to recommend LPL Financial as custodian for the assets in your advisory account. We encourage you to discuss any such conflicts of interest with your representative before making a decision to custody your assets at LPL Financial. Other Third Parties We may occasionally co-sponsor educational seminars or receive marketing support from unaffiliated investment companies or mutual funds. Our clients do not pay more for investment transactions effected and/or assets maintained as result of this arrangement. There is no commitment made by us to any other institution as a result of this arrangement. Payments for Referrals NWFA and Northwest Federal Credit Union are affiliated entities. NWFA is a wholly owned subsidiary of Northwest Federal Credit Union. Northwest Federal Credit Union endorses the services of NWFA and receives a portion of the investment advisory fees received by NWFA. We also compensate certain Credit Union employees that refer credit union members that are in need of investment advisory services to us. Those referrals must meet certain qualifications, such as: • • • • Be immediately and genuinely interested in an NWFA product or service; Need a full-service advisor, not a self-directed product or service; Have the means to purchase an NWFA product or service; and Keep their scheduled meeting with the IAR. Referrals cannot, under any circumstances, be qualified upon the result of a meeting or conversation. We do not qualify Credit Union employee referrals based on whether or not an account was opened, the size of any resulting transaction, or the volume of assets gathered. For each referral that satisfies all of the above qualifications, NWFA pays the Credit Union employee up to $25. NWFA may from time to time also compensate, either directly or indirectly, other parties for client referrals. These parties are referred to as promoters and NWFA pays them either a portion of the advisory fee paid by the client or a flat fee. Disclosures are made to the client by the promoter at the time of any referral. 21  Other Compensation Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 NWFA may receive additional compensation from various vendors, product providers, distributors and others. These providers may provide non-monetary compensation by paying some expenses related to training and education, including travel expenses, and attaining professional designations. NWFA might receive payments to subsidize our own training programs. Certain vendors may invite us to participate in conferences, on-line training or receive publications that may further our skills and knowledge. Some may occasionally provide us with gifts, meals and entertainment of reasonable value consistent with industry rules and regulations. If applicable, and in the event the payments, or non-monetary compensation, are received in connection with or as a result of the Retirement Plan Services, we will disclose such fees to Sponsors in accordance with ERISA and Department of Labor regulations. Item 15: Custody Most client assets are held in custody by LPL, an unaffiliated broker/dealer, but we can access client funds through the ability to debit advisory fees. LPL sends statements directly to the account owners on at least a quarterly basis. Some clients choose to hold their assets at other custodians. Clients should carefully review these statements, and should compare these statements to any account information provided by us. The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian, LPL Financial: • • • • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. • • • The client has the ability to terminate or change the instruction to the client’s qualified custodian. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. NWFA will not serve as a custodian for Plan assets in connection with the Retirement Plan Services. Sponsor is responsible for selecting the custodian for Plan assets. We may be listed as the contact for the Plan account held at an investment sponsor or custodian. Sponsor for the Plan will complete 22  Form ADV Part 2 Brochure | Northwest Financial Advisors LLC March 2025 account paperwork with the outside custodian that will provide the name and address of the custodian. The custodian for Plan assets is responsible for providing the Plan with periodic confirmations and statements. We recommend that Sponsor reviews the statements and reports received directly from the custodian or investment sponsor. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Item 16: Investment Discretion We manage client accounts on a discretionary basis, subject to the restrictions (if any) that have been provided by clients. For accounts handled on a discretionary basis, we have the authority to determine the securities to be bought and sold without obtaining client consent to specific transactions; however the IAR will generally discuss investment recommendations prior to executing trades. Clients grant us trading discretion through the execution of a limited power of attorney included in the client’s advisory contract. Discretionary trading authority is not used for the purchase or sale of alternative investments or structured products. These will be discussed in detail with the client and authorization will be received in advance of any trading activity. ). When providing Retirement Plan Services described herein, we may exercise discretionary authority or control over the investments specified in the Agreement. We perform these services to the Plan as a fiduciary under ERISA Section 3(21) and investment manager under ERISA Section 3(38). We are legally required to act with the degree of diligence, care and skill that a prudent person rendering similar services see also, Item 4 above would exercise under similar circumstances. This discretionary authority is specifically granted to us by Sponsor, as specified in the Agreement ( Item 17: Voting Client Securities As a matter of policy, we disclaim any responsibility for voting client securities. Clients may contact us for advice or information about a particular proxy vote but we do not exercise proxy voting authority over client securities and should not be designated by custodians as the party to receive information on voting client proxies. The obligation to vote client proxies rests with the client. We have no authority or responsibility to vote any security held by the Plan or the related proxies. That authority is reserved by the Sponsor or trustee of the Plan. Item 18: Financial Information We are not required to file a balance sheet since we do not collect more than $1,200 in fees and six months or more in advance. In addition, there is no known financial condition that is reasonably likely to impair our ability to meet contractual commitments, and we have not been the subject of a bankruptcy proceeding. 23 

