NPF INVESTMENT ADVISORS

Part 2A of Form ADV: Firm Brochure Norris, Perné & French L.L.P. d/b/a NPF Investment Advisors 40 Pearl Street NW, Suite 500 Grand Rapids, MI 49503 Telephone: (616) 459-3421 Facsimile: (616) 459-5369 E-mail: dhodge@npfinvest.com Web: www.npfinvest.com 03/24/2026 This brochure provides information about the qualifications and business practices of Norris, Perne & French L.L.P. dba NPF Investment Advisors (hereinafter “NPF” or “firm” or “we”). If you have any questions about the contents of this brochure, please contact us at (616) 459-3421 or at jstrockis@npfinvest.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 NPF is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for NPF is 104683. 1  Item 2. Summary of Material Changes Since the last annual filing of our Brochure, we have made the following material changes: • NPF launched an Exchange Traded Fund in March 2026. There are substantial updates throughout this disclosure brochure that reflect the services, operations, and conflicts of interest related to this event. • NPF enhanced its relationship with Schwab that resulted in additional disclosures in Items 12 and 14. Item 3. Table of Contents Item Section 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. Cover Page Material Changes Table of Contents Advisory Business Fees and Compensation Performance-Based Fees and Side-by-Side Management Types of Clients Methods of Analysis, Investment Strategies and Risk of Loss Disciplinary Information Other Financial Industry Activities and Affiliations Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Brokerage Practices Review of Accounts Client Referrals and Other Compensation Custody Investment Discretion Voting Client Securities Financial Information Page Number 1 2 2 2 3 5 5 5 6 6 6 7 8 9 9 9 10 10 Item 4. Advisory Business NPF is a fee-only SEC-registered investment adviser (SEC file number 801-3475). Our principal place of business is Grand Rapids, Michigan. We have been in business since 1933. Kurt Arvidson and Charles Dutcher are the firm’s current principal equity owners. David Hodge, Daniel Lupo, and Tyler Bosgraaf are the firm’s current minority equity owners. Discretionary assets under our firm’s management were approximately $2,691,127,889 as of 12/31/2025. We do not currently have any non-discretionary assets under management. Exchange Traded Fund Management NPF serves as the investment advisor to the NPF Core Equity ETF (NPFE), which is sub-advised by Vident Asset Management and distributed by Paralel Distributors LLC. NPF is not affiliated with Vident or Paralel. NPF’s responsibilities for NPFE are the selection of portfolio securities, arranging trades of customized baskets of securities to rebalance the portfolio as needed, and coordinating the management activities as required by the Board of Directors of NPFE. NPF’s activities and responsibilities for NPFE are described further in the fund prospectus and Statement of Additional Information. The portfolio management of NPFE is designed to create broad exposure to stocks and is not a tailored advisory service that specifically relates to the individual needs of a particular client. Clients may not impose restrictions on investing in certain securities inside of NPFE. Separately Managed Account Services NPF manages individually tailored investment portfolios. Our firm provides continuous supervisory services and advice to clients regarding the investment of their funds based on the individual needs of the client. We define the goals and objectives of each client through personal discussions about their circumstances. We then construct the client’s investment policy, including an asset allocation target, and manage their portfolio based on that policy. During our data-gathering process, we determine the client’s objectives, time horizon, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as the background of their family. We manage advisory accounts with a customized level of discretionary service, as agreed with each client. For discretionary accounts, we will generally make trades without obtaining the consent of the client. For accounts for which the client requires us to consult with them before completing contemplated transactions, we will consult with the client regarding planned 2  transactions and seek their consent. Clients with these types of restrictions should understand that any delay in obtaining their consent may result in less favorable transaction terms, including a worse security price and/or limited availability of the securities sought. Our supervision of each client’s accounts is guided by the objectives of the client, as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. We use Pontera, a third-party service, to facilitate management of client assets in employer-sponsored retirement plans. Pontera enables us to supervise and manage client assets within the plan without having custody. Planning Services We offer financial planning services to clients and potential clients, which include comprehensive accounting for net worth and cash flows for personal and business assets; asset allocation review of portfolio assets, whether or not managed by NPF; tax management strategies; estate plan strategies; insurance needs & review; Social Security optimization; retirement planning; charitable planning; review of illiquid investments; equity compensation & concentrated stock positions; education planning; debt management; and special needs planning. We do not offer authoritative