Peak Financial Planning

Item 1: Cover Page Peak Financial Planning, LLC Form ADV Part 2A – Firm Brochure 21201 Victory Blvd Suite 215, Canoga Park, California 91303 818-600-6099 April 28, 2026 This Brochure provides information about the qualifications and business practices of Peak Financial Planning, LLC, “PFP”. If you have any questions about the contents of this Brochure, please contact us at 818-600-6099 or by email at eric@thepeakfp.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. Peak Financial Planning, LLC is registered as an Investment Adviser with the State of California. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about PFP is available on the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s identification number, 317288. 1  Item 2: Material Changes The last annual update of this Brochure was filed on March 13, 2026, since this filing, material changes were made to the brochure. • Updated Onboarding and Refund Policy: ITEM 5: Fees and Compensation • Meeting Rescheduling and Forfeiture: We have implemented a new policy regarding client onboarding requirements and deposit refunds (Item 5). Clients are now required to reach "Onboarding Complete" status within 21 days of the engagement start date to maintain eligibility for our satisfaction guarantee and deposit refunds. We have clarified our rescheduling policy. Clients are • Minimum Annual Fee: permitted one reschedule for the Plan Proposal meeting. A second reschedule or failure to attend will result in the immediate termination of the engagement and forfeiture of the initial deposit as compensation for the Firm’s lost planning capacity. We have included that if a client’s assets under management with the Advisor are less than One Million Dollars ($1,000,000) the client will be charged a minimum annual advisory fee of Ten Thousand Dollars ($10,000). • Discretionary Policy: ITEM 16: Investment Discretion We use Nitrogen account linking specifically to determine risk tolerance for discretionary management. In the future, any material changes made during the year will be reported here. From time to time, we may amend this Brochure to reflect changes in our business practices, changes in regulations, and routine annual updates as required by securities regulators. Either this complete Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Peak Financial Planning. 2  Item 3: Table of Contents Contents 1 2 Item 1: Cover Page 3 Item 2: Material Changes 4 Item 3: Table of Contents 6 Item 4: Advisory Business 9 Item 5: Fees and Compensation 9 Item 6: Performance-Based Fees and Side-By-Side Management 9 Item 7: Types of Clients 12 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 12 Item 9: Disciplinary Information 13 Item 10: Other Financial Industry Activities and Affiliations 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 16 Item 12: Brokerage Practices 16 Item 13: Review of Accounts 17 Item 14: Client Referrals and Other Compensation 17 Item 15: Custody 17 Item 16: Investment Discretion Item 18: Financial Information 3  Description of Advisory Firm Item 4: Advisory Business Peak Financial Planning (hereinafter referred to as “PFP”, “we”, “firm”, and “us”) is registered as an Investment Adviser with the Securities and Exchange Commission (“SEC”). We were founded in October 2021. As of January 2026, Peak Financial Planning Holdco is the principal owner of PFP. Eric Amzalag is the Types of Advisory Services principal owner of Peak Financial Planning Holdco and is the Chief Compliance Officer of PFP. Investment Management Services We are in the business of managing individually tailored investment portfolios. Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable Financial Planning Services restrictions on investing in certain securities, types of securities, or industry sectors. Financial planning involves an evaluation of a Client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. ● Business Planning: In general, the financial plan will address some or all of the following areas of concern. The Client and PFP will work together to select specific areas to cover. These areas may include, but are not limited to, the following: ● Cash Flow and Debt Management We provide consulting services for Clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. ● College Savings : We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. : Includes projecting the amount that will be needed to achieve college or other post- secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial 4  ● Employee Benefits Optimization picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate). ● Estate Planning : We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. ● Financial Goals : This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. ● : We will help Clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much Investment Analysis time you will need to reach the goal, and how much you should budget for your goal. ● Retirement Planning : This may involve developing an asset allocation strategy to meet Clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. : Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). ● Risk Management: If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. ● Tax Planning Strategies: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self- insuring”). Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. 