Item 1: Cover Page Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure March 2025 Wrap Fee Program Sponsored by: Northwest Financial Advisors, LLC 200 Spring Street, Suite 120 Herndon, VA 20170 www.nwfllc.com Firm Contact: Nicole Davis Chief Compliance Officer This brochure provides information about the qualifications and business practices of Northwest Financial Advisors (“NWFA”). If clients have any questions about the contents of this brochure, please contact us at 703-810-1072 or ndavis@NWFLLC.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 our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #166769. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes NWFA is required to make clients aware of information that has changed since the last annual update to the Wrap Brochure (“Wrap Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. There were no material changes made to our Wrap Brochure since our last annual amendment in March 2024. Effective, January 1, 2019, NWFA has also discontinued the SWM II Wrap Program for new clients. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 2 NWFA  Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................................................................................. 1 Item 2: Mate rial Changes ................................................................................................................................................................................. 2 Item 3: Table of Contents ................................................................................................................................................................................ 3 Item 4: Services, Fees & Compensation ....................................................................................................................................................... 4 Item 5: Account Requirements & Types of Clients ................................................................................................................................. 7 Item 6: Portfolio Manager Selection & Evaluation.................................................................................................................................. 8 Item 7: Client Information Prov ided to Portf olio Manager(s) ........................................................................................................ 10 Item 8: Client Contact with Portfolio Manager(s) ................................................................................................................................ 10 Item 9: Additional Information ................................................................................................................................................................... 11 ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 3 NWFA  Item 4: Services, Fees & Compensation We generally provide advisory services through programs sponsored by LPL Financial, LLC (“LPL Financial”), a registered investment adviser and broker-dealer. LPL Financial is independently owned and operated and not affiliated with us or Northwest Federal Credit Union. LPL Financial offers wrap-fee programs and non-wrap fee programs to clients. Our firm sponsors a wrap fee program, which allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Transaction fees will be paid your firm via individual transaction charges. Because our firm absorbs client transaction fees, a financial incentive exists to recommend transactions in securities that carry lower fees (e.g., transactions involving equity securities may be recommended over fixed income securities because of the lower transaction charge) or to limit trading activities in client accounts. Custodial transaction costs, however, are not included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the client to LPL Financial. Depending on the client’s account or portfolio trading activity, clients may pay more for using our wrap fee services than they would for using our non-wrap services. The advisory fee we charge may take the payment of transaction charges into consideration. That is, the advisory fee we charge to other accounts may be lower than the advisory fee we charge to accounts for which we are paying the transaction charges. You should also understand that engaging in a “buy and hold” strategy would not capitalize on any higher advisory fee being charged in light of our paying for the transaction charges in certain securities. In addition, these conflicts may also have an impact on the performance of your account. By participating in a wrap fee program, you may end up paying more or less than you would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to you by LPL Financial. Our wrap program offers clients an asset management account that is directly managed by our firm’s investment adviser representatives. Clients pay a single wrap fee for advisory services and associated custodial transaction costs. Clients participating in our non-wrap account pay an asset- based management fee and separate transaction costs. Please see our Firm Brochure for more information regarding our asset management services. Our Wrap Advisory Services Strategic Wealth Management Program (“SWM”): As part of our SWM wrap program service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and/or other investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. It is important to note that not all investments recommended by NWFA can be held in a wrap account. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 4 NWFA  Fees: The maximum annual fee to be charged to the client’s account(s) will not exceed 1.50%. The fee to be assessed to each account will be detailed in the client’s signed advisory agreement or LPL Financial Account Application. Fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from the account(s). Please note that fees will be adjusted for deposits and withdrawals made during the quarter. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during the next regularly scheduled billing cycle. As part of this process, Clients understand the following: a) b) c) LPL Financial as the client’s custodian sends statements at least quarterly, showing all disbursements for each account, including the amount of the advisory fees paid to our firm; Clients provide authorization permitting LPL Financial to deduct these fees; LPL Financial calculates the advisory fees for all fee schedules and deducts them from the client’s account. Other Types of Fees & Expenses: In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus, mark-ups and mark- downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. When providing services, we use mutual funds that the custodian makes available. Mutual funds offer multiple share classes which can be titled, for example, as Class A, Class I, institutional, fee- based, investor, retail, service, administrative or platform share classes. The mutual funds are no- load or load-waived share classes and therefore not subject to any upfront sales charge. However, different mutual fund share classes have different expense structures (i.e., some higher and some lower) and in some cases the mutual fund share classes pay a 12b-1 fee, administrative fee, recordkeeping fee, and/or revenue sharing fee to the custodian. You should understand that the mutual fund share class we select for purchase in your account in some cases will not be the least expensive share class that the mutual fund makes available. We select mutual fund share classes based on a variety of different considerations, including but not limited to: the advisory fee that is charged; the amount of the transaction charges applied to the purchase or sale of the mutual fund; the anticipated frequency of transactions; the holding period for the mutual funds; the overall cost structure of the advisory program; share class eligibility requirements; and potential tax consequences. You should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through accounts. Termination and Refunds Either party may terminate the signed advisory agreement at any time. Upon receipt of your notice of termination, LPL Financial will process a pro-rated refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 NWFA  ERISA and Retirement Accounts If the client is a qualified plan subject to the Employee Retirement Income Security Act of 1974 (ERISA) or a plan within the meaning of Section 4975(e) of the Internal Revenue Code of 1986 (the Code), NWFA is acting as a fiduciary under ERISA as defined in Section (21) of ERISA or Section 4975 of the Code with respect to services listed in Item 4 of the Brochure. There is a conflict of interest for individuals that currently invest in an employer-sponsored retirement plan or individual retirement account that are considering a rollout of assets from the retirement plan or account. A conflict of interest exists because we will be compensated only if the individual rolls over the proceeds into an IRA that we then manage. As a result, it can be construed that we have a financial incentive to recommend one option over another. The individual considering the roll out of assets into an IRA should understand that certain IARs associated with NWFA maintain an education-only policy with respect to rollovers and certain other IARs will make a recommendation with respect to a rollover. To the extent the IAR maintains an education-only policy, NWFA and its IAR will not make a recommendation and the individual is solely responsible for considering all relevant services, fees, and conflicts of interest applicable to the management services by NWFA. To the extent an IAR makes a rollover recommendation, the recommendation to roll out assets into an IRA will only be made if it is determined to be in the individual’s best interest. Regardless, we encourage each individual to include in his/her decision making process, a thorough review of all options available; for example (i) remain invested in the current retirement plan or account (if available), (ii) transfer assets to a new employer-sponsored retirement plan (if available), (iii) transfer assets to an IRA with a financial institution, or (iv) withdraw assets directly, which would be subject to federal and applicable state and local taxes and possibly subject to the IRS penalty of 10% depending upon the age of the individual. When considering these options, NWFA encourages individuals to consider the advantages and disadvantages of each option, including any applicable fees and all features of each option. A decision to roll over assets should reflect consideration of various factors, the importance of which will depend on the individual’s needs and circumstances. Wrap Fee Program Recommendations: Effective, January 1, 2019, NWFA discontinued the SWM Wrap Program for new clients. Item 5: Account Requirements & Types of Clients Our firm has the following types of clients: We do not impose a minimum account size to become an advisory client; however certain programs offered by LPL Financial and other broker dealers may require a minimum amount of investable assets to open and maintain an account. A minimum initial account value of $25,000 was suggested for our SWM wrap program service. In certain instances, we permitted a lower minimum account size. • • • Individuals and High Net Worth Individuals; Trusts, Estates or Charitable Organizations; Pension and Profit Sharing Plans; ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 NWFA  • Corporations, Limited Liability Companies and/or Other Business Types Item 6: Portfolio Manager Selection & Evaluation Selection of Portfolio Managers: Our firm’s investment adviser representatives (“IARs”) act as portfolio manager(s) for this wrap fee program. A conflict arises in that other investment advisory firms may charge the same or lower fees than our firm for similar services. Our IARs are subject to individual licensing requirements as imposed by state securities boards. Our firm is required to confirm or update each IAR’s Form U4 on an annual basis. IAR supervision is conducted by our Chief Compliance Officer or management personnel. Our firm’s IARs will regularly review the Account and implement changes that the IAR deems appropriate. An official account review will be conducted and documented at least annually. The nature of these reviews is to learn whether client accounts are in line with their investment objectives and