STEELE STREET PRIVATE WEALTH MANAGEMENT

ITEM 1 – COVER PAGE CDKV HOLDING, LLC DBA 50 S. Steele Street, Suite 501 Denver, Colorado 80209 720-730-2550 www.steelestpwm.com Part 2A of Form ADV: Firm Brochure March 11, 2026 This brochure provides information about the qualifications and business practices of CDKV Holdings, LLC DBA Steele Street Private Wealth Management (“SSPWM”). If you have any questions about the contents of this brochure, please contact us at 720-730-2550. 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. SSPWM is a Registered Investment Adviser. Registration as an Investment Adviser with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. information about SSPWM available on the SEC’s website Additional at is www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as an IARD number. The IARD number for SSPWM is #299856. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 1  ITEM 2 – MATERIAL CHANGES This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.adviserinfo.sec.gov. Since our last ADV Annual Amendment filing on January 31, 2025, there have been no material changes to report. If you would like another copy of this Brochure, please download it from the SEC Website as indicated above or you may contact our Chief Compliance Officer, Daniel Katz, dkatz@steelestpwm.com or 720-730-2550. We encourage you to read this document in its entirety. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 2  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE .............................................................................................................................. 1 ITEM 2 – MATERIAL CHANGES .................................................................................................................. 2 ITEM 3 – TABLE OF CONTENTS ................................................................................................................. 3 ITEM 4 – ADVISORY BUSINESS ................................................................................................................. 4 ITEM 5 - FEES AND COMPENSATION ........................................................................................................ 9 ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................... 14 ITEM 7 – TYPES OF CLIENTS .................................................................................................................... 14 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................... 14 ITEM 9 - DISCIPLINARY INFORMATION ................................................................................................... 20 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................. 20 ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ................................................................................................................................................ 20 ITEM 12 – BROKERAGE PRACTICES ......................................................................................................... 21 ITEM 13 – REVIEW OF ACCOUNTS .......................................................................................................... 27 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................. 27 ITEM 15 – CUSTODY ............................................................................................................................... 28 ITEM 16 – INVESTMENT DISCRETION ..................................................................................................... 29 ITEM 17 - VOTING CLIENT SECURITIES .................................................................................................... 30 ITEM 18 – FINANCIAL INFORMATION ..................................................................................................... 31 STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 3  ITEM 4 – ADVISORY BUSINESS This Disclosure document is being offered to you by Steele Street Private Wealth Management (“SSPWM” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. Our Firm was registered as an Investment Adviser in January 2019 and is owned by Daniel Katz and Casey Vader. Casey Vader is Chief Operating Officer and Daniel Katz serves as Chief Compliance Officer for the Firm. We are committed to helping clients build, manage, and preserve their wealth, and to provide guidance that helps clients to achieve their stated financial goals. We specialize in retirement investing and income generation. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and SSPWM execute an Investment Management Agreement. Investment Management Services We manage advisory accounts on a discretionary and non-discretionary basis. Once we determine a client’s profile, income need, and investment plan, we execute the day-to- day transactions with or without prior consent, depending on the client’s agreement with our Firm. Account supervision is guided by the client’s investment policy statement. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among various equities, cash, Exchanged Traded Funds (“ETFs”), other mutual funds and debt securities in accordance with their stated investment objectives and income needs. All of these are considered asset allocation categories for the client’s investment strategy. In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and income need. As appropriate, we also review their prior investment history, as well as family composition and background. Based on client needs, we develop the client’s personal profile and investment plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals and income needs. Once we have determined the appropriate strategy for clients or client businesses and executed the strategy, we will provide ongoing investment review and management services. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 4  With our discretionary relationships, we will make changes to the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios based on the combination of our market views and your objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. Additionally, clients may engage our firm separately to advise on certain investment products that are not maintained at their primary custodian, such as annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. Financial Planning Our Financial Planning services are offered to clients who are engaged in our wealth management services described above. While we will work with all clients to understand their financial objectives, we will not present a formal financial plan to all of them. Through the financial planning process, our team strives to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each family in mind, our team may offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow and retirement income, wealth transfer and family legacy objectives. Our team partners with our client’s other advisors (CPA, estate attorney, insurance broker, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets and periodic updates. -We have established a relationship with Kristi Sullivan with Sullivan Financial Planning, a State Registered Investment Advisor. Sullivan Financial Planning provides financial planning services for clients on a project basis. Sullivan Financial Planning bills our firm an hourly fee for planning services. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 5  Sullivan Financial Planning’s specific services in preparing a client’s formal financial plan may include: • Review and clarification of financial goals; • Assessment of overall financial position including cash flow and income, balance sheet, investment strategy, risk management and estate planning; • Creation of a financial plan, including personal and business real estate, education, retirement, financial independence, charitable giving, estate planning, business succession and other personal goals; • Development of a goal-oriented investment and income plan, with input from various advisors to our clients around tax strategy, asset allocation, asset location, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans, taxable and trust accounts that require special attention. • Design of a risk management plan including risk tolerance, risk avoidance, mitigation and transfer, including liquidity as well as various insurance and possible company benefits; and • Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death. Retirement Plan Advisory Services For employer-sponsored retirement plans with participant-directed investments or cash balance plans, our firm provides its advisory services as an investment advisor as defined under Section 3(21) or 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(38) investment manager, the Plan Sponsor is relieved of all fiduciary responsibility for the investment decisions made by Our Firm. Our Firm is a discretionary investment manager in accordance with the terms of a separate ERISA 3(38) Plan Sponsor Investment Management Agreement between Our Firm and the Plan Sponsor. Our Firm’s investment management is limited in that it has the discretion solely to replace funds in plan fund lineups and initiate the transfer of existing balances to the replacements without prior approval from the client. Our Firm provides the following services to the plan sponsor: • Select the investments. • Monitor the investments and replace investments when appropriate. • Provide a quarterly monitoring report. • Assist the plan sponsor in developing an Investment Policy Statement (“IPS”). STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 6  • Provide a comprehensive fiduciary investment review designed to meet Plan Sponsor fiduciary responsibility and enhance the participant experience. This includes fiduciary education as requested by the Department of Labor (DOL). • Recommend QDIA alternatives. • Recommend non-discretionary model portfolios. When serving as an ERISA 3(21) investment advisor, the Plan Sponsor and Our Firm share fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement between our Firm and the Plan Sponsor. Under the 3(21) agreements, our Firm provides the following services to the Plan Sponsor: investments and suggests replacement investments when • Screen investments and make recommendations. • Monitor the appropriate. • Provide a quarterly monitoring report. • Assist the plan sponsor in developing an Investment Policy Statement (“IPS”). • Recommend QDIA alternatives. • Recommend non-discretionary model portfolios. We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial education to Plan participants, benchmarking the Plan services, education to fiduciary committee members, and monitoring the service provider. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA and participant education will relate to general principles for investing and information about the investment options currently in the Plan. We may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for new participants. Participant Level Education We can also be engaged to provide financial education to plan participants. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA and participant education will relate to general principles for investing and information about the investment options currently in the plan. We may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for new participants. We may meet with plan participants on a regular basis (quarterly, semi-annually or annually) as agreed upon at the Client’s discretion to discuss the reports and investment recommendations. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 7  Tax Planning and Preparation Our Firm recommends independent CPAs to provide tax planning and preparation for individuals and business owners. These services may be provided to the client for a separate fee and will be engaged. Accounting services performed by these CPAs are separate and distinct from our firm’s advisory services. Steele Street and the CPAs are unaffiliated. Financial Planning and Consulting Services While financial planning services are included in our wealth management services and fees, we do provide investment advice on isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic under a separate Financial Consulting Agreement. Additionally, we provide non-securities advice related to estate planning, insurance, real estate, and annuity. We also provide advisory & consulting services for equity or debt investments in privately held businesses. In these cases, you will be required to select your own investment managers, custodians, and insurance companies to implement consulting recommendations. If you need brokerage and/or other financial services, we will recommend one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals ("Firms"). You must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm you choose. You have the right to choose whether to follow the consulting advice that we provide. Disclosure Regarding Rollover Recommendations A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 8  those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations are also reviewed by our Firm’s Chief Compliance Officer in a best effort to determine that the recommendation to a client was reasonable or that the client has determined to make the rollover after being provided ample information about their options. No client is under any obligation to roll over plan assets to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the account while maintained with the client's employer. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding this disclosure. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Wrap We do not provide a Wrap Fee Program. Assets As of December 31, 2025, we manage $186,757,145 on a discretionary basis and a total of $767,118 under non-discretionary management. Total assets under management total $187,524,263. ITEM 5 - FEES AND COMPENSATION Investment Management Fees and Compensation Our Firm charges an advisory fee as compensation for providing Investment Management services on client accounts. These services include portfolio management, investment supervision and other account-maintenance activities. Our recommended custodian charges custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for additional details. Financial Planning services are included in our firm’s investment management fees. Our maximum investment advisory fees as a percentage of assets under management is 1.50%. The specific advisory fees are set forth in your Investment Advisory Agreement. Asset-based fees are billed quarterly in advance and calculated on the market value on STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 9  the last business day of the prior quarter. For the initial billing period, the advisory fee is billed in arrears and calculated on a pro rata basis for the number of days your account is under our management for the partial quarter. All additions and withdrawals will result in a prorated fee adjustment during the following quarter of the addition or withdrawal. There may be a possibility for price or account value discrepancies due to quarter-end transactions in an account. Dividends or trade date settlements may occur, and our third- party billing software may report a slight difference in account valuation at quarter end compared to what is reported on your Statement from the Custodian. Our firm has the ability to produce billing summaries, which can be provided upon request. We may negotiate our advisory fees such. For example, we may negotiate a lower advisory fee or have the right to waive the minimum account value. Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account or other reasons agreed upon by us and the client. In certain circumstances, our fees and the timing of the fee payments may be negotiated. Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of determining the account size and annualized fee. The common practice is often referred to as “householding” portfolios for fee purposes and may result in lower fees than if fees were calculated on portfolios separately. Our method of householding accounts for fee purposes looks at the overall family dynamic and relationship. When applicable and noted in the Investment Management Agreement, legacy concentrated stock positions may also be excluded from the fee calculation. The independent qualified custodian holding your funds and securities will debit your account directly for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be paid directly from your account held by the qualified custodian. At the client’s discretion, you may pay the advisory fees directly to our Firm by check. Further, the qualified custodian agrees to deliver an account statement to you on a quarterly basis indicating all the amounts deducted from the account including our advisory fees. The Investment Advisory Agreement may be terminated by the client within five (5) business days of signing the Agreement without penalty or incurring any advisory fees. After the 5 business days, either party giving written or verbal notice to the other may cancel the Investment Advisory Agreement at any time for any reason. Notice given by the client shall be effective upon actual receipt by SSPWM at the address specified on the Investment Advisory Agreement or the then current address. The management fee will be pro-rated to the date of termination, for the quarter in which the cancellation STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 10  notice was given and the unearned fee refunded to your account as indicated in your Agreement. Upon termination, you are responsible for monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those assets. In the event of client’s death or disability, our Firm will continue management of the account until we are notified and given alternative instructions by an authorized party. In no case are our fees based on, or related to, the performance of your funds or investments. We will not require prepayment of more than $1,200 in fees per client, six (6) or more months in advance of providing any services. Employer Sponsored Retirement Plan Services For Retirement Plan Advisory Services compensation, we charge an annual fee as negotiated with the client and disclosed in the Employer Sponsored Retirement Plans Investment Advisory Agreement. The compensation method is explained and agreed upon in advance before any services are rendered. Asset based fees range from 0.20% to 1.00% annually and fixed fees range from $500 - $100,000 annually. Plan advisory services begin with the effective date of the Employer Sponsored Retirement Plans Investment Advisory Agreement, which is the date you sign the Employer Sponsored Retirement Plans Investment Advisory Agreement. For that calendar quarter, fees will be adjusted pro rata based upon the number of calendar days in the calendar quarter that the Agreement was effective. Our fee is billed in arrears on the last business day of the calendar quarter or month as outlined in the Agreement. For Plans where our fee is billed to the custodian, the fee is deducted directly from the participant accounts. Written authorization permitting us to be paid directly from the custodial account is outlined in the Agreement. Either party may terminate the Investment Advisory Agreement at any time upon immediate notice. You are responsible to pay for services rendered until the termination of the Agreement. Consulting Fees We provide consulting services for clients who need advice on a limited scope of work. We will negotiate consulting fees with you. Fees for Consulting Services will vary based on the extent and complexity of the consulting project. The maximum hourly fee to be charged will not exceed $500.00 per hour. The fee-paying arrangements for this service will be determined on a case- by-case basis and will be detailed in the signed consulting STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 11  agreement. Fees will be billed as services are rendered and sent to the Client. Either party may terminate the agreement. Periods of Inactivity Our Firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, our Firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when our Firm determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by our Firm will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 above during periods of account inactivity. Additional Fees and Expenses In addition to the advisory fees paid to our Firm, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include custodial fees, commissions, charges imposed by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), 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. Our brokerage practices are described at length in Item 12, below. Neither our Firm nor its supervised persons accept compensation for the sale of securities or other investment products. Further, our firm does not share in any of these additional fees and expenses outlined above. Our firm may include mutual funds and exchange traded funds, (“ETFs”) in our investment strategies. Our policy is to purchase institutional share classes of those mutual funds selected