Petersen Hastings Wealth Advisors, Inc.

Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Item 1 – Cover Page Petersen Hastings Wealth Advisors, Inc. 8203 West Quinault Avenue, Suite 101 Kennewick, WA 99336 (509) 735-0484 www.PetersenHastings.com April 27, 2026 This Brochure provides information about the qualifications and business practices of Petersen Hastings Wealth Advisors, Inc. “Petersen Hastings.” If you have any questions about the contents of this Brochure, please contact us at (509) 735-0484 and/or Info@PetersenHastings.com. 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. Petersen Hastings registered with the SEC as an investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications we provide is for you to determine whether to hire or retain Petersen Hastings as your investment adviser. information about Petersen Hastings also is available on the SEC’s website at Additional www.adviserinfo.sec.gov.  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Item 2 – Material Changes This Brochure is required to be updated at least annually or sooner when material changes to our business take place. In this regard, each year we will deliver to you, by no later than April 30th, either (i) a free updated Brochure that includes a summary of material changes to our business, or (ii) a summary of material changes accompanied by our offer to provide a free copy of our updated Brochure and directions regarding how you may obtain it. Since the most recent Annual Amendment to this Brochure, dated March 26, 2026, the following changes have been incorporated: • Items 4, 5, 7, 8, 10, 12, 16, and 17 to discuss allocations to separately managed account programs and third-party investment managers, and related details on fee practices, account and fee minimums, risks, conflicts of interest, brokerage and best execution practices, and proxy voting practices. You may request a free copy of our updated Brochure by contacting Diane Gaines, Chief Compliance Officer at (509) 735-0484 or Info@PetersenHastings.com. This Brochure is also available on our web site www.PetersenHastings.com, free of charge. information about Petersen Hastings is available via the SEC’s web Additional site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Petersen Hastings who are registered as investment adviser representatives of our firm. 2  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure 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 ................................................................................................... 4 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 7 Item 7 – Types of Clients ................................................................................................................ 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 7 Item 9 – Disciplinary Information ................................................................................................. 10 Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 10 Item 11 – Code of Ethics ............................................................................................................... 11 Item 12 – Brokerage Practices ...................................................................................................... 11 Item 13 – Review of Accounts ...................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ................................................................... 14 Item 15 – Custody ......................................................................................................................... 15 Item 16 – Investment Discretion .................................................................................................. 15 Item 17 – Voting Client Securities ................................................................................................ 16 Item 18 – Financial Information ................................................................................................... 16 3  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Item 4 – Advisory Business Firm Description Petersen Hastings Wealth Advisors, Inc. (“Petersen Hastings,” “we,” “us,” “our”) was incorporated in 1962. We began managing investments for Qualified Retirement Plans in 1976 and registered with the SEC as an investment adviser in 1983. Principal Owners The principal owners are Blaine A. Carr and Matthew J. Petersen. Types of Advisory Services Petersen Hastings provides investment management services on a fee-only discretionary basis to individuals, pension and profit-sharing plans, trusts, charitable organizations, and other institutions. In addition to investment management, we offer investment consultation, financial planning, retirement plan consulting services, and trust administration services. investment portfolio recommendations by taking We develop personalized into account your personal circumstances, long-term goals, assets, financial objectives, time horizon, and risk tolerance. When we select investments for your portfolio, safety of principal and an adequate return are important considerations, in addition to transaction fees, expense ratios, management style, and investment philosophy of the investment. Clients may impose reasonable restrictions on our management of their accounts. For early investors or clients who do not have at least $50,000 in assets designated for management, we offer “Managed Accounts Without Financial Planning” for customized investment management services through a digital platform. Our discretionary management authority includes the authority to allocate some or all of a client’s investment assets to one or more separately managed programs or third-party