STOKER OSTLER WEALTH ADVISORS, INC.

Item 1 – Cover Page Stoker Ostler Wealth Advisors Inc. 4900 N Scottsdale Road, Suite 2600 Scottsdale, AZ 85251 (480) 890 8088 www.stokerostler.com ‐ Adviser Brochure (Part 2A of Form ADV) October 20, 2025 This brochure provides information about the qualifications and business practices of Stoker Ostler Wealth Advisors Inc. If you have any questions about the contents of this brochure, please call us at (480) 890 8088. ‐ 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. Additional information about Stoker Ostler Wealth Advisors Inc. is also available on the SEC’s website at http://www.adviserinfo.sec.gov/. Our CRD number is 111320. Stoker Ostler Wealth Advisors Inc. is a registered investment adviser. Registration of an adviser with the SEC does not imply a certain level of skill or training.  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 2 – Material Changes There have been no material changes to our brochure since our last update dated September 23, 2025. 2  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 3 – Table of Contents - Item 1 – Cover Page....................................................................................................... 1 Material Changes ……………………………………………………………………………………….…… 2 Item 2 Item 3 – Table of Contents ............................................................................................. 3 Item 4 – Advisory Business ............................................................................................ 4 Item 5 – Fees and Compensation ................................................................................... 6 Item 6 – Performance-Based Fees and Side-By-Side Management .................................. 8 Item 7 – Types of Clients ................................................................................................ 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................... 10 Item 9 – Disciplinary Information ................................................................................. 15 Item 10 – Other Financial Industry Activities and Affiliations ........................................ 16 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading................................................................................................................. 17 Item 12 – Brokerage Practices ..................................................................................... 19 Item 13 – Review of Accounts ...................................................................................... 21 Item 14 – Client Referrals and Other Compensation ..................................................... 22 Item 15 – Custody ....................................................................................................... 24 Item 16 – Investment Discretion .................................................................................. 25 Item 17 – Voting Client Securities ................................................................................ 26 Item 18 – Financial Information ................................................................................... 27 Additional Information ................................................................................................ 28 3  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 4 – Advisory Business owned subsidiary of BMO Financial Corp., a wholly owned Stoker Ostler Wealth Advisors, Inc. (referred to as “Stoker Ostler,” “our,” “us,” “we”) was formed as Private Wealth Management Inc., in June 1997. Our principal place of business is in Scottsdale, Arizona. We are a wholly subsidiary of Bank of Montreal (“BMO”). ‐ ‐ We operate under our legal name, Stoker Ostler Wealth Advisors, Inc., as well as under the brand name “BMO Wealth Management” and “BMO Private Wealth.” This brand is discussed more fully in Item 10 “Other Financial Industry Activities and Affiliations.” We offer investment management, financial planning, and consulting services to high net- worth individuals, trusts, estates, charitable organizations, and other entities. Investment Management We provide discretionary and non-discretionary investment management services based on the individual needs of our clients. We develop a personalized Investment Policy Statement (“IPS”) based on data that we gather through personal discussions with our clients. During these discussions, we determine clients’ individual goals and objectives, investment time horizon, risk tolerance, asset allocation targets, investment guidelines, and liquidity needs. Clients can also impose reasonable restrictions for investing in certain securities or types of securities. We then build a customized and diversified portfolio that meets the parameters outlined in the IPS. We generally recommend that clients allocate investments among various asset classes. Asset classes include fixed income, domestic and international equities, real estate investment trusts, and alternative investments. Within these asset classes, we generally recommend that clients allocate investments among various issuers and types of issuers. Client funds are deposited with a custodian. Depending on the breadth of our investment management authority, we select investment funds and purchase and sell securities. When we provide investment advice to clients regarding client retirement plan accounts or individual retirement accounts (IRAs or Roth IRAs), we are 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. The way we make money creates some conflicts with clients’ interests, so we operate under a special rule that requires us to act in clients’ best interest and not put our interests ahead of clients’ interests. Financial Planning and Consulting We also provide financial planning and consulting services to clients. We gather information about clients’ current financial status and tax status, future goals, return objectives, and risk tolerance. We carefully review documents supplied by clients, and prepare financial reports designed to help clients achieve their financial goals and objectives. When requested we can recommend the services of other professionals, such as attorneys or accountants. Our clients retain discretion over any implementation decisions and are free to accept or reject any of our recommendations. 