5  Financial Planning Services are offered on an Comprehensive engagement. Comprehensive Financial Planning This service involves working one-on-one with a planner over an extended period of time. By paying a fixed monthly fee, Clients get to work with a planner who will work with them to develop and implement their plan. The planner will monitor the plan, recommend any changes and ensure the plan is up to date. Upon engaging us for financial planning, a Client will be taken through establishing their goals and values around money. They will be required to provide information to help complete the following areas of analysis: net worth, cash flow, credit scores/reports, employee benefit, retirement planning, investments, college planning, and estate planning. Once the Client's information is reviewed, their plan will be built and analyzed, and then the findings, analysis and potential changes to their current situation will be reviewed with the Client. Clients subscribing to this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. If a follow- up meeting is required, we will meet at the Client's convenience. The plan and the Client's financial situation and goals will be monitored throughout the year and follow-up phone calls and emails will be made to the Client Tailored Services and Client Imposed Restrictions Client to confirm that any agreed upon action steps have been carried out. We consult with clients initially and through the duration of their engagement with us, to determine risk tolerance, time horizon and other factors that may impact on the clients’ investment and/or planning needs. We ensure that clients’ investment and planning recommendations are suitable for their needs, goals, objectives, and risk tolerance. Clients are able to specify, within reason, any limitations they would like to place on discretionary authority as it pertains to individual securities and/or sectors that will be traded in their account. All such requests Wrap Fee Programs must be provided to PFP in writing. PFP will notify Clients if they are unable to accommodate any requests. Assets under Management We do not participate in wrap fee programs. PFP currently reports $93,000,000 in discretionary and $0 in non-discretionary Assets Under Management. CCR Section 260.235.2 Disclosure Assets Under Management were calculated as of February 2025. For Clients who receive our Financial Planning services, we must state when a conflict exists between the interests of our firm and the interests of our Client. The Client is under no obligation to act upon our recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through our firm. Item 5: Fees and Compensation Please note, unless a client has received this brochure at least 48 hours prior to signing an investment advisory and/or a Financial Planning Agreement (collectively, “Client Contract”), the Client Contract may be terminated by the Client within five (5) business days of signing the Client Contract without incurring any fees. How we are paid depends on the type of advisory services we provide. Below is a brief description of our fees, however, you should review your executed Client Contract for more detailed information regarding 6 the exact fees you will be paying.  Investment Management Services Annual Advisory Fee Our standard advisory fee is based on the market value of the assets under management and is calculated as follows: Account Value $0 - $999,999.99 $1,000,000 - $1,999,999.99 0.85% 1.00%* 0.75% $2,000,000 - $4,999,999.99 $5,000,000 and above 0.5% * Minimum Annual Fee. If Client’s assets under management with the Advisor are less than One Million Dollars ($1,000,000), Client will be charged a minimum annual advisory fee of Ten Thousand Dollars ($10,000), in lieu of the fee that would otherwise be calculated under the tiered fee schedule above. The minimum annual fee will be billed monthly in arrears at a rate of $833.33 per month and is not prorated based on account value. Beginning with the first billing period after Client’s assets under management with the Advisor reach or exceed One Million Dollars ($1,000,000), Client’s advisory fee will be calculated under the tiered fee schedule above rather than the minimum annual fee. If Client’s assets under management subsequently fall below $1,000,000, the minimum annual fee will resume beginning with the next billing period, except where the decline in assets results from Client-directed withdrawals or market depreciation occurring during an active billing period, in which case the fee in effect at the start of that billing period will continue through its end. Client acknowledges that the minimum annual fee may, depending on Client’s assets under management, represent a higher effective percentage of assets than the tiered fee schedule would otherwise produce, and that advisory services may be available from other firms at a lower cost. Client has had the opportunity to review alternative fee arrangements and agrees that the minimum annual fee is reasonable in light of the services to be provided. The annual fees are negotiable and are prorated and paid in arrears on a monthly basis. The advisory fee is a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the account value as of the last day of the previous month. We calculate period-end account values after all dividends settle in the account, therefore, the account value used to calculate advisory fees may differ from that of the custodial account statement. For clients that custody their funds at Altruist Financial LLC, the fees will be calculated on a monthly ending balance and charged on a monthly basis for the prior month. Our billing invoice will indicate the total account value used to calculate the advisory fee. No increase in the annual fee shall be effective without agreement from the Client by signing a new agreement or amendment to their current advisory agreement. Advisory fees are directly debited from Client accounts, or