Peak American Investment Advisors, Inc.

Part 2A of Form ADV: Firm Brochure Item 1 Cover Page 2400 Dallas Parkway STE 100 Plano, TX 75093 972-212-9292 CRD# 145056 http://www.peakamericaninvestmentadvisors.com/ This brochure provides information about the qualifications and business practices of Peak American Investment Advisors, Inc. It is prepared pursuant to regulatory requirements. If you have any questions about the contents of this brochure, please contact us at the phone number or website listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Our registration as an Investment Advisor does not imply any level of skill or training. Additional information about Peak American Investment Advisors, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. September 8, 2026  Item 2 Material Changes Summary of Material Changes: The last annual update of this brochure was January 23, 2026. The following material change has occurred since that update: Digital leads are purchased to generate interest in speaking with our advisers. See Item 14. 2  Item 3 Table of Contents Item 1 Cover Page .................................................................................................................................... 1 Item 2 Material Changes ........................................................................................................................... 2 Item 3 Table of Contents ........................................................................................................................... 3 Item 4 Advisory Business .......................................................................................................................... 4 Item 5 Fees and Compensation ................................................................................................................ 6 Item 6 Performance-Based Fees and Side-By‐Side Management ........................................................... 8 Item 7 Types of Clients .............................................................................................................................. 8 Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss ...................................................... 8 Item 9 Disciplinary Information ................................................................................................................ 10 Item 10 Other Financial Industry Activities and Affiliations ....................................................................... 10 Item 11 Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .............. 10 Item 12 Brokerage Practices ..................................................................................................................... 11 Item 13 Review of Accounts ...................................................................................................................... 12 Item 14 Client Referrals and Other Compensation ................................................................................... 12 Item 15 Custody ........................................................................................................................................ 12 Item 16 Investment Discretion ................................................................................................................... 13 Item 17 Voting Client Securities ................................................................................................................ 13 Item 18 Financial Information .................................................................................................................... 13 3  Item 4 Advisory Business Introduction Incorporated in April 2007, Peak American Investment Advisors, Inc. (herein referred to as “Peak American IA,” “Firm,” “we,” ”our,” “us”) is a Texas corporation with a principal place of business located at 2400 Dallas Parkway STE 100, Plano, Texas 75093. We are registered as an investment advisor with the Securities and Exchange Commission. We are notice filed in various states, which means we can conduct business in these states. We can conduct business in other states by claiming an exemption from notice filing based on those states’ exemption policies. Our registration as an investment advisor does not imply any level of skill or training. The oral and written communications we provide you, including this Brochure, is information you can use to evaluate us and other advisors, which are factors in your decision to hire us or to continue to maintain a mutually beneficial relationship. This Brochure provides information about our qualifications and business practices. Ownership Peak American IA is a wholly owned entity of Peak American Financial Companies, Inc. Matthew W. McIntyre is the majority shareholder of Peak American Financial Companies, Inc., and an indirect owner of Peak American IA. Advisory Services Offered We provide the following services to our clients: • Wealth Management • Retirement Tax Strategy • Insurance Coordination • Retirement Income Solutions • Financial Planning • Estate Planning and Legacy Coordination • Referrals to CPAs and Estate Attorneys Wealth Management Services Peak American IA is an investment advisory firm which offers fee-based portfolio management services on a discretionary basis. Our service constitutes an ongoing process by which: a) Your investment objectives, constraints, and preferences are identified and specified; b) Your strategies are developed and implemented through a combination of financial assets; c) Capital market conditions and your circumstances are monitored; and d) Portfolio adjustments are made as appropriate to reflect significant changes to any or all of the relevant variables set out above. On a discretionary basis, we design, revise, and reallocate a custom portfolio for you. The investments are determined based upon your investment objectives, risk tolerance, net worth, net