4  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Wrap Fee Disclosure Stoker Ostler does not participate in or sponsor any wrap fee programs. Assets under Management As of December 31, 2024, we had approximately $2.99 billion of discretionary assets under management and approximately $105.5 million of non discretionary assets under management. ‐ 5  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 5 – Fees and Compensation Investment Management Our standard fees are based on a specified annual percentage rate of the client’s assets under management. Our standard fees are listed below. However, our fees are negotiable and will vary. Further, previous fee schedules are still in effect for some clients. These previous fee schedules include fees that are higher and lower than the current fee schedule. Current fee schedule (billable on total assets under management): 1% on the first $3 million 0.85% on the next $2 million 0.65% on the next $5 million 0.55% on assets above $10 million Each agreement for investment advisory services contains the effective fee schedule. Our fees are prorated and paid monthly, in arrears, and are based on the market value of the assets on the last business day of the previous month. After fees are calculated, they are rounded to the nearest dollar. Negative cash balances (margin) will not be deducted from the value of clients’ billable assets and therefore included in the calculation of the advisory fee paid to us. Most commonly, fees are debited directly from the client’s account. However, with special approval, the clients are invoiced directly. A client agreement can be terminated by either party for any reason by written notice. If a client terminates their client agreement, the client is still obligated to pay advisory fees prorated through the date of termination. Financial Planning and Consulting For clients receiving investment management services, most ongoing financial planning and consulting services are included in the investment management fees. However, we will charge investment management clients for extraordinary financial planning or consulting services in certain circumstances. We will provide written notice to the client in these situations. We typically charge hourly fees to non-investment management clients for financial planning and consulting services and to investment management clients for extraordinary financial planning and consulting services. Fees charged will depend on the level and scope of the services required and the professionals rendering these services. Hourly fees will generally range from $250 to $400 per hour plus any expenses incurred. We bill hourly fees monthly in arrears. If the circumstances warrant, we charge a fixed fee for financial planning and consulting services. lot differentials, transfer taxes, wire transfer and fund level charges, odd ‐ Other Fees Clients will incur charges from custodians, broker-dealers, and other third parties including custodial fees, mutual electronic funds fees, and other fees and taxes on brokerage accounts and securities ‐ transactions. Mutual funds, closed-end funds, and exchange-traded funds also charge internal management fees, which are disclosed in each fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fees. We do not receive any portion of these charges, fees, or commissions. 6  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A We select and recommend mutual fund share classes that are available to the client and in the client’s best interest. In most cases, this means the lowest expense share class in which the client qualifies to invest. We can negotiate with the fund to gain access to lower fee share classes for the benefit of clients. For example, for clients that would normally only have access to investor share classes with higher fees, we attempt to negotiate access to institutional share classes (or equivalents) that have a lower expense ratio. However, we are not always successful in negotiating institutional share class access for all our clients. Access to institutional or equivalent share classes are not available to all clients. Client access will be limited to investor or higher fee classes if the client cannot meet the minimum fund investment level for a lower fee share class, the lower fee share class is not available on the client’s investment platform, or if there are other requirements of the specific share class that the client does not meet. We will still recommend an investment in such a fund if the available share class is in the client’s best interest. In making this determination, we will consider, among other things, whether the investment is not available in an institutional share class or other no load option, offers the best fee for clients in situations where an institutional share class is not ‐ available, and charges fees that are reasonable given the fund’s strategy and other factors. Please refer to Item 12—Brokerage Practices which further describes the factors that we consider in selecting or recommending custodians or broker dealers for client transactions. ‐ 7  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 6 – Performance-Based Fees and Side-By-Side Management based fees (fees based on a share of capital gains on, or We do not charge any performance capital appreciation of, the client’s assets). ‐ 8  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 7 – Types of Clients We provide investment management services to the following types of clients: charitable organizations • high net-worth individuals • trusts • estates • • other entities Our account minimum is typically $500,000. However, we can choose to reduce the account minimum based on certain criteria. These criteria include anticipated future earnings capacity, anticipated future additional assets, assets to be managed, related accounts, account composition, and negotiations with clients. 