tax or legal advice, nor do we offer tax filing services. We select and implement services on behalf of our clients’ needs at the time we offer these services to the client, and our clients generally do not require the use of all our planning services. Our planning services generate specific recommendations tailored to each client’s situation. Our ability and willingness to offer these services depends on the client’s situation, our ability to secure the information required to formulate a prudent recommendation, and our ability and expertise required to deliver a recommendation to the client. Conflicts of Interest Regarding Our Services Almost all our compensation depends on the total value of the assets we manage. This means that we have a conflict of interest in advising you to maintain assets with other advisers, pay off debt, or invest in alternative asset classes that we do not offer. In addition, we will tend to focus our investment advice on the products about which we are most familiar: namely, our own investment strategies. If we recommend that you roll over an employer-sponsored retirement plan, such as a 401(k), 403(b), or pension plan, you might forego special features of these accounts, such as the ability to access accounts without penalty, borrow funds, or lifetime income options, to roll the funds over to an account we manage for you. In addition, the amount you pay us to manage your account may be more than you are currently paying for advice and administration in your retirement plan. Services in General Our investment, financial planning, and consulting recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will primarily include advice regarding the following instruments: • Equity securities • Corporate debt securities • Municipal securities • Exchange traded funds (ETFs) Occasionally, we may also offer advice/counsel on investments in the following instruments: • Certificates of deposit • “No-load” or “load-waived” mutual funds • Warrants • Commercial paper • Variable annuities • United States government securities • Private Placements in pooled investment vehicles We do not offer or represent private placements, nor are we a broker or dealer in any investments, whether public or private. Our advice is specific to our understanding of each client’s situation. We may provide different recommendations about the same investment to different clients, based on the relevant facts of each client’s situation. Item 5. Fees and Compensation Exchange Traded Fund Management Services NPF charges a unitary fee of 0.40% for the management of NPFE, which is calculated daily and paid monthly. NPF pays the cost of nearly all fund operations and administration from its unitary fee, except for brokerage commission costs, interest charges on short sales or other borrowings, taxes and related services, and extraordinary expenses of NPFE. More information about brokerage costs can be found in Item 12 of this brochure. 3  Separately Managed Account Services Our fees for Separately Managed Account Services are based upon a percentage of assets under management, subject to the minimum fee of $10,000 for new accounts. Our fees will not exceed the following fee schedule, subject to the minimum fee. Exceptions to the fee schedule can be made at NPF’s discretion. Assets Under Management ($) Annual Fee (%) First $2 million Next $3 million Over $5 million 0.90% 0.75% 0.55% Portfolio management fees are usually charged quarterly in advance at a rate of ¼ of the annual rate. Our fee calculation is based upon the net value of the assets in the client account on the last business day of the previous quarter. The net value of the assets in the account includes interest accrued on fixed income holdings as of the date of valuation, as well as dividends recorded before the quarter end but paid after the quarter-end before we complete our billing cycle. We do not adjust fees for cash flows into or out of accounts. Our accounting policies may be different from those of the custodian used by our clients, resulting in different values used for our billing purposes, depending on each custodian’s valuation procedures. Depending on the particular arrangement with each client, we send clients an invoice to pay by check or directly debit their custodial accounts for portfolio management fees. Planning Services In certain circumstances, we may charge clients for planning services on an hourly or project basis. While fees vary based on the complexity of the plan or project and the range of services we are retained to provide, our hourly rate ranges from $250 to $500 per hour, based on the complexity of the work involved. Fees are payable as services are performed. We estimate how long a project will take and provide the client with a quote based on the hourly rate. We may require an advance deposit, and the balance becomes due and payable upon completion of the service. The deposit amount is noted in the agreement the client signs. Fees in General Fees for all services may be negotiable based upon NPF’s sole discretion. We may group related client accounts for the purpose of determining the account size and/or annualized fee, depending on the nature of the relationship. Older client agreements may be governed by fee schedules different from those listed above. Clients who own NPFE and use our separately managed account services receive a credit towards their advisory fees for the portion of NPFE’s unitary fee that is earned as an advisory fee by NPF. We do