income, age, investment time horizon, tax situation, and other various suitability factors. In making recommendations to you, we shall rely on your profile document or questionnaire completed by you that reflects your circumstances, preferences, and objectives. Restrictions and guidelines imposed by you may affect the composition and performance of custom portfolios, as well as recommendations provided to you. As a result, performance of custom portfolios within the same investment objective can differ and you should not expect that the performance of your custom portfolio to be identical to any other individual’s portfolio performance. Portfolios can consist of individual stocks and bonds, options, ETF’s, mutual funds, cash and other securities, or other investment vehicles deemed appropriate by us. The investment programs identify your investment needs and goals, and we determine the appropriate mix of investments to attain that goal. 4  Retirement Tax Strategy Retirement planning goes far beyond building a portfolio—it’s about creating a tax-efficient income strategy that supports your lifestyle and preserves your wealth. Without a proactive plan, taxes can quietly erode your retirement income. Our approach is designed to help you minimize unnecessary tax exposure, maximize income, and maintain control over how and when your wealth is distributed. We integrate tax strategy directly into your financial plan—so every decision works together to support your long-term goals. Insurance Coordination Insurance isn’t viewed as a standalone product—it’s an essential part of a well-structured financial plan. We help you coordinate life insurance, long-term care coverage, and disability protection to safeguard your income, protect your assets, and preserve your legacy. By integrating insurance into your broader wealth and estate strategy, we ensure you’re prepared for the unexpected—without compromising your long-term goals. Retirement Income Solutions We build customized income strategies using a range of vehicles, thoughtfully combined to create balance and durability. Depending on your situation, this may include: • Guaranteed income sources that provide stability and peace of mind • “Homegrown” dividends from well-structured investment portfolios • Tax-efficient withdrawal strategies • Market-based growth components to help offset inflation Our role is to coordinate these elements into a cohesive plan—so your income isn’t left to chance, market timing, or guesswork. The result is a strategy designed to support your lifestyle today while preserving flexibility for tomorrow. Financial Planning Services Clients will receive a written report providing a basic financial plan designed to help achieve their stated financial goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: • Preparation of a recommended asset allocation that serves to diversify the client's portfolio among different categories of investments that are suitable in light of the client's investment goals, objectives, and risk tolerance. • Preparation of a retirement plan that serves to identify whether the client is saving enough and investing in a way that meets retirement objectives in light of the client's financial circumstances and risk tolerance. • Preparation of cash flow projections to ensure that the client can meet daily living expenses and • obligations. Insurance planning to meet the needs of the client, considering family, business, and other financial objectives of the client. Peak American IA gathers required information through in-depth personal interviews and questionnaires. Information gathered includes a client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report is prepared covering one or more of the above-mentioned topics as directed by the client. We use one or more licensed software programs to facilitate our financial planning services. Peak American IA is not a licensed tax or legal processional and does not provide accounting or legal services. Services rendered should not be interpreted as legal or accounting advice. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Peak American IA. To the extent that you would like to implement any of our investment recommendations through Peak American 5  IA, you must execute a separate written agreement with Peak American IA for our asset management services. Estate Planning and Legacy Coordination Services Estate planning is about more than documents. It’s about ensuring your wealth, your wishes, and your family are protected for generations to come. That’s why we treat it as an integrated part of your overall financial strategy, not an afterthought. While we are not attorneys, we work closely with a trusted network of legal partners to align your financial plan with the proper legal structures, including: • Proper asset titling • Beneficiary designations • Trust structures and estate vehicles • Tax considerations across generations Our role is to help you think through the decisions that matter and keep every piece aligned, so nothing is left to chance. Most importantly, we emphasize being proactive, not reactive. Referrals to CPAs and Estate Attorneys When clients come to us in need of a CPA or an estate attorney, we are happy to make referrals to those we trust. California Disclosure Pursuant to California Code of Regulation, CCR Section 260.238 (j), Peak American IA hereby discloses that clients may receive the same or comparable services from other financial advisors at a lower fee. All material conflicts of interest under California Code of Regulations, CCR Section 260.238 (k) are disclosed regarding Peak American IA, its representatives, or any of its employees, which could be reasonable expected to impair the rendering of unbiased and objective advice. Clients are under no obligation to act upon Peak American IA’s recommendations. If a client elects to act on our recommendations, the client