appropriately positioned. Advisory Business: Information about our wrap fee services can be found in Item 4 of this brochure. Effective, January 1, 2019, NWFA discontinued the SWM Wrap Program for new clients. Each SWM wrap program client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Performance-Based Fees & Side-By-Side Management: Our firm does not charge performance-based fees. Methods of Analysis, Investment Strategies & Risk of Loss: We use a long term investment philosophy and provide individual advice based on each client's risk tolerance. We review our client’s long-term and short-term financial needs and objectives, and risk tolerance or risk-aversion. Investment recommendations are based on information provided to us by our clients, financial records, responses to our questionnaires or personal interviews. We design each client’s investment strategy based on a thorough evaluation of the individual goals and objectives of each client. After analyzing a client’s financial situation and understanding their individual investment objectives, we will recommend investment programs sponsored by third party financial institutions including LPL Financial. Following client approval, we will implement each aspect of the strategy, as appropriate. Account supervision is guided by the stated objectives of the client, and all managed accounts will be maintained with an independent custodian broker- dealer. Our investment strategy involves recommending an asset allocation mix to our clients based on their individual needs by selecting an appropriate mix of mutual funds, exchange traded funds, equities, fixed income or Portfolio Managers to manage your assets. We monitor the asset allocation mix and performance of the investments, and make periodic adjustments to the account, as ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 NWFA  necessary to meet client objectives. In the event we recommend Portfolio Managers, we will monitor manager performance and various investment markets to determine if the allocation among investment options is appropriate or if changes to those options are necessary due to changes in the market or client’s needs. The description provided above is a brief overview of the investment category and is not intended to be complete. Investing in securities is inherently risky. An investment in individual securities or in a portfolio of securities could lose money. We cannot give any guarantee that we will achieve your investment objectives or that any client will receive a return of its investment. The description below is an overview of the risks entailed in our investment strategy and is not intended to be complete. All investing involves a risk of loss and the investment strategy offered by us could lose money over short or long periods. Performance could be hurt by a number of different market risks including but not limited to: Stock Market Risk. Stock market risk, which is the chance that stock prices overall will decline. An investment in individual securities or in a portfolio of securities could lose money. We cannot give any guarantee that we will achieve the client’s investment objectives or that any client will receive a return of its investment. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Alternative Strategy Mutual Funds. Certain mutual funds invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities are not registered as an investment company. Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 8 NWFA  ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 9 NWFA  their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions are magnified over time. Because of these distortions, these products should be actively monitored, as frequently as daily, and may not be appropriate as an intermediate or long-term holding. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. LPL imposes limitations on accounts purchasing leveraged or inverse ETFs, ETNs, and mutual funds. Please Note: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask any questions you may have. Voting Client Securities: As a matter of policy, we disclaim any responsibility for voting client securities. Clients may contact us for advice or information about a particular proxy vote but we do not exercise proxy voting authority over client securities and should not be designated by custodians as the party to receive information on voting client proxies. The obligation to vote client proxies rests with the client. Item 7: Client Information Provided to Portfolio Manager(s) All SWM wrap accounts are managed by our in-house licensed IARs. The IAR selected to manage the client’s account(s) or portfolio(s) will be privy to the client’s investment goals and objectives, risk tolerance, restrictions placed on the management of the account(s) or portfolio(s) and relevant client notes taken by our firm. Please see our firm’s Privacy Policy for more information on how our firm utilizes client information. Item 8: Client Contact with Portfolio Manager(s) Clients are always free to directly contact their IAR or Portfolio Manager with any questions or concerns about their portfolios or other matters. Item 9: Additional Information Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 10 NWFA  Financial Industry Activities & Affiliations We are a separately capitalized company that is indirectly owned by Northwest Federal Credit Union (the “Credit Union”). We will have relationships and clients may utilize the services of certain entities affiliated with the Credit Union. The particular services involved will depend on the types of services offered by the affiliated company. Affiliated companies will be engaged on an arms- length basis for services it provides our client. Services provided by affiliated companies may include, without limitation, banking, tax advice, insurance advice, estate planning, retirement planning, real estate purchases, and other specialized advisory services. Broker Dealer Northwest Financial Group LLC (“NWFG”) is a member of the Financial Industry Regulatory Authority (“FINRA”). NWFG receives commission-based compensation from LPL Financial for the sale of investment products. The compensation is earned by IARs in their capacity as registered representatives of LPL Financial. If a client desires to purchase investment products offered by LPL Financial through an IAR acting as a registered representative of LPL Financial