for the client’s portfolio. The institutional share class generally has the lowest expense ratio. The expense ratio is the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for funds expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and all other asset-based costs incurred by the fund. Some fund families offer different classes of the same fund and one share class may have a lower expense ratio than another share class. These expenses come from client assets which could impact the client’s account performance. Mutual fund expense ratios are in addition to our fee, and we do not receive any portion of these charges. If an institutional share class is not available for the mutual fund selected, the adviser will purchase the least expensive share STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 12  class available for the mutual fund. As share classes with lower expense ratios become available, we may use them in the client’s portfolio, and/or convert the existing mutual fund position to the lower cost share class. Clients who transfer mutual funds into their accounts would bear the expense of any contingent or deferred sales loads incurred upon selling the product. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). All mutual fund expenses and fees are disclosed in the respective mutual fund prospectus. When selecting investments for our clients’ portfolios we might choose mutual funds on your account custodian’s Non-Transaction Fee (NTF) list. This means that your account custodian will not charge a transaction fee or commission associated with the purchase or sale of the mutual fund. The mutual fund companies that choose to participate in your custodian’s NTF fund program pay a fee to be included in the NTF program. The fee that a mutual fund company pays to participate in the program is ultimately borne by the owners of the mutual fund including clients of our Firm. When we decide whether to choose a fund from your custodian’s NTF list or not, we consider our expected holding period of the fund, the position size and the expense ratio of the fund versus alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best interest. Administrative Services Provided by Tamarac We have contracted Tamarac to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, client database maintenance, quarterly performance evaluations, payable reports, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Tamarac will have access to client information, but Tamarac will not serve as an investment adviser to our clients. SSPWM and Tamarac are non-affiliated companies. Tamarac charges our Firm an annual fee for each account administered by Tamarac. Please note that the fee charged to the client will not increase due to the annual fee SSPWM pays to Tamarac, the annual fee is paid from the portion of the management fee retained by our Firm. Our agreement with Tamarac does provide for the confidentiality of your personal identifiable information. Regulatory Fees To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to applicable sales transactions. The Securities and Exchange Commission (SEC) regulatory fee is assessed on client accounts for sell transactions, and a FINRA fee is assessed on client accounts for sell transactions, for certain covered securities. This fee is not STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 13  www.sec.gov/fast-answers/answerssec31htm.html charged by our Firm but is accessed and collected by the custodian. The Custodian that our Firm uses, is a FINRA member firm. These fees recover the costs incurred by the SEC and FINRA, for supervising and regulating the securities markets and securities professionals. The fee rates vary depending on the type of transaction and the size of that transaction. For more information on the SEC and FINRA fees, please visit their websites: or www.finra.org/industry/trading-activity-fee. ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client account (so-called performance-based fees) nor engage in side-by- side management. ITEM 7 – TYPES OF CLIENTS We provide investment advice to individuals, high net individuals, employer sponsored retirement plans, charitable organizations, institutions, estates and trusts. The minimum initial account value for opening an account with our firm is $500,000.00; however, we may accept accounts for less than the minimum at our sole discretion. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Investment Strategies, Philosophy, and Methodology We seek to recommend investment strategies that will give a client a diversified portfolio consistent with the client’s investment objective. The goal is to identify a client’s risk tolerance, and then find construct portfolios with the maximum expected return for that level of risk. Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Our Firm specializes in retirement investing and income strategies. Asset liability matching is utilized to determine cash flow needs and timing of cash flow and principal payments. Our IARs build portfolios to address client needs for income and growth using dividend paying stocks, preferred stocks, and fixed income investments, including individual bonds. We assess each individual’s tax liabilities when determining the appropriate investment vehicles. We optimize the tax efficiency of the portfolio for high STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 14  income investors through the use of tax free municipals bonds and instruments that provide qualified dividend income. We utilize both fundamental and technical analysis. We gather our information from a broad array of financial resources including both sell-side and buy-side research, financial newspapers, magazines, research prepared by others, corporate rating services, company press releases, annual reports, prospectuses and filings with the Securities and Exchange Commission. We determine how to allocate assets among the various asset classes based on the investment strategy chosen, prevailing economic conditions and our determination of where we are in the economic cycle. Potential risks and opportunities are weighed to determine to what degree the portfolio should be invested. From time-to-time, market conditions may cause your account to vary from the established allocation. To remain consistent with the asset allocation guidelines established, your account is monitored on an ongoing basis and rebalanced to the original allocation, or if deemed beneficial, to a new allocation based on the then prevailing economic conditions and within the guidelines of the chosen investment strategy. In addition to the rebalancing, overall market conditions and microeconomic factors that affect specific holdings in your account may trigger changes in allocation. Your account may also receive informal reviews more frequently in volatile markets. Investment Philosophy Prior to making recommendations, we determine your financial status, needs, time horizon, investment objectives, risk tolerance, and tax status. From this, we create