is under no obligation to affect the transaction through us. Tailored Advisory Services Advisory services will be tailored to the individual needs of each client based on the goals and objectives of the client which are documented in the Firm’s client relationship management system. Clients may impose restrictions on investing in certain securities or types of securities in their accounts by notifying us in writing. Clients may change these restrictions at any time by notifying us. We do not participate in any wrap fee programs. Client Assets Under Management As of September 4, 2026, Peak American IA has $162,050,631 in discretionary assets under management. Item 5 Fees and Compensation Peak American IA Wealth Advisory Fees Peak American IA’s compensation for services is based on the following fee schedule: 1.45% 1.25% 1.20% 1.00% 0.90% 0.85% $0 - $250,000 $250,001 - $500,000 $500,001 - $1,000,000 $1,000,001 - $1,500,000 $1,500,001 - $3,000,000 $3,000,001+ 6  Clients authorize Peak American IA to deduct advisory fees directly from their custodial accounts. Client assets are maintained with Charles Schwab & Co., Inc. (“Schwab”), an independent qualified custodian. PAIA utilizes GeoWealth, LLC (“GeoWealth”), a third-party turnkey asset management platform, for certain portfolio management, trading, reporting, billing, and other administrative services. GeoWealth assists PAIA with the calculation and administration of advisory fees. Pursuant to the client's written authorization, fee information is transmitted to Schwab, and Schwab deducts the applicable advisory fee from the client's account. The amount of the advisory fee deducted is reflected on the client's custodial account statement provided by Schwab. All fees are calculated based upon the average daily market value of the assets held in your account over the billing period. Fees are paid monthly in arrears and are negotiable. Financial Planning Fees Financial planning services are included with portfolio management services. Peak American IA also provides financial planning services under a fixed-fee arrangement for those not wanting their portfolios to be managed by the Firm. Fees are based on several factors including time and labor, the nature and complexity of your situation, and any special circumstances involved. The fixed fee for a financial plan is $2,900, with $1,450 due to start the planning process and $1,450 due upon delivery of the financial plan (“Planning Fee”). We will typically complete your plan within sixty (60) days after you sign the Financial Planning Agreement. To the extent the client, within thirty (30) days of the execution of the Financial Planning Agreement, engages Peak American IA to provide investment management services regarding the portfolio assets, pursuant to the Peak American IA Portfolio Management Agreement (“Management Agreement”), Peak American IA will refund the Planning Fee to the client. The client retains the right, for any reason, to terminate their Financial Planning Agreement within the first five days after the client signs the Agreement and receive a complete refund of any fee paid. Thereafter, clients who decide to end their relationship will not be entitled to a refund as fees are considered earned. Clients who do not receive their financial plan within sixty (60) days are entitled to a full refund. No refunds are given once the financial plan is completed and delivered to the client unless another arrangement is mutually agreed upon. Other Charges Clients shall be solely responsible for all commissions and other transaction charges, and any charges relating to the custody of securities in the account(s), such as brokerage commissions, mark-ups and mark- downs, dealer spreads or other costs associated with the purchase and sale of securities, exchange fees, option assignment or exercise fees, custodian fees, bank charges, interest, taxes, or other account(s) expenses. In addition, shareholders of each mutual fund or exchange-traded fund in which the account(s) may be invested will also be charged investment advisory fees and other expenses which are disclosed in each fund’s prospectus or summary disclosure. Peak American IA does not share in any part of these additional charges. Other Compensation Received Advisory agents of the Firm are also licensed insurance agents for Peak American Financial Group, Inc., a registered insurance agency and affiliated firm of Peak American Financial Companies. If a financial plan includes the recommendations to purchase insurance products and you act upon that recommendation or buy insurance through our investment advisory agents, they receive a commission from insurance sales, which includes life, accident, disability, and fixed annuities. Peak American IA does not charge management fees on commission-based fixed index annuities. However, the advisory agent will receive commissions as an insurance agent from the recommendation of any insurance product, like a fixed index annuity. Commission may include additional sales awards or award trips. We will seek out the products of any company, agency, or brokerage that have products fitting your needs. The client always has the right to decide whether to act on insurance recommended by the investment advisory representative. If the client decides to act, clients have the right to do so through the professional they choose. 