not collect fees in excess of $1,200 more than six months in advance of services rendered. Account Termination Clients have a period of five (5) business days from the date of signing the agreement to unconditionally rescind the agreement and receive a full refund of fees. Thereafter, the client may terminate the agreement by providing us with a 30-day written notice at our principal place of business. Upon termination of an account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Occasionally, a complex termination may result in no fees being refunded. Mutual Fund and ETF Fees and Expenses All fees paid to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees reflect the internal costs of the fund. A client could invest in a mutual fund or an ETF directly, without the services of our firm. Accordingly, the client should review both the fees charged by the funds and ETFs and the fees charged by us to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Brokerage and Custodial Fees In addition to advisory fees paid to our firm, clients will also be responsible for all transaction, brokerage, trade- away and custodial fees incurred as part of their account management. Please see Item 12 of this Brochure for important disclosures regarding our brokerage practices. 4  Item 6. Performance-Based Fees and Side-By-Side Management We do not charge any fees based on a share of capital gains or capital appreciation of the assets of a client. Item 7. Types of Clients NPF generally provides Separately Managed Account services to individuals, foundations, endowments, pension and profit- sharing plans, trusts, estates, charitable organizations, corporations and other business entities. NPF provides Exchange Traded Fund services to NPFE. We will generally suggest a minimum relationship size of $1,500,000 (with a minimum annual fee of $10,000). Item 8. Methods of Analysis, Investment Strategies and Risk of Loss When deciding on the asset allocation for a client, we take into account the client’s risk tolerance, goals, investment objectives and other data gathered during client meetings. Asset allocation is an investment strategy that aims to balance risk and reward by apportioning a portfolio’s assets according to an individual’s goals, risk tolerance and investment horizon among various asset classes. The risk associated with asset allocation is that each class has different levels of risk and return, so each will behave differently over time. Also, despite being diversified, there is no guarantee that the account will grow. The methods of analysis, investment strategies, and risk of loss used in NPF’s management of NPFE are very similar to those used in NPF’s separately managed account services, except that NPFE does not include any asset allocation services, fixed income, or other investment service not described in the fund’s prospectus. Fundamental Analysis: Fundamental analysis of a business involves analyzing its income statement, financial statements, its management, competitive advantages, competitors, and markets. Fundamental analysis rests on the assumption that markets may misprice securities in the short run but that the "correct" price will eventually be reached. Fundamental analysis tries to make profits by buying the underpriced security and waiting for the market to recognize its "mistake" and re-price the security to a higher level. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments may result in significant price fluctuations that can lead to investor losses. Mutual fund and/or ETF analysis: We look at the experience and track record of the manager of the mutual fund or ETF to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF to determine if there is a significant overlap in the underlying investments held in other funds in the client’s portfolio. We also monitor the funds or ETFs to determine if they are continuing to follow their stated investment strategy. The risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the client’s portfolio. Risks for all forms of analysis: Our analytical methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate, misleading, or misinterpreted information. Long-term purchases: We purchase securities with the intent of holding them for a long-term time horizon. A risk of this long- term purchase strategy is that, by holding the security for a long period of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline in value before we make the decision to sell. All investments bear different types and degrees of risk and investing in securities involves the risk of loss that clients should be prepared to bear. While we use investment strategies that are designed to provide appropriate investment diversification, some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. A client needs to ask questions about risks he/she does not understand. 