then LPL Financial and NWFG will receive brokerage-related compensation for those services, such as commissions and/or trail fees. Information regarding the amount of brokerage compensation will be provided to the client before the transaction is completed. Clients are advised that investment products provided through LPL Financial are available from other financial institutions. LPL Financial is a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL Financial transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. Our IARs are licensed as registered representatives of LPL Financial, and will receive commissions for selling investment products to clients. A conflict of interest exists since an IAR has an incentive to recommend products that pay commissions. IARs do not receive commissions when providing investment advisory services through us. Credit Union Northwest Federal Credit Union offers traditional credit union services and products to its members, including checking and savings accounts and consumer loans. Employees of the Credit Union may refer banking customers who are in need of investment advisory services to us. Insurance Company NW Insurance Agency LLC(“NWIA”) is a licensed insurance agency offering insurance products. IARs may be licensed as insurance agents of NWIA and receive commission when selling insurance products. The receipt of commissions on the sale of insurance products may create an incentive for the IAR. Whether or not to use the insurance services from or through our affiliated Insurance Agency is at the discretion of the client. To the extent that advisory clients use the insurance services from or through our IARs, commissions will be paid to them as an appropriately licensed agent. Clients are advised that similar insurance services are available elsewhere. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Code of Ethics We have adopted a written Code of Ethics (the “Code”) predicated on the principal that we owe a fiduciary duty to our clients. The Code establishes guidelines for professional conduct and personal trading procedures, including certain pre-clearance and reporting obligations. We require pre-clearance before purchasing an IPO or limited offering (i.e., private placement); ADV Part 2A, Appendix 1 – Wrap Fee Brochure NWFA Page 11  require periodic reporting of personal securities transactions and all holdings; and require prompt internal reporting of Code violations to our Chief Compliance Officer. A copy of our Code is available upon request by contacting our Chief Compliance Officer at 703-810-1072. Our employees may purchase, sell, or hold the same securities that our recommended to clients. Trades by employees are executed in a manner consistent with our fiduciary obligations to our clients. Employee trades must not be timed to precede orders placed for any client, nor should trading activity be so excessive as to conflict with the employee’s ability to fulfill daily job responsibilities. All employees are required to sign a statement acknowledging their understanding of the rules, which are designed to prevent potential compliance-related concerns and mitigate potential conflicts, on an annual basis. The Chief Compliance Officer monitors employee trading, relative to client trading, to ensure that employees do not engage in improper transactions. Review of Accounts We review the performance of managed accounts on a continuous, ongoing basis. On a quarterly basis, we review the account’s rebalancing activity, review the fees charged to the account, review trading in the account against any client-directed restrictions, and review the performance of the account. We communicate with the client at least annually or more frequently to review any changes in their financial goals or profile which would require any changes in their asset allocation. Clients receive account statements directly from the custodian on at least a quarterly basis. Other Compensation LPL Financial NWFA and/or its Dually Registered Persons may be incented to join and remain affiliated with LPL Financial and to recommend that clients establish accounts with LPL Financial through the provision of Transition Assistance (discussed in Item 12 of our Firm Brochure). LPL Financial also provides other compensation to NWFA and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards and other benefits. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL Financial as custodian for the assets in your advisory account. We encourage you to discuss any such conflicts of interest with your representative before making a decision to custody your assets at LPL Financial. Other Third Parties We may occasionally co-sponsor educational seminars or receive marketing support from unaffiliated investment companies or mutual funds. Our clients do not pay more for investment transactions effected and/or assets maintained as a result of this arrangement. There is no commitment made by us to any other institution as a result of this arrangement. Payment for Referrals NWFA and Northwest Federal Credit union are affiliated entities. NWFA is a wholly owned subsidiary of Northwest Federal Credit Union. Northwest Federal Credit Union endorses the services and NWFA and receives a portion of the investment advisory fees received by NWFA. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 12 NWFA  We also compensate certain Credit union employees that refer credit union members that are in need of investment advisory services to us. Those referrals must meet certain qualifications, such as: • • • • Be immediately and genuinely interested in an NWFA product or service; Need a full service advisor, not a self-directed product or service; Have the means to purchase an NWFA product or service; and Keep their scheduled meeting with the IAR. Referrals cannot, under any circumstances, be qualified upon the result of a meeting or conversation. We are prohibited from qualifying Credit Union referrals based on whether or not an account was opened, the size of any resulting transaction, or the volume of assets gathered. For each referral that satisfies all of the above qualifications, NWFA pays the Credit Union up to $25. Financial Information • Our firm is not required to provide financial information in this Brochure because: • Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months. Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 13 NWFA