investment managers, depending on the client’s circumstances and objectives. If your assets are allocated to one or more outside managers, the retained manager(s) will have day-to-day discretionary management responsibility over the allocated assets, and we will provide regular and continuous monitoring of the retained manager(s). To the extent applicable, and unless otherwise disclosed, fees charged by separately managed account programs and third-party investment managers are separate from, and in addition to, the fees charged by Petersen Hastings. For participant-directed retirement plans, we can also be engaged to assist with the selection of an investment lineup, qualified default investment alternative options, the preparation or maintenance of the plan’s investment policy statement, and the provision of personalized advice to plan participants. We can also make risk-based investment models available for participant allocation, which are comprised of various investment managers and vehicles and are managed by us on a discretionary basis. The specific scope of services to be provided will be agreed upon with the plan sponsor prior to the commencement of services. Retirement plan services are provided in our capacity as a fiduciary (as defined under Section 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”)) and/or investment manager (as defined under Section 3(38) of ERISA), as indicated in our agreement with the plan. Assets Under Management As of December 31, 2025, Petersen Hastings had $1,576,834,456 in client assets under management on a discretionary basis. Item 5 – Fees and Compensation The specific manner in which fees are assessed is established in our Investment Advisory Agreement with you. Fee Schedule 4  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Petersen Hastings provides investment management services, according to the following account categories, for a fee calculated as a percentage of account assets under management. Managed Accounts with Financial Planning Portfolio Value Quarterly Rate 0.3000% Annualized Rate 1.20% First $500,000 Next $1,500,000 0.2000% 0.80% Next $3,000,000 0.1500% 0.60% Next $15,000,000 0.1000% 0.40% Next $30,000,000 0.0750% 0.30% Above $50,000,000 0.0500% 0.20% Minimum Fee $500.00 $2,000.00 Managed Accounts without Financial Planning Portfolio Value Above $5.00 Monthly Rate 0.0417% Annualized Rate 0.50% Minimum Fee $1.00 $12.00 Unless otherwise agreed, in writing, the Managed Accounts without Financial Planning fee arrangement is generally only made available with respect to investment assets managed through our GrowWealth Digital Strategies program. Managed Accounts Flat Rate with Financial Planning Portfolio Value Above $25,000.00 Monthly Rate $350.00 Annualized Rate $4,200.00 Unless otherwise agreed, in writing, the Managed Accounts Flat Rate with Financial Planning fee arrangement is generally only made available with respect to investment assets maintained through TIAA CREF and for which we are unable to directly debit our fee. Retirement Plan and Charitable Foundation Accounts Portfolio Value First $5,000,000 Quarterly Rate 0.2000% Annualized Rate 0.80% Next $5,000,000 0.1000% 0.40% Next $40,000,000 0.0750% 0.30% Next $50,000,000 0.0500% 0.20% Above $100,000,000 0.0375% 0.15% Minimum Fee $250.00 $1,000.00 5  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Hourly Rates Periodically, for advisory situations when time and resources cannot be clearly determined upfront, an hourly fee arrangement may be available. The hourly rates are $400 for advisors and $250 for staff. Hourly charges will continue only for necessary work beyond the initial notification date. Fee Billing Our investment fees typically are based upon market values of all managed assets in your account(s) on the last day of each calendar month (for Managed Accounts without Financial Planning) or quarter (for all other accounts). Fees are billed monthly or quarterly, as applicable, and payable in advance for the applicable time period of services rendered. Management fees shall not be pro-rated for each capital contribution and withdrawal made during the applicable calendar month or quarter. You may elect to have our fees billed directly or authorize us to directly debit this fee from your account(s). If there is no ready market for an asset that is under our management, rendering it illiquid, then said asset with be excluded from our management fee. By excluding this asset from our management fee, the assigned value will be reliant on the issuer. Clients will receive a statement from their custodian at least quarterly indicating all transactions in their accounts, including the deduction of our advisory fee. Clients are encouraged to carefully review the advisory fee deducted from their accounts, as the custodian will not, and to report any issues promptly. Our fees may be negotiated in certain circumstances. Clients are advised that the fee practices of separately managed account programs and third-party investment managers, including with respect to fee timing, frequency, valuation, payment, and calculation methodology, may differ from the practices of Petersen Hastings and shall apply to any assets allocated to such outside manager(s). The specific fee practices of a retained outside manager will be disclosed to the client prior to or at the time of allocation, through delivery of the outside manager’s Form ADV Part 2A or similar disclosure document. Other Fees Broker-dealers / custodians charge transaction fees for executing certain securities transactions according to their fee schedule and they or their affiliated or unaffiliated custodians may impose additional charges for custodial services and