5  An investment could lose money over short or even long periods. A client should expect his/her account value and returns to fluctuate within a wide range, like the fluctuations of the overall stock and bond markets. The client’s account performance could be hurt by: • Stock market risk: The change that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices. Stock markets are also significantly affected by geopolitical risk and world events. NPF may also concentrate its investments in certain economic sectors or market capitalizations that magnify the risk inherent in the aggregate market. • Interest rate risk: The change that bond prices overall will decline because of rising interest rates. Interest rate risk will vary for us, depending on the amount of client assets invested in bonds. • Manager risk: The change that the proportions allocated to the various securities will cause the client’s account to underperform relative to benchmarks or other accounts with a similar investment objective. • Credit risk: This is the risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation. • Inflation risk: This is the risk that inflation will undermine the performance of your investment and/or the future purchasing power of your assets. • Cybersecurity risk: This is the risk that an unauthorized party could gain access to critical information or software used by NPF, the account custodian, or other vendors that are essential to the management of your account. This risk also applies to the investments that NPF selects. • Liquidity risk: Liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing the ability to sell such illiquid securities at an advantageous time or price, or possibly requiring the client to dispose of other investments at an unfavorable time or price in order to satisfy its obligations. • ETF risks: NPFE may trade at market prices that are different from the Net Asset Value (NAV) for a variety of reasons, and this risk may be heightened at times of market stress. There may be insufficient liquidity in the market to execute client orders, either individually or in aggregate, for buying or selling, if the volume of client orders exceeds the capacity of authorized participants, market makers, and other liquidity providers to meet that volume at that time. NPFE has a limited operating history. Clients should understand that investing in any securities, including mutual funds and ETFs, involves a risk of loss of both income and principal that they should be prepared to bear. Item 9. Disciplinary Information Our firm has no reportable disciplinary events to disclose. Item 10. Other Financial Industry Activities and Affiliations Three of our employees are registered as representatives of Paralel, including David Hodge, one of our partners. The registration of our employees and partner with Paralel is strictly to meet regulatory requirements associated with the offering and management of NPFE. There are no material conflicts of interest or compensation arrangements related to or resulting from the registration of any of our employees or partners as registered representatives. Item 11. Code of Ethics, Participation in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal and state securities laws. Our Code of Ethics includes policies and procedures for the review of annual holdings reports and quarterly securities transactions reports and provides for oversight, enforcement, and recordkeeping provisions. A copy of our Code of Ethics is available to our advisory clients and prospective clients upon request to either David Hodge or Jason Strockis at the firm’s principal office address. Our firm or individuals associated with our firm may buy or sell securities identical to those recommended to or purchased for customers for their personal accounts. In addition, any related person(s) may have an interest or position in securities which may also be recommended to a client. This practice results in a potential conflict of interest, as we may have an incentive to manipulate the timing of such purchases to obtain a better price or more favorable allocation in rare cases of limited availability. We restrict personal trading, particularly when it relates to client securities holdings, to prevent unethical trading practices. To mitigate these potential conflicts of interest and ensure the fulfillment of our fiduciary responsibilities, we have established the following restrictions: 1. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) when their decision is substantially derived, in whole or in part, by reason of his or her employment, unless the information is also available to the investing public. No principal or employee of our firm may prefer his or her own interest to that of the advisory client. 2. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to transactions 6  made on behalf of advisory clients. Employees are prohibited from benefiting from transactions placed on behalf of advisory accounts. 3. We maintain a list of all securities holdings for our firm and all persons with access to advisory recommendations. 4. All our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 5. Any individual not in observance of the above may be subject to disciplinary action, including and up to termination. NPF has a material interest in NPFE, and the operations and management of NPFE are covered by NPF’s Code of Ethics. In addition to the personal trading practices of NPF’s employees and partners, which are governed by NPF’s Code of Ethics, NPF also monitors and mitigates trade timing conflicts for securities owned in both NPFE and separately managed client accounts. Item 12. Brokerage Practices We recommend the use of a broker dealers, provided that such a recommendation is consistent with our fiduciary duty to the client. Generally, for equity transactions, we will recommend the brokerage services offered by the client’s custodian. The factors considered by our firm when making this recommendation are the broker's ability to provide professional services, our experience with the broker, the broker's reputation, the quality of execution services, the costs of such services, the technology