7  Portfolio management clients are fee-based and are not assessed commissions generated from securities transactions. Our Firm also has a written Business Continuity Plan identifying procedures relating to an emergency or significant business disruption including death or incapacitation of our Firm or any of its investment advisory agents. You can contact our office at 972-212-9292 for any questions about this or any other matter. Pursuant to California Code of Regulation, CCR Section 260.238 (j), Peak American IA hereby discloses that clients may receive the same or comparable services from other financial advisors at a lower fee. Item 6 Performance-Based Fees and Side-By‐Side Management We do not charge performance-based fees, nor do we provide side-by-side management services. Item 7 Types of Clients Client Base Our customer base consists of individuals and high net worth individuals. Conditions for Account Management We have imposed a minimum account size of $30,000 in assets to be managed. We can make an exception to these minimums from time to time based on individual factors such as length of time the account has been known, overall composition of the account, multiple accounts held with us, etc. This exception is in our sole discretion. Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis and Investment Strategies Our objective is to grow capital for our client’s future needs. However, our most basic responsibility is to guard a client’s principal. We work with you to devise an investment strategy to meet your financial objectives. This includes: • discussion regarding your objectives • review of existing holdings • ongoing analysis of funds • advice on best direction for new investments • updates of specific changes within the market or to particular funds • monitoring of recommended investments and reviews The flexibility of our strategies gives us the ability to best manage investment risks in any investment market. We use Charting and Fundamental security analysis methods. Charting Analysis is a way of gathering and processing price and volume information of a particular security by applying mathematical equations and then plotting the resulting data onto graphs in order to predict future price movements. Fundamental Analysis involves using real data to evaluate a security's value. We perform fundamental analysis on a securities value by looking at economic factors, such as interest rates and the overall state of the economy, information about issuers, potential changes in credit ratings, revenues, earnings, future growth, return on equity, profit margins, and other data to determine underlying value and potential for future growth. 8  You are advised to notify us promptly if there are ever any changes in your financial situation or investment objective or if you wish to impose any reasonable restrictions upon our management services. If you wish to impose any reasonable restrictions upon our management services, you will need to advise us in writing of any restrictions. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent, warrant, or imply that the services or methods of analysis employed by us can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. All securities trading, whether in stocks, options, or other investment vehicles, is speculative in nature and involves substantial risk of loss that clients should be prepared to bear. Past performance is not necessarily indicative of future results. Clients should make every effort to understand the risks involved. General Principle Risks of Investing include, but are not limited to: General Risks: Your investments with us are not a deposit of a bank and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Accordingly, you may lose money by investing with us. When you sell your investments, they may be worth less than what you paid for them because the value of investments will fluctuate reflecting day-to-day changes in market conditions, interest rates, and a number of other factors. Allocation Risk: Our allocation of investments among different asset classes, such as equity or fixed-income assets classes, may have a more significant effect on your returns when one of these classes is performing more poorly than others. Market Risk: Stock and bond markets often trade in random price patterns, and prices can fall over sustained periods of time. The value of the investments we make for you will fluctuate as the financial markets fluctuate. This could result in your account value(s) declining over short- or long-term periods of time. Equity Risk: Your investments will be subjected to the risk that stock prices may fall over short or extended periods of time. Historically, the equity markets have moved in cycles, and the value of equity securities in your portfolio may fluctuate drastically from day to day. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. These factors will contribute to the volatility and risk of your assets. Foreign Securities Risk: We have the ability to invest in foreign securities, and, from time to time, a significant percentage of your assets may be composed of foreign investments. Foreign investments involve greater risk in comparison to domestic investments because foreign companies/securities: may have different auditing, accounting, and financial reporting standards; may not be subject to the same degree of regulation as U.S. companies and may have less publicly available information than U.S. companies; and are often denominated in a currency other than the U.S. dollar. Currency Risk: Your investments may be subject to currency risk. Currency fluctuations and changes in the exchange rates between foreign currencies and the U.S. dollar could negatively affect the value of your investments in foreign securities. Interest Rate Risk: Your investments are subject to interest rate risk. Interest rate risk is the risk that the value of a security will decline because of a change in general interest rates. Investments subject to interest rate risk will usually decrease in value when interest rates rise. For example, fixed-income securities with long maturities typically experience a more pronounced change in value when interest rates change. 