other fees associated with maintaining the client’s account. The amount of the commissions, transaction fees and custodial fees may vary depending upon the following factors: the broker-dealer/custodian utilized; the amount of assets under management or custodied; the type of asset (e.g., equity, ETF, mutual fund, fixed income product); and whether clients receive their account statements electronically or by hard copy. Our fees are exclusive of brokerage commissions, transaction fees, and other investment related costs and expenses. Some of these additional costs are described below. Please contact us for information about specific fee amounts charged by the financial institutions listed below. LPL Financial – Beginning January 1, 2028 or later LPL Financial charges Petersen Hastings’ clients a quarterly “Custody Platform Fee” that is based on quarter end balances for that prior quarter. This Custody Platform fee compensates LPL Financial for all applicable transaction, maintenance, conversion, technology, service, and other applicable custodial fees. However, clients will still incur fees on a per-transaction basis for the following specific, and commonly unanticipated items that are assessed according to LPL Financials’ fee schedule with the client: Alternative Assets, Physical Certificates, Restricted Securities, Corporate Actions, Overnight Mail, Legal Transfer, Outgoing Transfer, Stop Payment, Wire, IRA/QRP & 403b Termination, QRP & 403b Loan Processing, 990-T filing, 1099R for Pooled QRPs, or other fees from time to time, as applicable. Matrix Trust Company – Matrix Trust Company charges an annual asset based fee, subject to a minimum annual fee, to cover all mutual fund trades. This rate can be adjusted downward in some circumstances. Alerus Financial, N.A. – Alerus charges an annual asset based fee, subject to a minimum annual fee, to cover its services as a custodian and record keeper including mutual fund trading. This rate can be adjusted downward in some circumstances. Charles Schwab – Charges a percentage fee, with maximum, per mutual fund trade. For equity securities, Charles Schwab charges a flat fee per transaction. Charles Schwab Institutional funds trade at no cost. Bonds at Charles 6  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Schwab receive wholesale pricing if purchased through BAM and are subject to an additional “trade away” or “prime brokerage fee” if bond transactions for bonds custodied at Charles Schwab are executed through broker-dealers other than Charles Schwab on a per transaction basis. National Advisors Trust Company – National Advisors Trust Company charges an annual tiered asset-based fee. Additional transaction costs are charged to cover all mutual fund trades. You may also incur certain other charges imposed by custodians, brokers, third party investments and other third parties, including managerial fees, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, trade away / prime brokerage fees, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange-traded funds (“ETFs”) also charge their own fees and expenses, which are disclosed in the applicable fund’s prospectus. Any assets allocated to separately managed account programs or third-party investment managers will incur fees associated with the management services provided by the retained outside manager, in accordance with that manager’s fee practices. All such charges, fees and commissions are in addition to our fee. We do not receive any portion of these commissions, fees, and costs. Termination of the Advisory Agreement For Managed Accounts with Financial Planning, if the Investment Advisory Agreement is terminated and the date of the termination is after the first day of any calendar quarter, the fee for such partial calendar quarter may be pro- rated based on a 90-day quarter and promptly refunded to you. For Managed Accounts without Financial Planning, if the Investment Advisory Agreement is terminated and the date of the termination is after the first day of any calendar month, the fee for such partial calendar month will not be pro-rated and refunded to you. Clients are advised that the termination and refund practices of any retained separately managed account program or third- party investment manager may differ from those of Petersen Hastings, and such outside manager’s termination and refund practices shall apply to any assets allocated to such outside manager(s). Item 6 – Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the client's assets). Item 7 – Types of Clients We provide portfolio management services to individuals, high net worth individuals, corporate pension and profit- sharing plans, charitable organizations, corporations, trusts, and other types of U.S. businesses. We generally require a minimum account size of $50,000 for new clients with financial planning services. There are no such minimum account sizes for new clients without financial planning services. Our minimum account fees are set forth above in Item 5. We may waive account minimums in certain circumstances. Separately managed account programs and third-party investment managers may apply different minimum account size or minimum annual fee requirements, which requirements will apply to any client assets allocated to such outside manager(s). Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Petersen Hastings employs a wide range of methods to manage portfolios and evaluate investments. We use academic research when making investment decisions. We primarily utilize an investment approach based on Modern Portfolio Theory. Modern Portfolio Theory refers to the process of reducing risk in a portfolio through systematic diversification across asset classes and within those particular asset classes. We adhere to the passive style of investing and, thus, recommend indexed and passive mutual funds. We generally do not recommend individual stocks or bonds in our asset allocation strategies and portfolio recommendations to clients. Keeping client’s investment fees, expenses, and taxes under control are a top priority in our investment strategy. 