an investor profile and general asset allocation target. While we believe asset allocation is a key factor affecting long term rate of return, we also believe fundamental research and securities selection are vital. • Active Manager Selection: We focus primarily on the people, processes, research, consistency, and culture rather than simply recent “high performance” or “track record.” In addition to direct discussions with managers and fund companies, we utilize outside data vendors, such as Morningstar, when analyzing active managers. • Passive Manager Selection: Passive investment vehicles, mainly in the form of indexed ETFs, will be evaluated based on price, liquidity, optionality, the underlying index or process, and fund STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 15  structure. We employ numerous passive vehicles in each asset class, allowing us to tax loss harvest without losing exposure to specific asset classes, styles, or sectors. Individual Security Selection: • Individual securities will be used to generate alpha (excess returns above an index or sector). The decision to allocate to a specific asset class, style, or sector is based on “top-down” or macroeconomic analysis. The selection of individual securities within each asset class, style, or sector is based on “bottom-up” or fundamental analysis. We seek to identify securities that are comparatively undervalued or are subject to price inefficiencies. We will often use both sell-side and buy-side research when researching individual securities. Furthermore, credit analysis is heavily used when selecting fixed income securities. Resources such as SEC EDGAR and MSRB EMMA are used to research specific credits. Sell side research will also be used when evaluating investments that are below investment grade (“junk” and “distressed” securities). • Private Placements for Certain Qualified Investors: For certain accredited investors, we may recommend and monitor certain private placements. These investments will diversify the sources of return by allocating to various strategies, including hedge funds, private equity, and real estate. Our rigorous due diligence process includes both quantitative and qualitative reviews. Quantitative reviews will include an assessment of risks, return attribution, and performance benchmarking. Qualitative reviews include an assessment of the people, investment philosophy, investment process, portfolio construction, and risk management. A structural review will also be used to evaluate operational risks, legal and regulatory risks, and business risks. As much as reasonably possible, we strive to: • Diversify strategically with non-correlating assets. • Balance between growth and value styles. • Diversify globally. • Rebalance as markets change. • Manage for tax efficient returns wherever possible. Risk of Loss Clients must understand that past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different types of investments there will be varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss including loss of original principal. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 16  Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Investors should be aware that accounts are subject to the following risks: • Market Risk — Even a long-term investment approach cannot guarantee a profit. Economic, political and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon liquidation. • Foreign Securities and Currency Risk — Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. • Capitalization Risk — Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. • Interest Rate Risk — In a rising rate environment, the value of fixed- income securities generally declines, and the value of equity securities may be adversely affected. • Credit Risk — Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and, thus, impact the fund’s performance. • Securities Lending Risk — Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. • Exchange-Traded Funds — ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 17  the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset value.” • Performance of Underlying Managers — We select the mutual funds and ETFs in our portfolios. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. • Liquidity Risk - Liquidity risk exists when particular investments would be difficult to purchase or sell, possibly preventing clients from selling such securities at an advantageous time or price. • Limited Partnership (“LP”) Risk - LPs are often marketed as investments that combine the tax benefits of limited partnerships with the liquidity of publicly traded securities. An investment in LP units, however, involves risks that differ from a similar investment in equity securities, such as common stock, of a corporation. Holders of LP units have the rights typically afforded to limited partners in a limited partnership. As compared to common shareholders of a corporation, holders of LP units have more limited control and limited rights to vote on matters affecting the partnership. Further, there are certain tax risks associated with an investment in LP units, as LP units are treated differently for tax purposes than common stock. Clients are advised to speak with their accountant to receive tax advice about LPs. • Alternative Risk – Investments classified as "alternative investments" may include a broad range of underlying assets including, but not limited to, hedge funds, private equity, venture capital, and registered, publicly traded securities. Alternative investments are speculative, not suitable for all clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with a single advisor; absence of information regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees than other investment options such as mutual funds. The SEC and/or States require investors be accredited to invest in these more speculative alternative investments. Investing in a fund that concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 18  • • Cybersecurity Risk - In addition to the Material Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at SSPWM or one of its third- party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information, and generally compromise our Firm’s ability to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk that cybersecurity breaches may not be detected. Interval Funds Risk- An interval fund is a type of closed-end fund. Unlike other closed end shares they do not trade on the secondary market. Instead, the fund periodically offers to buy back a percentage of outstanding shares at net asset value. The rules for interval funds, along with the types of assets held, make this investment largely illiquid compared with other funds. High yields are the main reason investors are attracted to interval funds. There may not be a guarantee that the fund will offer to buy back the shares. • Margin Risk When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds through a margin account, securities purchased are the firm's collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account. Investing with margin is characterized by unique risks including amplified losses due to increased leverage; margin calls; forced liquidations; and additional fees including margin interest charges. In order to manage margin risk, we recommend leveraging responsibly (borrowing less than the amount available); keeping a diversified portfolio; and monitoring the account and evaluating risk regularly. Before investing on STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 19  margin, be sure to read the Margin Disclosure Statement provided by your custodian. • Artificial Intelligence and Machine Learning: Certain service providers utilized by the Firm to service client accounts have artificial intelligence components, such as our client relationship management system and/or communication tools that utilizes artificial intelligence to summarize client meeting notes. The use of artificial intelligence and machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. ITEM 9 - DISCIPLINARY INFORMATION We do not have any legal, financial or other “disciplinary” item to report. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Our Firm recommends various CPAs to provide tax planning and preparation for individuals and business owners. There is no affiliation or common ownership with any of the CPA firms. Accounting services provided by these CPAs may be separate and distinct from our advisory services. Clients are under no obligation to utilize the services of the tax planning and preparation. Clients have the right to decide to engage the recommended professionals. ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, and the prohibition against the use of inside information. The Code of Ethics is designed to: • protect our clients, • detect and deter misconduct, • educate personnel regarding the firm’s expectations and laws governing their conduct, • remind personnel that they are in a position of trust and must act with complete propriety at all times, • protect the reputation of our Firm, • guard against violation of the securities laws, STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 20  • establish procedures for personnel to follow so that we may determine whether their personnel are complying with the firm’s ethical principles. Our Firm and persons associated with us are allowed to invest for their own accounts or to have a financial investment in the same securities or other investments that we recommend or acquire for your account and may engage in transactions in the same securities that our firm is purchasing for client accounts. We recognize the fiduciary responsibility to act in your best interest and have established policies to mitigate conflicts of interest. We have established the following restrictions in order to ensure our firm’s fiduciary responsibilities: 1. A director, officer or employee of SSPWM shall not buy or sell any securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No supervised employee of SSPWM shall prefer his or her own interest to that of the advisory client. Additionally, supervised persons are prohibited from front running client accounts. 2. We maintain a list of all securities holdings of anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of SSPWM. 3. We emphasize the unrestricted right of the client to decline to implement any advice rendered, except in situations where we are granted discretionary authority of the client’s account. 4. We require that all supervised employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 5. Any supervised employee not in observance of the above may be subject to termination. You may request a complete copy of our Code of Ethics by contacting us at the telephone number on the cover page of this Part 2; Attn: Chief Compliance Officer. ITEM 12 – BROKERAGE PRACTICES Clients must maintain assets in an account at a “qualified custodian,” generally a broker- dealer or bank. We generally recommend that our clients use Charles Schwab & Co., Inc. Advisor Services (“Schwab”), a registered broker-dealer, member SIPC, as the qualified STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 21  custodian. We are independently owned and operated, and unaffiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities as instructed. In some cases, our Firm may recommend that you establish accounts with a firm other than Schwab to maintain custody of your assets. While we recommend that clients use Schwab as Custodian, client must decide whether to do so and open accounts with Schwab or any other custodian by entering into account agreements directly with them. The client opens the accounts directly with the Custodian. The accounts will always be held in the name of the client and never in SSPWM or the Advisors’ name. How We Select Custodians We seek to recommend a custodian/broker who will hold client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: 1. Combination of transaction execution services and asset custody services (generally without a separate fee for custody) 2. Capability to execute, clear, and settle trades (buy and sell securities for client accounts) 3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) 4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) 5. Availability of investment research and tools that assist us in making investment decisions 6. Quality of services 7. Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices 8. Reputation, financial strength, and stability 9. Prior service to SSPWM and our other clients 10. Availability of other products and services that benefit us, as discussed below (see Products and Services Available to Us from Schwab) Client Brokerage and Custody Costs STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 22  For our clients’ accounts that Schwab maintains, Schwab generally does not charge separately for custody services. On occasion, a client may be charged fees to custody alternative investments held outside of Schwab. Schwab receives compensation by charging ticket charges or other fees on trades that it executes or that settle into clients’ Schwab accounts. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see How We Select Brokers/Custodians). Products and Services Available to Us from Schwab Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like us. They provide SSPWM and our clients with access to its institutional brokerage, 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; others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis (we do not have to request them) and at no charge to us. These are considered soft dollar benefits. This creates a conflict of interest because there is an incentive to do business with Schwab. We have established policies in this regard to mitigate any conflicts of interest. We believe that our selection of Schwab as custodian and broker is in the best interests of clients. SSPWM will at all times act in the best interest of their clients and act as a fiduciary in carrying out services to clients. Following is a more detailed description of Schwab’s support services: Services That Benefit Our Clients 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 paragraph generally benefit our clients and their accounts. Services That May Not Directly Benefit Our Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit our clients or their accounts. 