9  Credit Risk: Your investments are subject to credit risk. An investment’s credit quality depends on its ability to pay interest on and repay its debt and other obligations. Prepayment Risk: Your investments may be subject to prepayment risk. Prepayment risk occurs when the issuer of a security can repay principal prior to the security’s maturity. Securities subject to prepayment can offer less potential for gains during a declining interest rate environment and similar or greater potential for loss in a rising interest rate environment. In addition, the potential impact of prepayment features on the price of a security can be difficult to predict and result in greater volatility. Inflation Risk: This is the risk that the value of your assets or income investments will be less in the future as inflation decreases the value of your money. As inflation increases, the value (purchasing power) of your assets can decline. This risk increases as we invest a greater portion of your assets in fixed-income securities with longer maturities. Item 9 Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. Our Firm does not have any material facts about legal or disciplinary events that are material to your evaluation of the integrity of our Firm or its investment advisory representatives to disclose. Your confidence and trust placed in our Firm and its investment advisory representatives is something we value and endeavor to protect. Item 10 Other Financial Industry Activities and Affiliations Relationship with Peak American Financial Group, Inc. Our investment advisory representatives are also licensed insurance agents for Peak American Financial Group, Inc., an affiliated insurance agency with our Firm. In their capacity as a licensed insurance agent, investment advisory representatives will earn commission-based compensation for implementing insurance products on behalf of clients. This creates a conflict of interest that the investment advisory representative is also a licensed insurance agent and can recommend insurance products to clients. We address our fiduciary duty by utilizing insurance products only where it is in the best interest of clients, and after consultation with the client. Peak American IA will not charge management fees on commission-based fixed index annuities. The client always has the right to decide whether to act on any insurance recommended by the investment advisory representative. If the client decides to act, clients have the right to do so through the professional they choose. Item 11 Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Code of Ethics We have adopted a Code of Ethics Policy to mitigate conflicts of interest from personal trading by our advisory personnel and have established standards of conduct expected of our advisory personnel. We have set forth in the Code of Ethics Policy statements of general principles, required course of conduct, reporting obligations, and review and enforcement of the Code of Ethics Policy. We will provide a copy of the Code of Ethics Policy to our clients or prospective clients upon written request. Participation or Interest in Client Transactions / Personal Trading Our investment advisory representatives will buy or sell for themselves securities that they also recommend to you. While we allow investment advisory representatives to purchase or sell the same securities that may 10  be recommended to and purchased on behalf of clients, such trades are typically aggregated with client orders or traded afterward. At no time will we, or any investment advisory representative of our Firm, engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. We will do everything possible to mitigate these conflicts. Records of all advisory associates’ proprietary trading activities are reviewed and kept by us. We and our advisory agents will act in a fiduciary manner, understand the prohibitions against the use of any insider information and will always act in your best interest. Trading of affiliates of the advisor are prohibited from frontrunning or disadvantaging of client accounts. Item 12 Brokerage Practices Brokerage Selection We recommend Charles Schwab & Co., Inc. (Member FINRA/SIPC), as the custodian for client accounts and for the execution of securities transactions therein. Custody of your accounts for both securities and funds will be maintained at Schwab. We are not a subsidiary of, or an affiliated entity of Schwab. We have sole responsibility for investment advice rendered, and our advisory services are provided separately and independently from Schwab. Factors considered when determining the reasonableness of a custodian’s compensation for execution services include, but are not limited to, price and the quality of services offered by the Firm. The custodian used to provide execution services offer our clients substantial financial strength and stability, economies of scale, and reliable execution services. In seeking best execution, the determinative factor is not the lowest possible commission cost, although that is clearly an important factor, but the holistic analysis of best execution entails evaluating whether the transaction represents the best qualitative execution, taking into consideration the full range of custodian services, including the value of research provided, execution capability, commission rates, and responsiveness. We do not render advice to or take any actions on behalf of you with respect to any legal proceedings, including bankruptcies and shareholder litigation, to which any securities or other investments held in client accounts, or the issuers thereof, become subject, and does not initiate or pursue legal proceedings, including without limitation shareholder litigation, on behalf of you with respect to transactions, securities or other investments held in your accounts. The right to take any actions with respect to legal proceedings, including shareholder litigation, with respect to transactions, securities, or other investments held in a client account is expressly reserved to you. Directed Brokerage We do not permit clients to direct brokerage. Brokerage