9  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Investment products are not insured by the FDIC, have no bank guarantee, and may lose value. We make no guarantee or representation of performance. Past performance is not indicative of future results. Methods of Analysis We meet with each client to determine their unique portfolio objectives and wealth management needs. Through this process, we work with the client to develop an appropriate ratio of investments by asset class suitable to the client’s investment goals and risk tolerance. Currently, we allocate client investment assets primarily among individual securities. We maintain working lists of securities that we select for use in client portfolios, and we conduct and document investment due diligence on the working lists. Reviews of securities included on the working lists include both qualitative and quantitative factors. We also utilize working lists or other research provided by several of our affiliates to identify securities that we are allowed to recommend to our clients. We review the securities on these working lists to identify and avoid any securities that pose potential conflicts of interest. We also perform investment due diligence on these securities before approving them for potential recommendation to our clients, which likely include consideration of research and other information provided by our affiliates. Our securities analysis methods rely on the assumption that the issuers of the securities we recommend, the rating agencies that review these securities, and other publicly available sources of information about these securities are providing accurate and unbiased data. While we are alert to any indications that data could be incorrect, there is always a risk that our analysis could be compromised by inaccurate or misleading information. ‐ We attempt to offset this risk by reviewing and rebalancing each client’s portfolio as outlined in moving nature of the markets, unanticipated new risks the IPS. Because of the dynamic and fast can arise at any time. Maintaining a highly diversified investment portfolio helps to offset these types of risks but cannot eliminate them altogether. Individual Securities: While we do not focus primarily on individual securities, we do recommend and purchase individual securities, both equities and fixed income, to achieve optimal asset allocation for our clients. Individual securities expose our clients to certain risks. The prices of securities held in client accounts and the income they generate could decline in response to local and global events. These events often affect the issuers of the securities, the general economy, and the financial markets. Other factors affecting individual securities include local, regional, or global political, social, or economic instability and governmental or governmental agency responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations also affect security prices. 10  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Individual Equity Securities – Common stocks are the most common individual equity securities we recommend and purchase for our clients. Common stocks represent an ownership interest in a company. The prices of common stocks and the income they generate fluctuate based on events specific to the issuing company, conditions affecting the general economy, overall market changes, changes or weakness in applicable business sectors, and other factors. Fixed Income Securities – Investment-grade corporate bonds and municipal bonds are the most common fixed income investments we recommend and purchase for our clients. Prices of fixed income securities rise and fall in response to changes in the applicable interest rates. Generally, when interest rates rise, prices of fixed income securities fall. Changes in a fixed income security’s value usually will not affect the amount of interest income paid. Interest rate changes have a greater effect on the price of fixed income securities with longer maturities. Fixed income investments have a stated maturity date when the issuer must repay the principal amount. Some fixed income securities, known as callable bonds, are allowed to repay the principal earlier than the stated maturity date. Bonds are most likely to be called when interest rates are falling because the issuer can refinance at a lower rate. The credit rating or financial condition of an issuer often affects the value of a bond. Generally, a lower quality rating for a bond means there is a greater risk that the issuer will fail to pay interest fully and return principal in a timely manner. The issuer of an investment-grade bond is more likely to pay interest and repay principal than an issuer of a lower rated bond. Credit ratings are not an absolute standard of quality, but rather general indicators that reflect only the rating agency’s view. If an issuer defaults or becomes unable to honor its financial obligations, the bond is likely to lose some or all its value. Municipal Bonds – Municipal bonds are subject to risks based on many factors, including economic and regulatory developments, changes or proposed changes in the federal and state tax structure, deregulation, court rulings and other factors. The value of municipal securities is affected more by supply and demand factors or the creditworthiness of the issuer than by market interest rates. Repayment of municipal securities depends on the ability of the issuer or project backing such securities to generate taxes or revenues. There is also a risk that the interest on an otherwise tax- exempt municipal bond could also be subject to federal income tax. Mutual Funds and Exchange Traded Funds – We look at the experience and performance record of the fund manager to determine if the manager of a mutual fund or exchange traded fund (“ETF”) has demonstrated an ability to invest successfully over a period of time and in different economic conditions. We also look at whether the fund has no load or low load features, the fund’s return, and the fund’s cost efficiency. ‐ ‐ A risk of investing in mutual funds and ETFs is that a manager who has been successful might not be able to replicate that success in the