7  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure We analyze mutual funds recommended to clients based on a fund’s total operating expense ratio, portfolio turnover, investment objective, and investment restrictions and limitations. We typically recommend that clients invest in no-load funds, such as those managed by Dimensional Fund Advisors (“DFA”) or Vanguard, that have low operating expenses, low portfolio turnover, below average capital gains distributions, and a fundamental investment objective of investing primarily in a particular asset class. Some DFA funds are available for investment only by clients of registered investment advisers, and all investments are subject to approval of the adviser. This means that you may not be able to make additional investments in DFA funds if you terminate your agreement with us, except through another adviser authorized by DFA. When choosing investments, we analyze the following criteria: • Whether the investment’s performance closely tracks the desired asset classes. • Whether the total internal investment expenses are reasonable (internal expenses include management fees, administrative expense, 12(b)1 fees, transaction, and estimated trading costs). • Whether investment providers have a reasonable experience record, employ a qualified management team, embrace a highly disciplined investment philosophy, provide adequate information, and meet the custodial requirement to trade and hold. • Whether the investment is “no-load.” (We prefer no-load investments over those that charge commissions or sales charges.) We routinely monitor the universe of investment vehicles through our Investment Committee. When alternative or superior investment funds become available, existing investments may be replaced. When appropriate, we may also allocate client assets to one or more separately managed account programs or third- party investment managers. Clients will be provided with the Form ADV Part 2A of any such outside manager, or a similar disclosure document, prior to or at the time of allocation, which disclosure document will describe the outside manager’s various investment methods and strategies, as well as the associated material risks. Clients are encouraged to carefully review these disclosure documents and to bring any questions or concerns to the attention of their Petersen Hastings representative. Principal Investment Strategies Asset allocation models recommended to clients typically are set forth in each client’s Investment Policy Statement. We primarily recommend low-cost mutual funds because they can provide a diversified portfolio that is designed to limit the impact of large fluctuations in values of individual stocks and bonds. Mutual funds do not offer protection from market volatility. At times, different funds may be recommended to improve current client portfolios. Upon the request of a client, we may provide a limited review of client assets for which we do not have discretionary authority in the context of the overall plan. We invest for the long-term and do not engage in market timing. We generally do not recommend individual stocks or bonds, but certain exceptions may be made in cases where the stocks or bonds were obtained before becoming a client or are requested by the client. We monitor individual stock exposure in the overall portfolio. We may give advice and take action with respect to other clients that is different from the advice, timing, and nature of action taken with respect to your account. Timing, allocation, and types of investments are determined as part of each client’s overall financial plan. We believe in diversified asset class exposure obtained primarily through a diversified mix of low-cost mutual funds that represent desired asset classes. The mutual funds and ETFs that we recommend typically invest in some or all of the following types of securities: 8  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Primary Asset Classes Sub-Asset Classes US Large Capitalization Stocks Equity Investments US Small Capitalization Stocks International Large Capitalization Stocks International Small Capitalization Stocks Emerging Market Large Capitalization Stocks Emerging Market Small Capitalization Stocks Real Estate Investment Trusts (“REITs”) Fixed Income Investments US Corporate Bonds US Government Bonds Global Bonds Inflation Protected Bonds Mortgage-Backed Securities Certificates of Deposit Tax-free Municipal Bonds Stable Value Funds Money Markets Principal Risks Investing in securities involves risk of loss that clients should be prepared to bear. Petersen Hastings cannot guarantee that it will achieve a client’s investment objective. Client’s returns will fluctuate, and you may lose money. Below are some more specific risks of investing: • Market Risk. The prices of securities held by mutual funds in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a mutual fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • • • Management Risk. Our investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or fund is not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. 