the Client may choose to pay by check. Accounts initiated or terminated during a calendar month will be charged a prorated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 30 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the account. Financial Planning Services 7  • Comprehensive Financial Planning • Payment and Refund of Planning Deposits The initial Comprehensive Financial Planning fee is for the development and delivery of the financial plan. The engagement is 4 months in duration and consists of an upfront charge of $4,000 and monthly fee that is paid in advance at the rate of $1,000 per month. At no time do we require prepayment of fees 6 or more months in advance of delivering the requested services. Fees for this service may be paid by electronic funds transfer or credit card. This service may be terminated with 30 days’ notice. Fees will be refunded in full if client is unhappy with the results of the financial plan To begin a financial planning engagement, clients are required to pay an initial deposit of $4,000. This deposit is subject to specific refund and forfeiture policies based on the client’s participation in the onboarding process: ○ Onboarding Requirements: To ensure timely delivery of services, clients must reach "Onboarding Complete" status within 21 days of starting the engagement. This includes providing all requested documents, expense worksheets, goals questionnaires, and linking accounts via Nitrogen. ○ Refund Eligibility: Our "Satisfaction Guarantee" and any subsequent refund of the initial deposit are strictly contingent upon the client completing the onboarding requirements within the 21-day window. Failure to complete onboarding within this timeframe results in the forfeiture of the deposit. ○ Meeting Rescheduling & Cancellation: We manage our planning services based on a fixed monthly capacity. Because a rescheduled meeting displaces our ability to serve other clients, we allow only one (1) reschedule of the Plan Proposal meeting. ■ If a client reschedules, attempts to reschedule, or fails to attend the Plan Proposal meeting a second time, the engagement will be terminated, and the full deposit will be forfeited as liquidated damages for the loss of planning capacity. ■ If the Firm must reschedule a meeting because the client failed to provide necessary information or complete onboarding, it will be counted as a client-initiated reschedule. • Exceptions to Forfeiture At our sole discretion, we may waive the forfeiture of a deposit or extend onboarding deadlines for significant life events, such as a death in the family, serious illness or injury, natural disasters, or previously disclosed travel plans. All exception requests must be submitted in writing and may require supporting documentation. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for Client’s transactions and determining the reasonableness of their compensation (e.g., commissions). 8  We do not accept compensation for the sale of securities or other investment products including asset-based CCR Section 260.238(j) Disclosure sales charges or service fees from the sale of mutual funds. Please note, lower fees for comparable services may be available from other sources. We do not offer performance-based fees and do not engage in side-by-side management. Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients We provide financial planning and portfolio management services to individuals, high net-worth individuals and corporations or other businesses. We do not have a minimum account size requirement. Modern Portfolio Theory Item 8: Methods of Analysis, Investment Strategies and Risk of Loss • The underlying principles of MPT are: • Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. • Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. • The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. • Investing for the long term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Strategic Asset Allocation Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. In addition to MPT, Strategic Asset Allocation is a focus of our investment strategy. In the portfolio construction process, we focus not only on asset classes such as equities, fixed income, and cash, but also on investment strategy styles such as fundamental, quantitative, active, and passive. We believe that diversification across both asset classes and investment strategies is critical for achieving an attractive reward-to-risk ratio in the portfolio. We employ both strategic and tactical asset allocation approaches. 9  Through strategic asset allocation, we construct our long-term target weights for asset classes and strategies based on the client’s time horizon, risk tolerance, and required rate of return to meet his or her financial goals. Through tactical asset allocation approaches, we may deviate from target long-term weights established according to our strategic asset allocation approach within tolerance ranges based on our return Short-Term Strategy expectations for asset classes and investment strategies at a given point in the market cycle. A short-term strategy involves the purchase of securities with the idea of selling them within a relatively short time, typically a year or less. This strategy is done in an attempt to take advantage of conditions that Hedging Strategy result in market fluctuations in the securities purchased. A hedging strategy uses certain instruments such as options and certain ETFs to limit or reduce investment risk; however, this strategy can also be expected to limit or reduce the potential for profit or result in losses. Certain hedging transactions can involve the use of leverage, which could result in losses exceeding the Material Risks Involved amount committed in the transaction. All investing strategies involve risk and may result in a loss of your original investment which you Investing in any securities involves risk and may result in a loss of your should be prepared to bear. original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment Market Risk: strategies are listed below. Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the Strategy Risk: issuer’s operations or its financial condition. Small and Medium Cap Company Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the Turnover Risk: Client’s portfolio. At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the Interest Rate Risk: account’s performance. Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these Legal or Legislative Risk price changes. Most other investments are also sensitive to the level and direction of interest rates. : Legislative changes or Court rulings may impact the value of investments, or the Inflation securities’ claim on the issuer’s assets and finances. : Inflation may erode the buying power of your investment portfolio, even if the dollar value of your Short-Term Purchases: investments remains the same. Short-term purchases can incur more trading and brokerage costs in the form of increased commissions and transaction costs and increased tax obligations on the gains of a security’s value. 10  A short-term strategy runs the risk that certain anticipated market movements do not occur, resulting in the Risks Associated with Securities client holding a security for longer than intended. Apart from the general risks outlined above which apply to all types of investments, specific securities may Common stocks have other risks. may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an Exchange Traded Funds adverse effect on the price of all stocks. prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by Mutual Funds the underlying funds in which the Clients invest. : When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying Options: fund (such as the use of derivatives). 1. Market Risk: Before engaging in options trading, it is essential to understand and acknowledge the inherent risks associated with this type of investment. Options are complex financial instruments and trading them involves substantial risk. The following risk disclosure statement is intended to provide you with an overview of the potential risks involved in options trading: 2. Limited Duration: Options derive their value from underlying assets such as stocks, indices, or commodities. The prices of these underlying assets can fluctuate significantly due to various factors, including economic events, geopolitical developments, and market sentiment. As a result, the value of your options contract can rise or fall rapidly, leading to potential losses. 3. Leverage and Magnified Losses: Most options have a finite expiration date. If the option expires worthless or out of the money, you may lose your entire investment, including any premiums paid for the option contract. 4. Volatility Risk: Options trading allows you to control a larger position with a relatively small investment. While leverage can amplify profits, it also magnifies losses. It is crucial to understand that you can lose more than your initial investment when trading options, particularly when using leverage. 5. Intrinsic Value vs. Time Value: Options are sensitive to changes in volatility. An increase in market volatility can lead to higher option premiums but may also increase the likelihood of significant price swings, potentially causing losses if the market moves against your position. Options have two components: intrinsic value (the difference between the option's strike price and the current market price of the underlying asset) and time value (the additional premium attributed to the option's time until expiration). As an option approaches its expiration date, time value diminishes, potentially affecting the option's profitability. 11  6. Complex Strategies: 7. Assignment Risk: Advanced options strategies, such as spreads and combinations, can be intricate and challenging to understand fully. It is crucial to have a comprehensive understanding of these strategies before using them, as they may involve multiple options contracts and complex risk profiles. 8. Liquidity Risk: If you sell options (e.g., writing covered calls or naked puts), you may be subject to assignment, which means you are obligated to fulfill the terms of the contract. Assignment can occur at any time before the option's expiration, potentially leading to unexpected obligations. 9. Regulatory Risks: Some options may have limited trading volume and liquidity, making it challenging to execute orders at desired prices. This lack of liquidity can result in wider bid-ask spreads and potentially higher transaction costs. Options trading is subject to regulatory oversight, and changes in regulations can impact trading rules and margin requirements. It is essential to stay informed about regulatory Risk Tolerance and Investment Goals: changes that may affect your options trading activities. 