Overview

Assets Under Management: $130 million
Headquarters: COLORADO SPRINGS, CO
High-Net-Worth Clients: 16
Average Client Assets: $8 million

Services Offered

Services: Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (PEAK INVESTMENT ADVISORS, INC. ADV PART 2A AND PART 2B BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $50,000 1.00%
$10 million $100,000 1.00%
$50 million $500,000 1.00%
$100 million $1,000,000 1.00%

Clients

Number of High-Net-Worth Clients: 16
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 90.40
Average High-Net-Worth Client Assets: $8 million
Total Client Accounts: 173
Discretionary Accounts: 168
Non-Discretionary Accounts: 5

Regulatory Filings

CRD Number: 113967
Last Filing Date: 2024-08-14 00:00:00
Website: https://cs.com

Form ADV Documents

Primary Brochure: PEAK INVESTMENT ADVISORS, INC. ADV PART 2A AND PART 2B BROCHURE (2025-03-20)

View Document Text
Item 1: Cover Page Part 2A and Part 2B of Form ADV: Firm Brochure PEAK INVESTMENT ADVISORS, INC. Registered Investment Advisor 5825 Delmonico Drive, Suite 310 Colorado Springs, CO 80919 (719) 260-6475 (direct office) (719) 260-0660 (fax) O t h e r O f f i c e L o c a t i o n P r i v a t e R e s i d e n c e V e n i c e , F L 3 4 2 9 3 Website: PeakInvestmentAdvisors.com Email: PeakInvestments@cs.com Dated May March, 2025August 2024 This brochure provides information about the qualifications and business practices of Peak Investment Advisors, Inc. If you have any questions about the contents of this brochure, please contact us at (719) 260-6475 and/or peakinvestments@cs.com. The information is this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority, including but not limited to the State of Colorado’s Department of Regulatory Agencies (DORA) and its Division of Securities. Registration with the State of Colorado does not imply a certain level of skill or training. Peak Investment Advisors, Inc.’s CRD number is 113967 and additional information about the firm is also available on the SEC’s website at www.adviserinfo.sec.gov. i MATERIAL CHANGES Peak Investment Advisors has made the following material changes to its Firm Brochure since filing its annual amendment dated March 2024: Item 1 – We added the other office location of the firm   Item 4 – Peak Investment Advisors filed its initial application to become registered as in investment adviser with the U.S. Securities and Exchange Commission in May 2024, which was accepted on July 1, 2024.  Item 4 – If Client is currently receiving asset management services from Peak for an asset management fee, Peak provides consulting services for no additional charge. Item 5 – The fee for financial consulting as a separate service is $300 per hour.   Item 18 - Peak does not require or solicit the prepayment of more than $1,200 in client fees, six months or more in advance. Previously, this amount was $500. We will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time we will also offer or provide a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes as necessary. ii TABLE OF CONTENTS Item 1: Cover Page i. Item 2: Material Changes ii. iii. Item 3: Table of Contents 1. Item 4: Advisory Business Item 5: Fees and Compensation 4. Item 6: Performance-Based Fees and Side-By-Side Management 5. Item 7: Types of Clients 6. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 7. Item 9: Disciplinary Information 8. Item 10: Other Financial Industry Activities and Affiliations 9. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 10. Item 12: Brokerage Practices 12. Item 13: Review of Accounts 16. Item 14: Client Referrals and Other Compensation 17. Item 15: Custody 18. Item 16: Investment Discretion 19. iii TABLE OF CONTENTS (continued) Item 17: Voting Client Securities 20. Item 18: Financial Information 21. Privacy Policy 22. Part 2B of Form ADV: Brochure Supplement Item 1: Cover Page 24. Item 2: Educational Background and Business Experience 25. iv Item 4: Advisory Business Peak Investment Advisors, Inc. (Peak) has been in operation in Colorado since 1993. Peak and its predecessor firm have been in the investment management business since 1988. The firm is primarily owned by Richard A. Mueller, while Lisa A. Mueller owns a minority stake. Peak Investment Advisors, Inc. filed its initial application to become registered as in investment adviser with the U.S. Securities and Exchange Commission in May 2024, which was accepted on July 1, 2024. Peak provides investment advisory and financial consulting services primarily to individuals, families and businesses. Peak may also serve pension funds, banks, trusts, endowments and estates. Tax planning services are also provided to both individuals and small businesses. Investment and tax advisory services are tailored to meet the needs of individual clients, as each client situation is unique with regard to risk tolerances and return objectives. Investment strategies and policies are arrived at after meeting with clients and determining their goals, objectives and risk tolerances. Clients may limit or restrict investing in certain securities or types of securities. If Client is currently receiving asset management services from Peak for an asset management fee, Peak provides consulting services for no additional charge. It will be incumbent upon Client to identify the issues for which you are seeking our advice or consultation on. Retirement Plan Rollover Recommendations When Peak provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that {Investment Adviser Firm} is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way Peak makes money creates conflicts with your interests so Peak operates under a special rule that requires Peak to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Peak must as a fiduciary to a retirement plan account or IRA under ERISA/IRC: 1 • • • • • • Meet a professional standard of care when making investment recommendations (e.g., give prudent advice); Never put the financial interests of Peak ahead of you when making recommendations (e.g., give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that Peak gives advice that is in your best interest; Charge no more than is reasonable for the services of Peak; and Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Peak, please know that Peak and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Peak. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Peak. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Peak receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Peak and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the 2 circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Peak or our affiliated personnel. Client assets under management as of December 31, 2025March 31, 2024, were $139,558,385.0,474,788 Of these assets under management, $103,374,70196,165,831 were managed on a discretionary basis and $36,18,68434,308,957 were managed on a non- discretionary basis. 3 Item 5: Fees and Compensation Management fees are based on a percentage of assets under management. Annual management fees are typically 1.0% of assets, but may be more or less, depending upon the level of service provided, account size and type of investments. Client accounts are usually managed on a fully discretionary basis. Financial consultation is also available on an hourly basis of $300 or as negotiated. Investment management fees are negotiable. Management fees are calculated quarterly and are due at the end of each calendar quarter. Fees are usually deducted directly from client accounts, although some clients are invoiced and pay from outside their investment accounts. Clients may choose which method they prefer and this option is disclosed in the client contract letter. Regardless of which method is used, clients receive a bill/invoice quarterly that shows how the fee is calculated and whether it will be deducted from their account or is due and payable directly from the client. Clients incur fees other than investment management fees, such as brokerage fees (see Item/Section 12) and fees imbedded in mutual funds or Exchange Traded Funds (ETF’s). Peak attempts to minimize both brokerage fees (by using only discount brokers; such as Charles Schwab & Co.) and mutual fund/ETF fees by choosing no load funds and ETF’s with low internal management fees. Clients are never required to pay any investment management fees in advance. Nor does anyone at Peak accept compensation for the sale of securities or other investment products. This policy is in contrast to many individuals that work for large brokerage firms and insurance companies who are often compensated based on the sale of securities or investment products such as mutual funds, annuities and life insurance policies. 4 Item 6: Performance-Based Fees and Side-by-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because Peak does not charge or accept performance-based fees. 5 Item 7: Types of Clients Peak provides investment advisory, financial consulting and tax planning services primarily to individuals, families and businesses. Peak may also serve pension funds, banks, trust, endowments and estates. Minimum client group size is typically $500,000 although smaller accounts may be considered if the client relationship is likely to lead to larger account balances in the future. 6 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Peak gives investment advice on many types of securities, ranging from government and corporate bonds, common and preferred stocks to commodities. Peak relies on both internal and external investment research from sources such as financial publications, SEC filings, corporate interviews/inspections, company publications and corporate rating services, as well as online services such as Yahoo Finance, etc. Peak’s overall investment strategy is designed to maximize long-term returns with the least amount of risk. However, investment strategies are varied, depending upon client suitability and the risk/reward desires of individual clients. Investing in securities involves risk of loss that all clients need to be aware of and be willing to bear such risk. Investing in individual company securities, whether stocks or bonds, is limited within individual portfolios to minimize the risk of permanent loss. Diversification is used as an important risk reduction tool. Peak utilizes highly diversified mutual funds and Exchange Traded Funds (ETF’s) to further mitigate portfolio risk. 7 Item 9: Disciplinary Information In 2019 Peak underwent a periodic examination by the Colorado Division of Securities (the “Division”). No investor complaints or concerns triggered this exam; it was a result of the Division’s ongoing mandate to periodically exam all registered investment advisors that do business in the state of Colorado. As a result of this exam, a Deficiency Letter was generated that outlined issues and concerns that the Division identified with regard to Peak’s operations and compliance with state and federal regulatory requirements. Deficiency Letters are normally generated as a result of these exams by the Division. The Deficiency Letter outlined matters that Peak needs to address to bring it back into compliance with related regulatory requirements. In addition to the Deficiency Letter, Peak entered into a Stipulation For Consent Order. This Order outlined specific steps and requirements that the Firm must take in order to restore full compliance with regulatory requirements as outlined in the Deficiency Letter. Peak actively worked to comply with this Order and addressed the issues highlighted in the Deficiency Letter. In 2022, the Colorado Division of Securities conducted a follow up examination of Peak. After supplying the Division with the requested information, the Division stated that Peak had fully complied with the requirements of the Consent Order. Consequently, the State of Colorado Licensing Order (referred to above as Consent Order) entered into during November, 2019 has expired effective November, 2021. No further action is required related to this Order, other than complying with related state and federal regulatory requirements. 