9  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure • • Investment Companies Risk. We recommend open-end mutual funds and ETFs to implement a client’s portfolio. These underlying funds may, in turn, invest in a broad range of equity and fixed income securities, including foreign securities and securities of issuers located in emerging markets. Underlying funds may also invest in equity securities of any market capitalization including micro-, small- and mid-cap companies, real estate, commodities-related assets, fixed income securities of any maturity or credit quality, including high-yield, high-risk debt securities, and they may engage in leveraged or derivative transactions. We have no control over the investment strategies, policies or decisions of the underlying funds and, in the event of dissatisfaction with such a fund, our only option would be to liquidate clients’ investments in that fund. • REIT Risk. To the extent that a client invests in REITs, it is subject to risks generally associated with investing in real estate, such as (i) possible declines in the value of real estate, (ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds, (iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self-liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. REITs lacking a ready market, therefore creating illiquidity, are priced at a value provided by the issuer, and due to this, we do not recommend such illiquid investments. Foreign Securities Risk. Funds in which clients invest may purchase in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. Item 9 – Disciplinary Information Investment advisers are required to disclose all material legal or disciplinary events relevant to your evaluation of our firm or the integrity of our management. We have no information to disclose applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations The Zero Alpha Group In September of 2000, Petersen Hastings became a member/owner of The Zero Alpha Group, LLC (“ZAG”), along with seven other registered investment advisers. ZAG openly advocates a 100% passive investment strategy. Group members share investment information, strategic plans, financial data, marketing brochures, software, and research related to passive investment management. Personal client information is never shared with other ZAG members. ZAG members are geographically dispersed across the globe. Petersen Hastings Private Trust Petersen Hastings Private Trust is a Trust Representative Office of National Advisors Trust Company (NATC), an independent, federally chartered savings bank that provides trust and custodial services. The name “Petersen Hastings Private Trust” is used pursuant to an agreement between Petersen Hastings and National Advisors Trust. To the extent a client determines to retain Petersen Hastings, the client will enter into a separate and distinct agreement with NATC for trust administration, distribution and custodial services and will pay a separate fee for 10  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure such services. Any trust administration fees are in addition to the advisory fees paid for advisory services. Such trust administration fees are paid directly to NATC by the client, and Petersen Hastings does not share in these fees. NATC, one of the largest independent trust companies in the country, is owned by a diversified group of independent registered investment advisers. Dimensional Fund Advisors Petersen Hastings, when appropriate, may allocate some or all of a client’s investment assets to a separately managed account program sponsored and managed by Dimensional Fund Advisors (“DFA”), an unaffiliated registered investment adviser. DFA reduces its annual fee for separately managed account services from 0.29% to 0.23% for advisers who maintain $200 million or more in DFA-managed funds. Although we do not directly benefit from this arrangement, we are nevertheless incentivized to maintain such minimum allocation in DFA-managed funds, based on our interest in receiving discounted separately managed account program fees for our clients. Item 11 – Code of Ethics Code of Ethics We have adopted a Code of Ethics for all our supervised persons pursuant to Section 204A-1 of the Investment Adviser Act of 1940, as amended (the “Advisers Act”). The Code of Ethics includes provisions relating to the confidentiality of client information, prohibition on insider trading, and rumor mongering, restrictions and disclosure on the giving or acceptance of significant gifts, and personal securities trading procedures. Our supervised persons must report certain personal securities transactions and also must review and acknowledge the terms of the Code of Ethics at least annually. You may obtain a copy of our Code of Ethics, free of charge, by contacting Matthew Petersen. Participation or Interest in Client Transactions Petersen Hastings generally does not recommend investments to clients in which Petersen Hastings or any of its principals has a financial interest. Prior to proposing any such investment to a client, Petersen Hastings or its related person shall disclose any participation or interest in the transaction to the client and obtain the approval of Petersen Hastings’ Chief Compliance Officer in advance. No person associated with Petersen Hastings may prefer their own interest to that of an advisory client. Personal Trading Our employees and persons associated with us are subject to our Code of Ethics and must report their personal securities transactions to our Chief Compliance Officer for periodic review to the extent required under the Advisers Act. Our supervised persons may trade securities in their own accounts which are recommended to and/or purchased for clients. In addition, our Code of Ethics requires pre-clearance of many transactions, and restricts trading in close proximity to your trading activity. Petersen Hastings