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 STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 23  Schwab. In addition to investment research, Schwab also makes available software and other technology that: 1. Provide access to client account data (such as duplicate trade confirmations and account statements) 2. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts 3. Provide pricing and other market data 4. Facilitate payment of our fees from our clients’ accounts 5. Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: 1. Educational conferences and events 2. Consulting on technology, compliance, legal, and business needs 3. Publications and conferences on practice management and business succession 4. Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab, or other third-party product vendors, may also provide us with other benefits, such as occasional business entertainment of our personnel, travel and travel-related expenses related to investment selection and monitoring, or attending professional investment and industry specific conferences. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions. We believe that our selection of Schwab as custodian and broker is in the best interests of our clients. Some of the products, services and other benefits provided by Schwab benefit SSPWM and may not benefit our client accounts. Our recommendation or requirement that you STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 24  place assets in Schwab's custody may be based in part on benefits Schwab provides to us, or our agreement to maintain certain Assets Under Management at Schwab, and not solely on the nature, cost or quality of custody and execution services provided by Schwab. We place trades for our clients' accounts subject to its duty to seek best execution and its other fiduciary duties. Schwab's execution quality may be different than other Custodians. SSPWM annually reviews the relationship between Charles Schwab, SSPWM and the client in order to determine if the custodial relationship is in the best interest of the client. Fixed Income Trades We have full discretion in the selection of brokers or dealers for fixed income trading only. We seek to obtain quality execution for security transactions through brokers and dealers who in our opinion are financially responsible. In selecting a broker or dealer, we may take into account relevant factors with respect to liquidity and execution of the order, as well as the amount of the capital commitment by the broker or dealer. Other relevant factors may include, without limitation: (a) the execution capabilities of the brokers and/or dealers, (b) the size of the transaction, (c) the difficulty of execution, (d) the operations facilities of the brokers and/or dealers involved, and (e) the risk in positioning a block of securities. Aggregation and Allocation of Transactions We may aggregate transactions if we believe that aggregation is consistent with the duty to seek best execution for our clients and is consistent with the disclosures made to clients and terms defined in the client Investment Advisory Agreement. We may make trades in individual accounts (that are not aggregated with others) so that we may address that client’s unique circumstances. No advisory client will be favored over any other client, and each account that participates in an aggregated order will participate at the average share price (per custodian) for all transactions in that security on a given business day. We will aggregate trades for ourselves or our associated persons with your trades, providing that the following conditions are met: 1. Our policy for the aggregation of transactions shall be fully disclosed to our existing clients (if any) and the Custodian(s) through which such transactions will be placed; 2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty to seek the best execution (which includes the duty STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 25  to seek best price) for you and is consistent with the terms of our Investment Advisory Agreement with you for which trades are being aggregated; 3. No advisory client will be favored over any other client; each client that participates in an aggregated order will participate at the average share price for all our transactions in a given security on a given business day; 4. We will prepare a written statement (“Allocation Statement”) specifying the participating client accounts and how to allocate the order among those clients; 5. If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the allocation statement; if the order is partially filled, the accounts that did not receive the previous trade’s positions should be “first in line” to receive the next allocation; 6. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the Allocation Statement if all client accounts receive fair and equitable treatment and the reason for difference of allocation is explained in writing and is reviewed by our compliance officer. Our books and records will separately reflect, for each client account, the orders of which aggregated, the securities held by, and bought for that account; 7. We will receive no additional compensation or remuneration of any kind as a result of the proposed aggregation; and 8. Individual advice and treatment will be accorded to each advisory client. Trade Errors We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and we will absorb any loss resulting from the trade error if the error was caused by the firm. If the error is caused by the custodian or our trading platform provider, the custodian or trading platform provider will be responsible for covering all trade error costs. If an investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit or profit from trade errors. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 26  ITEM 13 – REVIEW OF ACCOUNTS Account Reviews and Reviewers – Investment Supervisory Services Our Investment Adviser Representatives will monitor client accounts on at least a quarterly basis and perform reviews with each client at least annually or more often as is agreed upon by the client and our firm. All accounts are reviewed for consistency with client investment strategy, asset allocation, risk tolerance and performance relative to the appropriate benchmark. More frequent reviews may be triggered by changes in an account holder’s personal, tax or financial status. Geopolitical and macroeconomic specific events may also trigger reviews. Clients may request a review at any time. Statements and Reports The custodian for the individual client’s account will provide clients with an account statement at least quarterly. As agreed upon between the client and the firm, clients may receive a SSPWM-prepared written report detailing their current positions, asset allocation, and year-to-date performance. You are urged to compare the reports provided by our firm against the account statements you receive directly from your account custodian. Please notify our firm of any discrepancies found in the Firm’s reports. Those clients who are exclusively Consulting or Financial Planning clients (i.e. those who have no assets under management with us in our advisory program) will receive no regular reports from the Firm. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION As referenced in Item 12 above, we may receive an indirect economic benefit from the firm’s recommended Custodian, Schwab. Our Firm, without cost (and/or at a discount), may receive support services and/or products from Schwab or another broker- dealer/custodian, investment manager, platform or fund sponsor. Other than that already disclosed in this Brochure, our Firm does not receive any additional compensation from third parties for providing investment advice to its clients. Further, our firm does not pay out compensation for any client referrals. From time to time, we may receive expense reimbursement for travel, marketing and/or seminar expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing-expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing such as advertising, publishing and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 27  sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. Our Firm may be asked to recommend a financial professional, such as an attorney, accountant, or mortgage broker. In such cases, representatives of our Firm may receive compensation in return for referrals made to individuals or firms in our professional network. Clients must independently evaluate these firms or individuals before engaging in business with them and clients have the right to choose any financial professional to conduct business. Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm does not pay or receive any direct compensation in return for any referrals made to or from our Firm. Our Firm does recognize the fiduciary responsibility to place your interests first and have established policies in this regard to mitigate any conflicts of interest. ITEM 15 – CUSTODY Custody has been defined by regulators as having access or control over client funds and/or securities. Our firm does not have physical custody of funds or securities, as it applies to investment advisors. Deduction of Advisory Fees Our firm has “constructive” custody of the funds and securities solely as a consequence of its authority to instruct the Custodian to make withdrawals from client accounts to pay its advisory fee. For all accounts, our firm has the authority to have its management fees deducted directly from client accounts. Our firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from our Firm. When you have questions about your account statements, you should contact our Firm or the qualified custodian preparing the statement. Please refer to Item 5 for more information about the deduction of adviser fees. Standing Letters of Authorization – Third Parties While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 28  described below under “Standing Instructions”. All our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our Firm has adopted the following safeguards in conjunction with our custodians: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice instruction and an annual notice reconfirming the confirming the instruction. ITEM 16 – INVESTMENT DISCRETION For discretionary accounts, prior to engaging our Firm to provide investment advisory services, you will enter a written Agreement with us granting the firm the authority to STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 29  supervise and direct, on an on-going basis, investments in accordance with the client’s investment objective and guidelines. In addition, you will need to execute additional documents required by the Custodian to authorize and enable SSPWM, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell or exchange securities in and for your accounts. We are authorized, in our discretion and without prior consultation with you to: (1) buy, sell, exchange and trade any stocks, bonds or other securities or assets and (2) determine the amount of securities to be bought or sold and (3) place orders with the custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you, the client. The limitations on investment discretion held by SSPWM for you are: 1. For discretionary accounts, we require that we be provided with authority to determine which securities and the amounts of securities to be bought or sold. 2. Any limitations on this discretionary authority shall be in writing. You may change/amend these limitations in writing as required. We also manage non-discretionary accounts. If engaged in a non-discretionary arrangement with our firm, we will discuss all transactions with you prior to execution or you will be required to make the trades if in an employer sponsored account. ITEM 17 - VOTING CLIENT SECURITIES Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitation. A class action is a procedural device used in litigation to determine the rights of and remedies, if any, for large numbers of people whose cases involve common questions of law and/or fact. Class action suits frequently arise against companies that publicly issue securities, including securities recommended by investment advisors to clients. With respect to class action suits and claims, you (or your agent) will have the responsibility for class actions or bankruptcies, involving securities purchased for or held in your account. We do not provide such services and are not obligated to forward copies of class action notices we may receive to you or your agents. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 30  ITEM 18 – FINANCIAL INFORMATION We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. PRIVACY POLICY Our Firm collects nonpublic personal information about Clients from information provided on applications or other forms, as well as from information regarding Client transactions with our Firm, our affiliates, or others. In accordance with Regulation S-P, our Firm does not disclose any nonpublic personal information about current or former Clients to third parties, except as permitted or required by law, or as necessary to service Client accounts. Access to Client information is restricted to Firm personnel who require such information to provide investment advisory services. Our Firm maintains physical, electronic, and procedural safeguards designed to protect Client information in compliance with federal standards and Regulation S-P. Our Firm provides a copy of its Privacy Policy to Clients at the time of account opening, upon request, and annually if the Policy is amended. STEELE STREET PRIVATE WEALTH MANAGEMENT 50 South Steele Street, Suite 501, Denver, Colorado 80209 FORM ADV 2A Brochure 31