and reporting provided to clients, and cash feature options. We are not required to recommend or use the lowest-cost brokerage services, but any broker we recommend must meet our standards described above. Clients are not required to use a broker that we recommend. If a client instructs us to execute transactions through a broker they specify, we may not have the authority to negotiate commissions or obtain volume discounts, such that best execution may not be achieved. In addition, we may not be able to aggregate orders to reduce transaction costs, the client may receive less favorable prices, or there may be additional trading, custody, or delivery charges, all of which are paid by the client. We reserve the right to decline client-directed brokerage if we believe that this choice would hinder our fiduciary duty to the client or our ability to service the account. With respect to NPFE, NPF separately engages brokerage services on behalf of the fund that are different from the services offered with clients who use NPF’s Separately Managed Account services. The brokerage needs of NPFE are distinct from those of separately managed client accounts with respect to execution capabilities & promptness, market making capabilities, and the ability to process customized basket trades on behalf of the fund. Additionally, NPFE does not require the trade aggregation & allocation services that NPF’s separately managed client accounts require. As a result, NPF uses different brokerage selection criteria for NPFE than it does for separately managed client accounts. Fixed Income Trading We typically require brokerage discretion for fixed-income trades. This enables us to select brokers or dealers which provide the best prices on fixed-income trades. The reasonableness of commissions or mark-up costs is based on the broker/dealer's ability to provide professional services, competitive costs, and other services which help us in providing investment management services to clients. We may use a broker who provides useful research and securities transaction services even though a lower commission may be charged by a competing broker. Research services may be useful in servicing all our clients, and not all such research may be useful for the account for which the particular transaction was affected. For Fidelity accounts holding fixed income securities with an aggregate value below $105,000, all fixed income trades will be traded through Fidelity. When selling fixed income securities on behalf of clients, we will sometimes arrange a swap of the position among unrelated client accounts. We use several fixed income brokers to provide pricing for this service, and we use the lowest-cost provider to execute these trades. NPF does not earn any direct or indirect compensation from swapping fixed income positions among clients. We use this practice to ensure that clients receive the best price available on the sale of a fixed income position, and, in instances in which the position would be a fit for the objectives for an unrelated client at the price obtained in the swap, we will arrange the swap through an unrelated broker. Soft-Dollar Arrangements We do not have any formal or informal soft-dollar arrangements. Our firm participates in the Schwab Advisor Servies (SAS) services program offered to independent investment advisers by Charles Schwab & Company, Inc. (“Schwab”), a FINRA-registered broker dealer. Clients in need of brokerage and custodial services may have Schwab recommended to them. While there is no direct linkage between the investment advice given and participation in the SAS program, economic benefits are received which would not be received if our firm did not give investment advice to clients. These benefits include: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk serving SAS participants exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; ability to have investment advisory fees 7  deducted directly from client account; access, for a fee, to an electronic communication network for client order entry and account information; receipt of compliance publications; and access to mutual funds which generally require significantly higher minimum initial investments or are generally available only to institutional investors. The benefits received through participation in the SAS program may depend upon the number of transactions directed to, or the amount of assets custodied by, Schwab. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf once the value of our clients’ assets at Schwab reaches certain thresholds. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions. The fact that we receive these services from Schwab is an incentive for us to recommend the use of Schwab that represents a conflict of interest. We believe, however, that our recommendation of Schwab as a custodian and broker is in the best interests of our clients, which is supported by our best execution reviews and competitive brokerage costs paid by clients. Our firm participates in the Fidelity Institutional Wealth Services Program (hereinafter, “FIWS”) sponsored by Fidelity Brokerage Services LLC (hereinafter, “Fidelity”), member NYSE/SIPC. Clients in need of brokerage and custodial services may have Fidelity recommended to them. While there is no direct linkage between the investment advice given to clients and our firm’s participation in the FIWS program, we receive economic benefits which would not be received if we did not give investment advice to clients. These