has also adopted an Insider Trading Policy that prohibits its investment advisory representatives from trading on material non-public information. Item 12 – Brokerage Practices Brokerage Recommendations Before engaging Petersen Hastings to provide investment management services, clients enter into an agreement with Petersen Hastings setting forth the terms and conditions for the management of the client’s assets, and a separate custodial/clearing agreement with the client’s designated broker-dealer/custodian. Depending on which broker-dealer/custodian clients select to maintain their account, they may experience differences in customer service, transaction timing, the availability of sweep account vehicles and money market funds, and other aspects of investing that could cause differences in account performance. Commission rates and securities transaction fees charged to place client transactions are established by the independent broker-dealer/custodian. The selection of a broker-dealer/custodian is at your discretion. However, for the reasons described below, Petersen Hastings 11  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure generally recommends investment management accounts be maintained at LPL Financial, an SEC-registered and FINRA/SIPC member broker-dealer and qualified custodian. Clients are advised that assets allocated to separately managed account programs or third-party investment managers will be subject to the brokerage and best execution practices of the outside manager(s), disclosure of which will be provided to the subject client prior to or at the time of allocation. Best Execution When seeking “best execution” from a broker-dealer, the determinative factor is not always the lowest possible cost, but whether the transaction represents the best qualitative execution when considering the full range of a broker-dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Although Petersen Hastings cannot guarantee clients will always experience the best possible execution available, it seeks to recommend a broker-dealer/custodian that will hold client assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. Petersen Hastings considers a wide range of factors when recommending a broker-dealer/custodian, including: • Combination of transaction execution services and asset custody services (generally without separate fees for each service); • Capability to execute, clear and settle trades (buy and sell securities for client accounts) including its use of advanced automation; • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); • Access to low cost, institutional funds and overall breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.); • Quality of services (including research products, responsiveness, reliable and accurate communications, and administrative capability); • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; • Reputation, financial strength, and stability; and • Prior service to Petersen Hastings and its other clients. While we believe LPL Financial’s transaction rates are competitive, transactions may not always be executed at the lowest available commission rate. Lower commissions or better execution may be achieved elsewhere, for example, by executing equity trades through so-called “discount brokers,” although you would not receive the benefits of our investment and financial planning advice. If a client establishes a brokerage/custodial account through LPL Financial or any other broker-dealer, we will place all orders on behalf of a client’s portfolio through that broker-dealer, even though such client potentially could obtain a more favorable net price and execution from another broker-dealer in particular transactions or from a discount broker in general. Recommendation to Engage LPL Financial Beginning January 1, 2028 or later, LPL Financial will charge Petersen Hasting’s clients a “Custody Platform Fee” based on quarter end balances for that prior quarter. The Custody Platform fee compensates LPL Financial for all applicable transaction, maintenance, conversion, technology, service, and other applicable custodial fees executed by LPL Financial for our clients’ accounts. However, our clients will still incur fees on a per-transaction basis for certain specific, and commonly unanticipated items described in Item 5. As a courtesy to Petersen Hastings’ clients, LPL Financial has agreed to waive the Custody Platform fee through the end of 2027. LPL Financial has agreed to this pricing arrangement with Petersen Hastings based on the expectation (though not the specific requirement) that LPL Financial will maintain custody of at least $700M of Petersen Hastings’ clients’ 12  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure assets designated for management. The amount of the amount of Custody Platform Fee assessed against each respective client portfolio will range between 0.015% and 0.03% per year, depending on the total amount of Petersen Hastings’ clients’ investment management assets held at LPL Financial. Based on this pricing arrangement, the factors described in the “Best Execution” section above, and our knowledge of the securities industry, Petersen Hastings believes that its recommendation that clients engage LPL Financial as broker-dealer/custodian offers the best price and execution to our clients compared to other broker-dealers that offer institutional advisory platforms. Research and Other Benefits Received from Broker-Dealers While Petersen Hastings does not receive traditional “soft dollar benefits,” Petersen Hastings and by extension, its clients, receive access to certain institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. LPL Financial or other