8 Item 10: Other Financial Industry Activities and Affiliations Peak is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, a lawyer or law firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. Peak is an independent registered investment adviser and only provides investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. Accounting Services Richard A. Mueller, an owner and Chief Compliance Officer of Peak Investment Advisors, is a licensed CPA. Clients needing assistance with tax preparation and/or account services may be referred to him but are not obligated to use his services. When advisory clients are referred to Richard A. Mueller, our investment adviser he will receive customary compensation for the tax services provided as a CPA. This creates a conflict of interest which is mitigated by our investment adviser representative always acting in the clients’ best interest. This conflict is disclosed to advisory clients and clients are never obligated to use the tax services of Richard A. Mueller. 9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Summary An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Peak has established a Code of Ethics to comply with the requirements of the securities laws and regulations that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. Peak’s Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment adviser representatives are classified as supervised persons. Peak requires its supervised persons to consistently act in your best interest in all advisory activities. Peak imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. This section is intended to provide a summary description of the Code of Ethics of Peak. If you wish to review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your request, we will promptly provide a copy of the Code of Ethics to you. Affiliate and Employee Personal Securities Transactions Disclosure Peak or supervised persons of the firm buy and sell for their personal accounts, investment products identical to those recommended to clients. This creates a conflict of interest. It is the express policy of Peak that all persons associated in any manner with our firm must place clients’ interests ahead of their own when implementing personal investments. As is required by our internal procedures, Peak and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. We are now and will continue to be in compliance with applicable state and federal rules and regulations. To mitigate conflicts of interest that can occur when access persons manage their personal accounts at the same time Peak manages client accounts, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, supervised persons):  Supervised persons cannot prefer their own interests to that of the client. 10  Supervised persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts.  Supervised persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment, unless that information is also available to the investing public upon reasonable inquiry.  Supervised persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”.  Supervised persons are discouraged from conducting frequent personal trading.  Supervised persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted to the Chief Compliance Officer of Peak. Any Supervised person not observing our policies is subject to sanctions up to and including termination. 11 Item 12: Brokerage Practices We exercise reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back-office services, technology and pricing of services offered. If Peak assists in the implementation of any recommendations, we are responsible to ensure that the client receives the best execution possible. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, we look at a number of factors besides prices and rates including, but not limited to:  Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with our existing systems, ease of monitoring investments)  Products and services offered (e.g., investment programs, back-office services, technology, regulatory compliance assistance, research and analytic services)  Financial strength, stability and responsibility  Reputation and integrity  Ability to maintain confidentiality Brokerage Recommendations Peak recommends that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc (“Schwab”), a FINRA-registered broker-dealer, Member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although Peak recommends clients establish accounts at Schwab, it is the client’s decision to custody assets with Schwab. Peak is independently owned and operated and not affiliated with Schwab. Schwab provides Peak with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as clients’ assets are maintained at Schwab Institutional. These services are not contingent upon Peak committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require significantly higher minimum initial investment. Schwab Institutional also makes available to Peak other products are services that benefit 12 Peak but may not directly benefit clients’ accounts. Many of these products and services may be used to service all or some substantial number of Peak’ accounts, including accounts not maintained Schwab. Schwab’s products and services that assist Peak in managing and administering clients’ accounts include software and other technology that (i) (ii) (iii) (iv) (v) provides access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of Peak’s fees from some of its accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Institutional also offers other services intended to help Peak manage and further develop its business enterprise. These services may include: (i) (ii) (iii) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or part of the fees of a third-party providing these services to Peak. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of Peak personnel. While as a fiduciary, Peak endeavors to act in its clients’ best interests, Peak’s recommendation that clients maintain their assets in accounts at Schwab may take into account availability of some of the foregoing products and services and other arrangements not solely on the nature of cost or quality of custody and brokerage services provided by Schwab, which may create a conflict of interest. Directed Brokerage Clients are allowed to select the broker-dealer that will be used for their accounts. Clients directing the use of a particular broker/dealer or other custodian must understand that Peak may not be able to obtain the best prices and execution for the transaction. Under a client-directed brokerage arrangement, clients may receive less favorable prices than would otherwise be the case if the client had not designated a particular broker/dealer or custodian. Directed brokerage account trades are generally placed by Peak after effecting trades for other clients of Peak. In the event that a client directs 13 Peak to use a particular broker or dealer, Peak may not be authorized to negotiate commissions and may be unable to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct Peak to use a particular broker or dealer versus clients who do not direct the use of a particular broker or dealer. Soft Dollar Benefits An investment adviser receives soft dollar benefits from a broker-dealer when the investment adviser receives research or other products and services in exchange for client securities transactions or maintaining an account balance with the broker-dealer. Peak utilizes the services of Charles Schwab & Co., Inc. While there is no direct linkage between the investment advice given to clients and Peak’s participation in the Charles Schwab & Co., Inc. program, economic benefits are received by Peak which would not be received if we did not give investment advice to clients. These benefits may be used for both research and non-research purposes and allows us to supplement, at no cost, our own research and analysis activities. These benefits include: a dedicated trade desk that services the program participants exclusively, a dedicated service group and an account services manager dedicated to Peak’s accounts, access to a real-time order matching system, the ability to “block” clients’ trades, electronic download of trades, balances and position information, duplicate and batched client statements, confirmations, year-end summaries, the ability to have advisory fees directly debited from client accounts (in accordance with federal and state requirements), availability of third-party research and technology, a quarterly newsletter, access to mutual funds, and . The benefits received through participation in the Charles Schwab & Co., Inc. program do not depend upon the amount of transactions directed to or amount of assets managed through Charles Schwab & Co., Inc. Research obtained with soft dollars is not necessarily utilized for the specific account that generated the soft dollars. We do not attempt to allocate the relative costs or benefits of research among clients because we believe that, in the aggregate, the research we receive benefits all clients and assists us in fulfilling our overall duty to you. These arrangements are deemed to create a conflict of interest to the extent that we would have to pay for some or all of the research and/or services with “hard dollars” if we were unable to obtain the research and services in exchange for commissions in connection with client transactions. Client trades are always implemented based on the 14 goals and objectives of the client and not on any research, products or other incentives available. Block Trading Policy Investment advisors may elect to purchase or sell the same securities for several clients at approximately the same time when they believe such action may prove advantageous to clients. This process is referred to as aggregating orders, batch trading or block trading. Peak does not engage in block trading. It should be noted that implementing trades on a block or aggregate basis may be less expensive for client accounts; however, it is our trading policy to implement all client orders on an individual basis. Therefore, we do not aggregate or “block” client transactions. 15 Item 13: Review of Accounts All client accounts are periodically review by Mr. Mueller, at least on a quarterly basis. Such review involves comparing the portfolio to those goals and objectives established by both Peak and the client. Any changes, if needed, are made as a result of these reviews. Peak provides a written Portfolio Statement to each and every client at the end of each calendar quarter. In addition, written investment performance reports are provided to clients on a quarterly basis, showing the portfolio’s investment performance as compared to relevant and predetermined benchmarks. 16 Item 14: Client Referrals and Other Compensation Peak does not receive any compensation for providing investment advice, other than that received directly from clients. In addition, neither Peak nor any related persons provide compensation to any person or entity for client investment advisory referrals. 17 Item 15: Custody Since Peak deducts client investment management fees directly from client accounts, the firm is deemed to have constructive custody of those assets. In order to address this custody issue the firm does the following: 1. Peak secures written authorization from the client prior to deducting fees from their account. 2. The custodian sends portfolio statements directly to the client, showing the fee deduction from their account. 3. Peak sends a written invoice to the client showing how the fee was calculated and that it was going to be deducted from the client’s account. Clients are urged to carefully review statements they receive, both from the broker/custodian and from Peak. In addition, clients should compare these statements to insure that appropriate fee amounts are being deducted from their accounts and that information on the statements are consistent and proper. 