10. It is imperative to assess your risk tolerance and align your options trading strategies with your investment goals. Diversification and risk management techniques should be integral parts of your trading plan. Criminal or Civil Actions Item 9: Disciplinary Information Administrative Enforcement Proceedings PFP and its management have not been involved in any criminal or civil action. Self-Regulatory Organization Enforcement Proceedings PFP and its management have not been involved in administrative enforcement proceedings. PFP and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of PFP or the integrity of its management, nor have any management persons been subject to any self-regulatory organization (SRO) proceedings. Item 10: Other Financial Industry Activities and Affiliations Neither Peak Financial Planning nor any PFP employee are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither Peak Financial Planning nor any PFP employee are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. Peak Financial Planning does not have any related parties. As a result, we do not have a relationship with any related parties. Peak Financial Planning only receives compensation directly from Clients. We do not receive compensation Recommendations or Selections of Other Investment Advisers from any outside source. We do not have any conflicts of interest with any outside party. PFP does not recommend Clients to Turnkey Asset Management Programs to manage their accounts. 12  Disclosure of Material Conflicts All material conflicts of interest under CCR Section 260.238(k) are disclosed regarding PFP, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an Code of Ethics Description ethical and professionally responsible manner in all professional services and activities. • This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory Clients. A summary of the Code of Ethics' Principles is outlined below. • Integrity - Associated persons shall offer and provide professional services with integrity. • Objectivity - Associated persons shall be objective in providing professional services to Clients. • Competence - Associated persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. • Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. • Confidentiality - Associated persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. • Professionalism - Associated persons' conduct in all matters shall reflect the credit of the profession. Diligence - Associated persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Investment Recommendations Involving a Material Financial Interest and Conflicts of Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Interest Neither our firm, its associates or any related person is authorized to recommend to a Client or effect a transaction for a Client, involving any security in which our firm or a related person has a material financial Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest interest, such as in the capacity as an underwriter, adviser to the issuer, etc. Our firm and its “related persons” do not invest in the same securities, or related securities, e.g., warrants, options or futures, which we recommend to Clients. 13  Trading Securities At/Around the Same Time as Client’s Securities Because our firm and its “related persons” do not invest in the same securities, or related securities, e.g., warrants, options or futures, which we recommend to Clients, we do not trade in securities at or around the same time as Clients. Factors Used to Select Custodians and/or Broker-Dealers Item 12: Brokerage Practices Specific custodian Peak Financial Planning does not have any affiliation with Broker-Dealers. recommendations are made to the Client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. ● In recommending broker-dealers, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the broker-dealer’s services. The factors we consider when evaluating a broker-dealer for best execution include, without limitation, the broker-dealer’s: ● Execution capability; ● Commission rate; ● Financial responsibility; ● Responsiveness and customer service; ● Custodian capabilities; ● Research services/ancillary brokerage services provided; and Any other factors that we consider relevant. With this in consideration, our firm recommends Charles Schwab & Co., Inc. (“Schwab”) or Altruist Financial LLC (“Altruist”), independent and unaffiliated SEC registered broker-dealer firms and members of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Although clients may request us to use a broker-dealer of their choosing, we generally recommend that clients open brokerage accounts with Schwab or Altruist. We are not affiliated with Schwab or Altruist. The Client will ultimately make the final decision of the Custodian to be used to hold the Client’s investments 1. Research and Other Soft-Dollar Benefits by signing the selected broker-dealer’s account opening documentation. Our qualified custodian(s) used for investment management may provide us with certain brokerage and research products and services that qualify as “brokerage or research services” under Section 28(e) of the Securities Exchange Act of 1934 (“Exchange Act”). This is commonly referred to as a “soft dollar” arrangement. These research products and/or services will assist us in our investment decision making process. Such research generally will be used to service all of our client accounts, but brokerage charges paid 2. Brokerage for Client Referrals by the client may be used to pay for research that is not used in managing that specific client’s account. We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third 3. Clients Directing Which Broker/Dealer/Custodian to Use party. 