future. The risk and value of a mutual fund or ETF investment is directly related to the risk and value of the securities invested in by the fund. Fund investors rely on the fund manager to make investment decisions for the fund as neither we nor the investor can direct the underlying investments in a mutual fund or ETF. Managers of different funds held by a single client could purchase 11  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager deviates from the stated investment mandate or strategy of the mutual fund or ETF, which could make the holding less suitable for the client’s portfolio. Closed-End Interval Funds – An interval fund is a type of closed-end fund that periodically (every three, six, or twelve months as disclosed in the fund’s prospectus and annual report) offers to repurchase its shares from shareholders at a price based on net asset value. Interval funds differ from traditional closed-end funds in that shares typically do not trade on the secondary market. Shareholders are not required to accept interval fund repurchase offers. However, these periodic repurchase offers are constraints on liquidity. There is no assurance that an investor will be able to sell shares of the interval fund when or in the amount desired, and the fund has the right to suspend or postpone repurchases. Interval funds share many of the same risks as other closed-end funds and mutual funds. In addition to these risks, interval funds often have liquidity constraints that result from the lack of a secondary market and the fact that repurchase offers are only made periodically. Because of these potential liquidity constraints, interval funds might not be appropriate for investors with a short-term investment horizon. Our portfolio managers evaluate the suitability of interval funds relative to the client’s investment strategy and time horizon as captured in the client’s IPS. Real Estate Investment Trusts – We could recommend the inclusion of Real Estate Investment Trusts (REITs) in some of our client’s accounts, when appropriate. REITs allow individuals to invest in large-scale, income-producing real estate and provide a way for individual investors to earn a share of the income produced through commercial real estate ownership. A REIT is a company that owns and typically operates income-producing real estate or related assets. REITs are subject to risks similar to those associated with direct ownership of real estate which include, but are not limited to, economic conditions, declines in real estate values, changes in government regulations, increases in interest rates, property taxes and defaults by borrowers. In addition, due to their concentration in the real estate industry, REIT portfolios are riskier and more volatile than a portfolio of common stocks that is not concentrated in a particular industry. REITs offer many features, benefits and risks that are unique. Clients will bear, in addition to the Program Fee, a proportionate share of any fees and expenses associated with ETFs and REITs in which their assets are invested. Selecting strategies that use these types of investments causes the client to incur these additional fees and expenses on assets the client designates for management according to such strategy. These fees and expenses include investment advisory, management, administrative, distribution, transfer agent, custodial, legal, audit and other customary fees and expenses. Alternative Investments – An alternative investment is a financial asset that does not fall into one of the conventional investment categories. Conventional categories 12  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A include stocks, bonds, and cash. Since alternative investments is a very broad description can include investments like private equity or venture capital, hedge funds, managed futures, commodities, and derivatives contracts. As with any other investment type, alternative investment strategies present a significant number of risks. Some of the key risks, include illiquidity, volatility, and complexity. We encourage investors to ask questions to ensure that they fully understand what types of specific alternatives are being considered for use in their accounts and the specific risks involved to allow you determine if an investment strategy is appropriate for your circumstances. Investment Strategies Our investment advice is based on several factors, including, but not limited to, the client’s investment objectives, risk tolerance, tax positions and objectives, asset class preferences, time horizons, liquidity needs, and expected returns. Our investment advice is also based on an assessment of current economic and market views expressed by economic analysts, banks and securities firms. As stated in Item 4—Advisory Business, we will develop the client’s IPS based on these factors. The IPS outlines recommended investment allocations among various asset classes and prepares a proposed asset allocation plan appropriate for that profile. A risk of this asset allocation approach is that the client might not participate in sharp increases in a particular security, industry, or market sector. In addition, there is a risk that the ratio of investments by asset class will change materially over time due to market movements. In this case, we will rebalance the asset allocation to be consistent with client’s goals. term (one year or more) due to preferential tax ‐ We utilize a variety of investment strategies, taking into consideration the client’s best interest. Ideally, we prefer to hold investments long treatment in taxable accounts. However, we sometimes hold investments for shorter periods of time depending on the security, market environment, and economic conditions. term investment strategy is that we could miss taking advantage of short term ‐ ‐ term investment strategy is more frequent related costs. In ‐ A risk in a long gains that could be profitable to a client. Moreover, a security could decline sharply in value before we make the decision to sell. A risk in a short trading, which results in an increase in brokerage and other transaction addition, short term