broker-dealer/custodians also make various support services available to Petersen Hastings. Some of those services help Petersen Hastings manage or administer its clients’ accounts, while others help it manage and grow its business. LPL Financial or other broker- dealer/custodians’ support services are generally available on an unsolicited basis (Petersen Hastings does not have to request them) and at no charge to Petersen Hastings. The institutional brokerage services that benefit Petersen Hastings’s clients and their accounts include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through LPL Financial or other broker-dealer/custodians include some to which Petersen Hastings might not otherwise have access or that would require a significantly higher minimum initial investment by its clients. LPL Financial or other broker-dealer/custodians also make other products and services available to Petersen Hastings that benefit Petersen Hastings but may only indirectly benefit its clients or their accounts, such as investment research that Petersen Hastings may use to service only certain clients’ accounts. They can offer technology that delivers access to client account data (such as duplicate trade confirmations and account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; provides pricing and other market data; facilitates payment of our fees from clients’ accounts; and assists with back-office functions, recordkeeping, and client reporting. The other services that Petersen Hastings may receive are intended to help Petersen Hastings manage and further develop its business. These services can include educational conferences and events; consulting on technology, compliance, legal and business needs; publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants, and insurance providers. LPL Financial or other broker-dealer/custodians may provide some of these services themselves or could arrange for third-party vendors to provide the services to Petersen Hastings. LPL Financial or other broker-dealer/custodians may discount or waive their fees for some of these services or pay all or a part of a third party’s fees. The availability of the services and products described above that Petersen Hastings receives from LPL Financial or other broker-dealer/custodians (the “Services and Products”) provides Petersen Hastings with an advantage, because we do not have to produce or purchase them. However, Petersen Hastings does not have to pay for Services and Products that LPL Financial or other broker-dealer/custodians provide. Our clients do not pay more for investment transactions executed or assets maintained at LPL Financial or other broker-dealer/custodians as a result. The receipt of Services and Products are not directly contingent upon Petersen Hastings committing any specific amount of business to LPL Financial or other broker-dealer/custodians in trading commissions or assets in custody. There is no corresponding commitment made by Petersen Hastings to LPL Financial or other broker- dealer/custodians or any other entity to invest any specific amount or percentage of client assets in any specific securities or investment products as a result of the above. However, this arrangement nonetheless incentivizes Petersen Hastings to recommend that clients maintain their account with a particular broker-dealer/custodian based on its interest in receiving services that benefit its business rather than based on clients’ interest in receiving the 13  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure best value in custody services and the most favorable execution of their transactions. This presents a conflict of interest. Therefore, when recommending a particular broker-dealer/custodian to a client, Petersen Hastings does so when it reasonably believes that recommending that broker-dealer/custodian to provide services is in the best interests of its clients. It is primarily supported by the scope, quality, and price of that broker-dealer/custodians’ services and not the services that benefit only Petersen Hastings. Directed Brokerage Petersen Hastings does not permit clients to direct brokerage with the assets we manage. Order Aggregation Certain accounts may trade in the same securities with your account(s) on an aggregated basis when consistent with our obligation of best execution. In such circumstances, these affiliated accounts and your account(s) will share commission costs equally and receive securities at a total average price. We will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order. Item 13 – Review of Accounts Reviews Your account with us is established after your personal circumstances, investment objectives, and risk tolerances are determined. At an initial in-person meeting we typically review the asset classes and types of holdings with which you are comfortable, the need for liquidity, and the degree of investment discretion given to us. Periodically you are requested to update us with respect to any change in your investment objectives or financial circumstances. Our Investment Committee periodically meets to review additions or deletions to its approved investment recommendations. Every account will be reviewed at least quarterly by an investment adviser representative of Petersen Hastings. Additional reviews may be triggered by investment performance that deviates from the expected volatility or performance under current market conditions, or a broad-based change in the financial markets. Every account is reviewed for maintenance of appropriate cash balances and rebalancing on a bi-weekly basis as needed per the variance limits set by the Investment Committee, or by account allocation constraints or market