14  We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing Clients to choose a specific custodian, we may be unable to achieve the most favorable execution The Custodian and Brokers We Use (Charles Schwab) of Client transaction, and this may cost Clients money over using a lower-cost custodian. The custodian and brokers we use maintain custody of your assets that we manage, although we may be deemed to have limited custody of your assets due to our ability to withdraw fees from your account (see Your brokerage and custody costs Item 15 – Custody, below). : For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated Products and services available to us from Schwab by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. : Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like us. They provide our clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to Services that benefit you request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: : Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this Services that may not directly benefit you paragraph generally benefit you and your account. : Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: Services that generally benefit only us: • provide access to client account data (such as duplicate trade confirmations and account statements) • facilitate trade execution and allocate aggregated trade orders for multiple client accounts • provide pricing and other market data • facilitate payment of our fees from our clients’ accounts • assist with back-office functions, recordkeeping, and client reporting Schwab also offers other services intended to help us manage and • further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs Publications and conferences on practice management and business succession 15  We do not require that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business and Schwab’s payment for services for which we would otherwise have to pay rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not The Custodian and Brokers We Use (Altruist) Schwab’s services that benefit only us. PFP offers investment advisory services through the custodial platform offered by Altruist Financial LLC (“Altruist”), an unaffiliated SEC registered broker dealer and FINRA/SIPC member. Custody, clearing and execution services are provided by Altruist Financial LLC as a self-clearing broker-dealer. PFP’s clients establish brokerage accounts through Altruist. PFP maintains an institutional relationship with Altruist whereby Altruist provides certain benefits to PFP, including a fully digital account opening process, a variety of available investments, and integration with software tools that can benefit PFP and its clients. PFP is not Aggregating (Block) Trading for Multiple Client Accounts affiliated with Altruist. Altruist does not supervise PFP, its agents, activities, or its regulatory compliance. We attempt to allocate trade executions in the most equitable manner possible, taking into consideration current asset allocation and availability of funds using price averaging, proration, and consistently non- arbitrary methods of allocation. We can aggregate orders in order to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. In aggregated orders, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. Item 13: Review of Accounts Eric Amzalag, Owner and CCO of PFP, and PFP adviser representatives, will work with Clients to obtain current information regarding their assets and investment holdings and will review this information as part of our financial planning services. PFP does not provide specific reports to financial planning Clients, other than financial plans. Client accounts with the Investment Advisory Service will be reviewed regularly on an annual basis by Eric Amzalag, Owner and CCO. The account is reviewed with regards to the Client’s investment policies and risk tolerance levels. Events that may trigger a special review would be unusual performance, addition or deletions of Client imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client's needs. Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. PFP will not provide written reports to Investment Management Clients. Item 14: Client Referrals and Other Compensation Outside of those listed above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Nor do we, directly or indirectly, compensate any person who is not 16 advisory personnel for Client referrals.  PFP does not accept custody of Client funds except in the instance of withdrawing Client fees. Item 15: Custody For Client accounts in which PFP directly debits their advisory fee: i. PFP will send a copy of its invoice to the custodian at the same time that it sends the Client a copy. ii. The custodian will send at least quarterly statements to the Client showing all disbursements for the account, including the amount of the advisory fee. iii. The Client will provide written authorization to PFP, permitting them to be paid directly for their accounts held by the custodian. Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains Client's investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16: Investment Discretion For those Client accounts where we provide Investment Management Services, we maintain discretion over Client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments. However, approval of such requests are at the firm’s sole discretion. Our ability to exercise discretionary authority is contingent upon the timely completion of our onboarding process, including account linking and risk profile completion. Please refer to Item 5 for details on onboarding deadlines and related deposit policies. Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. Item 18: Financial Information Registered Investment Advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to 17  meet contractual and fiduciary commitments to Clients, and we have not been the subject of a bankruptcy proceeding. We do not have custody of Client funds or securities or require or solicit prepayment of more than $500 in fees per Client six months in advance. 18