capital gains typically receive less favorable tax treatment. ‐ ‐ In taxable accounts we try to offset realized gains with realized losses. When market declines occur, we often “harvest” losses to be used to offset future gains. Using these strategies could increase a client’s after tax rate of return. ‐ Other investment strategies we are allowed to use include short sales, margin transactions and option trading. However, these are used rarely or at the request of our clients. The risk of using these types of strategies is disclosed, in writing, and we require clients to sign additional custodial forms prior to implementation. Risks of Loss As mentioned above, regardless of the strategy or analysis used, all investments carry the risk of loss including the loss of principal invested. Some risks could be avoided or mitigated, while 13  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A others are completely unavoidable. Some common risks you should consider prior to investing include, but are not limited to the following: Cybersecurity Risks – Cybersecurity is the process of defending Stoker Ostler by identifying risks and leveraging intelligence to direct operations in order to protect against, detect, respond to and recover from cyber-attacks. A cybersecurity breach could result in the loss of theft of customer data or funds, the inability to access electronic systems (“denial of services”), loss or theft of proprietary information or corporate data, physical damage to computer or network systems, or costs associated with system repairs. Such incidents could cause the advisor or other service providers to incur regulatory penalties, reputational damage, additional compliance costs or financial losses. We use BMO Bank Corporate Security to provide cybersecurity for the purpose of protecting our customers, employees and business from cybersecurity breaches. Legal, Regulatory and Tax Risks – Client investments could be adversely impacted by legal, regulatory and tax changes that could occur in the future. New and existing regulations, changing regulatory schemes and the burdens of regulatory compliance all could have a material negative impact on investment performance. Political, Social and Economic Uncertainty – Social, political, economic, and other conditions and events (such as natural disasters, epidemics and pandemics, terrorism, conflicts, and social unrest) will occur that create uncertainty and have significant impacts on industries, governments, and other systems, including the financial markets, to which clients are exposed. As global systems, economies and financial markets are increasingly interconnected, events that once had only local impact are now more likely to have regional or even global effects. Events that occur in one country, region or financial market will, more frequently, adversely impact those in other countries, regions, or markets, including in established markets such as the United States. There can be no assurance that such events will not cause clients to suffer losses and/or negatively impact returns. 14  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 9 – Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. We have no reportable disciplinary events to disclose. 15  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 10 – Other Financial Industry Activities and Affiliations dealer or We have no management persons registered or applying for registration as a broker dealer. registered representative of a broker ‐ ‐ We have no management persons registered or applying for registration as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the forgoing entities. We are one of several related parties operating under the BMO Wealth Management and BMO Private Wealth brands. “BMO Wealth Management” is a brand delivering investment management services, trust, deposit and loan products and services through BMO Bank N.A. , a national bank with trust powers (“BMO Bank”); family office services and investment advisory services through BMO Family Office, LLC, an SEC-registered investment adviser (“BMOFO”); investment advisory services through Stoker Ostler Wealth Advisors, Inc., an SEC-registered investment advisor; and trust and investment management services through BMO Delaware Trust Company, a Delaware limited purpose trust company (“BDTC”). “BMO Private Wealth” is a brand name used by BMO entities providing wealth management products and services in the United States and Canada. It includes the entities operating under the BMO Wealth Management brand name in the United States. These entities are all affiliates and owned by BMO Financial Corp., a wholly-owned subsidiary of BMO. BMO Wealth Management brand products and services are not available in every state or location. It is possible that BMO Bank, BMOFO, and BDTC recommends, purchases, or sells for their clients the same securities we recommend, purchase, or sell for our clients. It is possible that other related parties recommend, purchase, or sell the same funds or securities, thus sharing in the profits and losses of those funds or securities. We have common management and officers with some of our affiliates. We rely on BMO and BMO Financial Corp. for various administrative support, including information technology, human resources, business continuity, compliance and legal, finance, enterprise risk management, and internal audit. Our affiliates also provide investment research and other services which we use in servicing our clients, including the working lists and research described in Item 8—Methods of Analysis, Investment Strategies and Risk of Loss. While these affiliations can create potential conflicts of interest, we mitigate these potential conflicts of interest through our corporate governance structure and by maintaining policies and procedures to identify, mitigate, and disclose any actual or potential conflict of interest. We do not recommend to our clients any investments in which we or a related person have a proprietary interest. Our related persons are specifically disclosed in Section 7.A on Schedule D of Form ADV, Part 1, which can be accessed by following the directions provided on the Cover Page of this brochure. 