benefits include: A dedicated trading desk that services FIWS participants exclusively; a dedicated service group and an account services manager dedicated to our firm’s accounts; access to a real-time order matching system; ability to ‘block’ client trades; electronic download of trades, balances and positions; access, for a fee, to an electronic interface with FIWS’ software; duplicate and batched client statements, confirmations and year-end summaries; the ability to have advisory fees directly debited from client accounts; availability of third-party research and technology; a quarterly newsletter; access to Fidelity mutual funds, internet access to statements, confirmations, and tax reports; access to mutual fund families and mutual funds NOT affiliated with Fidelity, some of which have no transaction fee; and the ability to have loads waived for our clients who invest in certain Fidelity loaded funds, when certain conditions are met and maintained. Participation in the SAS and FIWS programs may represent a conflict of interest for our firm, as the receipt of the above benefits creates an incentive for us to use Schwab or Fidelity for the custody of client assets and the execution of client trades. We have reviewed the services of Schwab and Fidelity considering our responsibility to ensure that they provide best execution to our clients for separately managed account services. As a result of our review, we recommend their services based on several factors, including the quality of the professional services they offer; their commission rates; and the quality of their custodial and trading platforms. We may periodically attempt to negotiate lower commission rates for our clients with Schwab and Fidelity. For clients who do not use Fidelity or Schwab as a custodian, we usually establish a DVP (Delivery versus Payment) account with Fidelity or Schwab to execute and settle trades with the client’s custodian. Should we decide to use another broker dealer to execute a client trade due to better availability, liquidity, or pricing, the custodial broker may charge an additional trade-away fee for each of these trades. We include the total cost of the trade in our assessment of whether or not to use our ability to trade-away on behalf of our clients. Trade Aggregation We aggregate orders with respect to the same security purchased or sold in separately managed client accounts. When orders are aggregated, each participating account receives the average share price for the transaction and bears a proportionate share of all transaction costs, based upon each account’s participation in the transaction, subject to our discretion depending on factual or market conditions. No client accounts are neither given preferential nor inferior treatment versus other client accounts. Allocations of orders among client accounts must be made in a fair and equitable manner. Trade Errors We examine the trade error policies of the brokers that we recommend to clients as part of our best execution review. We do not require clients to pay for trade errors that are the result of a mistake on the part of NPF. Item 13. Review of Accounts. The following individuals are responsible for periodic reviews of separately managed accounts: • Kurt Arvidson, CFA, Partner, Co-CIO, Investment Advisor • Charles Dutcher, CFA, CPWA Partner, Investment Advisor • Daniel Lupo, CFA, CFP, Partner, Investment Advisor • David Hodge, CFA, CFP, CDFA, Partner, Investment Advisor • Tyler Bosgraaf, CFA, CFP, Partner, Co-CIO, Investment Advisor • Lauren DeHaan Brennan, CRPC, Investment Advisor • Daniel Michaud, CFP, Associate Investment Advisor • Maria Kuiper, CFA, Associate Investment Advisor • Heather Elve, CFP, Associate Investment Advisor 8  The above-listed individuals continuously monitor the underlying securities in client accounts and perform quarterly reviews of account holdings for all clients. Accounts are reviewed for consistency with the investment policy statement, including the target asset allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent reviews may be triggered by changes in an account holder’s personal, tax, or financial status, significant deposits or withdrawals, or direction of the client. Political, geopolitical, and macroeconomic events may also trigger reviews. Clients receive monthly or quarterly statements and confirmations of transactions from their broker dealer or custodian. We deliver customized quarterly reports showing portfolio positions, cash and cost basis, market value, estimated annual income, and performance compared to relevant index benchmarks. For those clients engaging us for Consulting services, we do not provide any ongoing reviews or reports beyond those specifically outlined in the advisory agreement. Item 14. Client Referrals and Other Compensation We currently pay referral fees to third parties for referring advisory clients to our firm. If a client is introduced to us by an unaffiliated solicitor, we may pay that solicitor an ongoing or limited term referral fee ranging from 10% to 25% of the referred client’s advisory fee paid to our firm. Payment of referral fees for prospective client referrals creates a potential conflict of interest to the extent that such a referral is not unbiased, and the solicitor is motivated by financial gain. As these situations represent a conflict of interest, we have established the following restrictions to ensure our fiduciary responsibilities are met: 1. Referral fees are paid in accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. 