conditions. Investment adviser representatives hold client meetings on a pre-scheduled and/or as needed basis. Each Investment adviser representative may manage individual account clients and/or ERISA clients. The average number of individual account clients managed by an investment adviser representative is 104 while ERISA clients is 5. Reports We provide you with quarterly financial reports detailing security values, cash accounts, and performance statistics. Transactions are provided to you, on at least a quarterly basis, on the custodian account statements. More frequent reporting is available on a fee basis and special reports are available upon your request. Item 14 – Client Referrals and Other Compensation We do not currently, but may in the future, compensate people or firms for providing referrals to us. We emphasize a "team approach" when providing investment advisory services to you. If you request or if we believe legal, accounting, or insurance services will benefit your financial plan, we will recommend an independent 14  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure attorney, accountant, or insurance agent. We do not pay for client referrals or enter into arrangements with other professionals for client referrals. However, there may be a conflict of interest if we receive referrals from professionals that we have recommended. We will only refer outside professionals to you when we believe these services best suit your needs. Petersen Hastings and The Lampo Group, LLC (d/b/a Ramsey Solutions) have entered into a marketing agreement, under which The Lampo Group, LLC receives a total of $4,025.60 per month from Petersen Hastings for marketing services related to the “SmartVestor Pro” program. That fee is the total monthly cost of the program and is not the cost per solicited client. The Lampo Group, LLC will receive 0% of the advisory fees received by Petersen Hastings from client accounts, and The Lampo Group, LLC’s compensation is fixed for services under the agreement at the amount indicated above. The total cost of services provided by The Lampo Group, LLC are billed in full to Petersen Hastings, and they are not related to any individual cost incurred by the client. No cost will be added to the advisory fees to be paid for Petersen Hastings’ services as a result of the compensation to be paid to The Lampo Group, LLC, and the investment advisory fees shall be the same as those charged to other clients of Petersen Hastings for similar services. The Lampo Group, LLC is not an investment adviser, employee, or agent of Petersen Hastings, is not otherwise affiliated with Petersen Hastings and is not authorized to bind or obligate Petersen Hastings in any way. Petersen Hastings also receives the Services and Products described in Item 12 above. Item 15 – Custody Petersen Hastings does not maintain physical custody of client assets. You will receive statements on at least a quarterly basis from the custodian that holds and maintains your investment assets. We urge you to carefully review such statements and compare their official custodial records to the reports provided by us and report any issues promptly. Our statements may vary from the custodial or brokerage statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion Discretionary Authority for Trading Pursuant to the terms of their Investment Advisory Agreement with us, clients typically grant Petersen Hastings discretionary authority over their accounts to determine the securities to be bought and sold, to place trades, to negotiate transaction costs on their behalf, where possible, to allocate assets to and from separately managed account programs and third-party investment managers, and to periodically rebalance the clients’ accounts back to the recommended allocations. Petersen Hastings has no obligation to supervise or direct investments held in client accounts that were not recommended, or that are not subject to review, by Petersen Hastings for a fee. We observe your investment policies, limitations, and restrictions when selecting securities and determining amounts to allocate to these securities. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Any investment restrictions you wish to impose on our management of your account must be provided to us in writing. Limited Power of Attorney Petersen Hastings will assist clients in opening an account with an independent custodian or broker-dealer or directly with a mutual fund company. Clients are required to grant a “Limited Power of Attorney” over their respective custodial accounts to Petersen Hastings for purposes of trading and fee deduction. Clients grant this authority in the brokerage account applications. 15  Petersen Hastings Wealth Advisors, Inc. ADV Part 2A Brochure Item 17 – Voting Client Securities We vote all proxies relating to securities held in your account(s) for which we provide discretionary investment management services, including ERISA clients, unless otherwise directed by you. For the avoidance of doubt, assets allocated to separately managed account programs or third-party investment managers will be subject to the proxy voting practices of such outside manager(s). When we vote proxies, all proxies are voted in a manner that is consistent with your best interests, pursuant to proxy voting guidance adopted by us. You may obtain a copy of our complete proxy voting policies and procedures, free of charge, upon request. You may also obtain information from us about how we voted any proxies on behalf of your account(s). Item 18 – Financial Information We are not aware of any financial condition that is reasonably likely to impair our ability to meet contractual obligations to you. 16