for Client Referrals Neither our Firm nor our investment advisory representatives receive client referrals from a broker dealer or other third party when recommending to you a custodian for the execution of securities transactions. Soft Dollar Practices Our custodian makes available to us products and services that benefit us but may not directly benefit our clients’ accounts. Some of these products and services assist us in managing and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); provide research, pricing information, and other market data; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. As a fiduciary, we endeavor to act in our clients’ best interests. While we recommend that clients maintain their assets in accounts at the custodian, that recommendation is based in part on the benefit to us of the availability of some of the foregoing products and services, and not solely on the nature, cost, or quality of 11  custody and brokerage services provided by custodian, which creates a conflict of interest. We mitigate that conflict of interest through disclosures made in this Brochure, client agreements, and in reports and conversations with clients. We believe that our recommendation of this custodian is in the best interest of our clients based upon the services provided by the custodian and the fees charged by the custodian. Trade Aggregation We may aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and each client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. We may determine not to aggregate transactions, for example, based on the size of the trades, the number of client’s accounts, the timing of the trades, the liquidity of the securities or the discretionary or non-discretionary nature of the trades. If we do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. Item 13 Review of Accounts Account reviews will be provided quarterly, but no less than annually, with the client or by your request. Reviews can be warranted more frequently due to tax law changes, market changes, market conditions, or changes in your personal circumstances. Reviews initiated by you can be for personal objectives or for any reason you so desire. The review will be conducted by the individual Investment Adviser Representative managing your account(s) and will be consistent with your desires regarding frequency and changing circumstances or objectives. Written statements and confirmations are furnished from your custodian with which you transact business. They are either mailed or provided electronically to you by these institutions. Item 14 Client Referrals and Other Compensation Client Referrals We purchase digital leads from various vendors, who run Facebook ads on different financial sites to generate interest in speaking with a financial advisor. Other Compensation Our Firm and/or our investment advisory representatives do not receive any economic benefit other than soft dollar benefits disclosed in item 12 of this brochure from a non-client in connection with giving advice to you. Item 15 Custody Your funds and securities will be maintained with a “qualified custodian” as required under Rule 206(4)-2 under the Advisers Act and we will not take physical possession of any client funds or securities. Custody for both funds and securities will be maintained at Schwab. Account statements are sent at least quarterly from the custodian, and you should carefully review those statements promptly when you receive them. Because Peak American IA generally has the authority to instruct the account custodian to deduct the investment management fee directly from the client’s account, we are considered to have “custody” of client assets. Custody is defined as having any access to client funds or securities. This limited access is monitored by the client through receipt of account statements directly from the custodian. These statements show the deduction of the management fee from the account. Otherwise, we may only direct the movement 12  of funds from one account in the client’s name to another such titled account but have no other access to funds. Safeguards The following are the safeguards the Firm has implemented: • written authorization from the client permitting us to receive fee payments directly from the client’s account and • an agreement by the custodian to send the client, at least quarterly, a statement showing all amounts disbursed from the account. Item 16 Investment Discretion Discretionary authority must be granted by the client in the client agreement. This authority will allow us to determine the type of securities and the amount of securities that can be bought or sold for the client portfolio without obtaining the client’s consent for each transaction. If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you prior to implementing changes in your account. Therefore, you will be contacted and required to accept or reject our investment recommendations including: • The security being recommended • The number of shares or units • Whether to buy or sell Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, you need to know that if you are not able to be reached or are slow to respond to our request, it can have an adverse impact on the timing of trade implementations, and we may not achieve the optimal trading price. Item 17 Voting Client Securities We do not have any authority to and do not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. We shall forward any proxy materials we receive that pertain to the assets in client accounts to you. You can contact our office at 972-212-9292 for any questions about a particular solicitation. Item 18 Financial Information We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. We do not have any financial condition that is reasonably likely to impair the ability to meet contractual commitments to you. We have never been the subject of a bankruptcy petition. 13