2. Referral fees are paid solely from our fee and will not result in any additional charge to the client. 3. If the client is introduced to us by an unaffiliated solicitor, the solicitor, at the time of the solicitation, will disclose the nature of his/her/its solicitor relationship and provide each prospective client with a copy of our Form ADV Part 2 Brochure, together with a copy of the written disclosure statement from the solicitor to the client disclosing the terms of the solicitation arrangement between our firm and the solicitor, including the compensation to be received by the solicitor from us. 4. All referred clients will be carefully screened to ensure that our fees, services, and investment strategies are suitable for their investment needs and objectives, and that our recommendations to them are in their best interests. Our firm offers a bonus program to employees who refer clients to the firm. Bonuses are paid as a percentage of the client fee over a period of two years. No client covered by this program pays more in fees to cover the cost of the bonuses, and the firm and its employees retain the responsibility to ensure that the services recommended are in the client’s best interests. We receive an economic benefit from Schwab in the form of payments for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. Our clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit fromt eh arrangement because the cost of these services would otherwise be borne directly by us. Item 15. Custody Custody is defined as any legal or actual ability by our firm to access client funds or securities. Since all client funds and securities are maintained with a qualified custodian, we do not take physical possession of client assets. However, under the current SEC rules, our firm is deemed to have constructive custody of client assets due to various arrangements which give us legal access to client funds, including trustee and co-trustee services offered to a limited number of clients, our ability to initiate third party transfers from client accounts pursuant to standing letters of authorization, and our ability to directly debit client accounts for advisory fees. We ask our clients to authorize us to deduct our fees directly from the client’s account. Therefore, we urge all our management clients to carefully review and compare their quarterly reviews of account holdings and/or performance results received from us to those they receive from their custodian. Should you notice any discrepancies, please notify us immediately. Item 16. Investment Discretion For clients granting us discretionary authority to determine which securities and the amounts of securities that are to be bought or sold for their account(s), we require that such authority be granted in writing. Should the client wish to impose reasonable limitations on this discretionary authority, such limitations shall be included in this 9  written authority statement. Clients may change/amend these limitations as desired. Such amendments must be submitted to us by the client in writing. Item 17. Voting Client Securities Advisory clients may elect to delegate their proxy voting authority to us. Alternatively, clients may, at their election, choose to receive proxies related to their own accounts, in which case we may consult with clients as requested. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. In order to direct us as to how to vote a particular proxy, clients should contact David Hodge or Jason Strockis directly. We have retained the services of ProxyEdge by Broadridge Financial Solutions, Inc. (hereinafter “ProxyEdge”), an unaffiliated third-party proxy voting service. Through its platform, ProxyEdge will vote all proxies according to our voting guidelines. ProxyEdge maintains all records, including vote decision, date voted, policies for vote decision and meeting information for all our clients receiving proxies. ProxyEdge produces comprehensive reports annually showing the company name, CUSIP, meeting date, how the proposals were voted, client name, and shares voted. Clients may obtain a copy of our voting policies, procedures, and guidelines by contacting Jason Strockis directly. Clients may request, in writing, information on how proxies for their shares were voted. If any client requests a copy of our proxy policy or information on how we voted for his/her account(s), we will promptly provide such information to the client. We have engaged Broadridge Financial Solutions Inc to assist in filing Proofs of Claim for legal proceedings involving companies whose securities are held in the client’s account(s). Broadridge reviews clients’ possible claims to an announced shareholder settlement and pursues potential recoveries throughout the class action lawsuit process. Broadridge actively seeks out any open and eligible class action lawsuits and files, monitors and expedites the distribution of settlement proceeds in compliance with SEC guidelines on behalf of our clients. In return, Broadridge retains a contingency fee for filing Proof of Claims, which is deducted from the gross amount recovered for each client. We have assessed the terms of the agreement with Broadridge and find it to be in our clients’ best interests to retain them to provide these services on behalf of our clients. Item 18. Financial Information Under no circumstances will we collect fees in excess of $1,200 more than six months in advance of services rendered. 10