18 Item 16: Investment Discretion Peak accepts discretionary authority to manage securities accounts on behalf of most clients. Some clients, while granting discretion, request that some investments not be purchased for their account. For example, some clients prohibit the purchase of investments involved with the tobacco industry. Investment contract letters typically outline the level of discretion Peak will have over that client’s investment accounts. Limitations on investments are usually documented from client interviews and noted in the client’s file at Peak. 19 Item 17: Voting Client Securities Peak does not accept authority to vote client securities on behalf of the client. Clients are responsible for voting on all securities held in their account. The custodian forwards proxies and other solicitations directly to the client, as required by law. Clients can contact Peak with any questions about a particular solicitation, either by phone, letter or email. 20 Item 18: Financial Information Peak does not require or solicit the prepayment of more than $1,200 in client fees, six months or more in advance. Peak does not have any financial condition that is reasonably likely to impair the firm’s ability to meet the contractual commitments to clients. Peak has not been the subject of a bankruptcy petition at any time, including the last 10 years. 21 Item 19: Requirements for State-Registered Advisers Richard A. Mueller is the only individual authorized to provide investment advisory services on behalf of Peak. Mr. Mueller was born in 1961 and has a BA in Accountancy from the University of Illinois and an MBA from the University of Chicago. He has been employed in the investment research and management business since 1986 and is both a CPA (1983) and CFA (1989). As required by many state securities regulations, he has passed the NASD Series 65 exam (1994). PRIVACY POLICY Commitment to Your Private Information: Peak has a policy of protecting the confidentiality and security information we collect about our clients. We do not, and will not, share nonpublic personal information about you (“Information”) with outside third parties without your consent, except for the specific purposes described below. This notice has been provided to you to describe the Information we may gather and the situations under which we may need to share it. Why We Collect and How We Use Information. We limit the collection and use of Information within our firm to only those individuals associated or employed with us that must have Information to provide financial services to you. Such services include maintaining your accounts, processing transaction requests, providing financial consultations, and other services described in our Form ADV. How We Gather Information. We get most Information directly from you when you provide us with information from any of the following sources:  Applications or forms (for example: name, address, social security number, birth date, assets, income, financial history)  Transactional activity in your account (for example: trading history and account  balances) Information services and consumer reporting sources (for example: to verify your identity or to assess your credit history)  Other sources with your consent (for example: your insurance professional, attorney, or accountant) How We Protect Information. Our employees and affiliated persons are required to protect the confidentiality of Information and to comply with our stated policies. They may access Information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services. Employees who violate our Privacy Policy are subject to disciplinary action, up to and including termination from employment with us. We also maintain physical, electronic, and procedural safeguards to protect information, which comply with applicable SEC, state, and federal laws. 22 Sharing Information with Other Companies Permitted Under Law. We do not disclose Information obtained in the course of our practice except as required or permitted under law. Permitted disclosures include, for instance, providing information to unrelated third parties who need to know such Information in order to assist us with providing services to you. Unrelated third parties may include broker/dealers, mutual fund companies, insurance companies, and the custodian with which your assets are held. In such situations, we stress the confidential nature of information being shared. Former Customers. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your nonpublic information with strict confidentiality. 23 Item 1: Cover Page Part 2B of Form ADV: Brochure Supplement Richard A. Mueller 5825 Delmonico Drive, Suite 310 Colorado Springs, CO 80919 (719) 260-6475 Peak Investment Advisors, Inc. 5825 Delmonico Drive, Suite 310 Colorado Springs, CO 80919 (719) 260-6475 Other office Location Private Residence Venice, FL 34293 May July March 2025August 2024 This brochure supplement provides information about Richard A. Mueller that supplements the Peak Investment Advisors, Inc. brochure. You should have received a copy of that brochure. Please contact Mr. Mueller if you did not receive Peak Investment Advisors’ brochure or if you have any questions about the contents of this supplement. Additional information about Richard A. Mueller is available on the SEC’s website at www.adviserinfo.sec.gov. 24 Item 2: Educational Background and Business Experience Since Richard A. Mueller is the only individual currently authorized to provide investment advisory services on behalf of Peak Investment Advisors, Inc., all the information required to be included in this Brochure Supplement is provided in Part 2A above and such information is hereby incorporated by reference. This Brochure is a combined filing of Part 2A and 2B of Form ADV. 25