16  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We have adopted BMO Wealth Management US Unified Code of Ethics (as supplemented by our Compliance Manual and other applicable policies and procedures, the “Code”) that describe our standards of business conduct, fiduciary duty to our clients, and the restrictions and reporting requirements for our employees’ personal investments. Our employees are subject to the Code and must acknowledge the terms of the Code annually or as it is amended. Employees are instructed to place the interests of our clients first, conduct all their personal securities transactions in a manner consistent with the Code, and not take advantage of their positions. The Code is intended to promote the highest standards of ethical and professional conduct. Among other terms, the Code contains provisions prohibiting fraudulent conduct, market manipulation, and trading based on material non-public information. The Code contains our requirements regarding the confidentiality of client information and provisions dealing with gifts and entertainment. As a fiduciary to our advisory clients, we owe those clients a duty of loyalty. We always act in utmost good faith, placing our clients’ interests first and foremost, while making full and fair disclosure of all material facts. This is especially true in cases of actual or potential conflicts of interest. We recognize that independence in the investment decision-making process is vital. The Code strictly prohibits action taken or avoided for the purpose of achieving a personal benefit rather than a client benefit. clearance of certain personal securities ‐ Our firm and our employees will sometimes buy and sell securities identical to or different from those recommended to our clients for their personal accounts. It is possible that our affiliates recommend, purchase, sell, or have a position or interest in securities that we recommend, purchase, or sell for our clients. While these factors create possibilities that our firm, our employees, or our affiliates will share in the profit or losses of securities held by our clients, we believe our policies, procedures, and controls, as well as those of our affiliates, are reasonably designed to ensure that any actual or potential conflicts of interest are addressed appropriately. The Code requires that our employees obtain pre transactions, including any acquisition of securities in a limited offering. Employees are restricted from acquiring any security distributed in an initial public offering until trading of the security commences in the secondary market. The Code also requires that our employees’ trading be continually monitored to reasonably prevent conflicts of interest with our clients. Our clients or prospective clients can request a copy of our Code by calling Lee Ann Reitz at (480) 890 8088 or emailing her at LeeAnn.Reitz@stokerostler.com. ‐ We do not effect principal or agency cross securities transactions for client accounts or cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker dealer, buys from or sells any security to any advisory client. A principal transaction could also ‐ be deemed to have occurred if a security trades between an affiliated fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in a transaction in which the investment adviser or its affiliate acts as broker- 17  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A dealer or has an affiliated broker dealer for both parties to a securities transaction. Agency cross transactions can arise where an adviser is dually registered as a broker registered as a broker dealer, and we do not use an affiliated broker dealer. We are not dealer for client trades. ‐ ‐ ‐ ‐ 18  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 12 – Brokerage Practices Our clients, regardless of their advisory relationship, are under no obligation to use any of our affiliated entities to provide brokerage services or act as custodian of assets. While a client can decide to select an affiliated entity to provide such services, we would not receive compensation resulting from the client’s decision to utilize the affiliate’s services. For clients in need of brokerage or custodial services, we recommend that clients establish accounts with the following broker-dealers to maintain custody of their assets and to effect trades for their accounts: • Schwab Advisor Services (“Schwab”), division of Charles Schwab & Company, Inc., an independent and unaffiliated registered broker dealer and FINRA member; • National Financial Services, Inc. (“Fidelity”), an independent and unaffiliated registered ‐ broker dealer and FINRA member; and ‐ When recommending or selecting a broker-dealer for any transaction or series of transactions, we are under a duty to seek the best qualitative execution for the client’s account. We consider many factors including, without limitation, the broker-dealer’s commission rate, convenience, execution capabilities and quality, clearance and settlement capabilities, our experience with the broker-dealer, reputation, error resolution, back- office efficiency, research services, and financial stability. We endeavor to select broker-dealers with transaction fees that are reasonable in relation to the value of the brokerage and overall service. Schwab’s and Fidelity’s services generally are available to independent investment advisors on an unsolicited basis at no charge to them. These services are not contingent upon our firm committing to these custodians any specific amount of business. These custodians’ brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab and Fidelity provide us with access to institutional trading and custody services which are typically not available to retail investors. They can provide products and services that assist us in managing and administering clientsʹ accounts, including software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing, and other market data; (iv) facilitate payment of our fees from its clientsʹ accounts; and (v) assist with back office functions, recordkeeping and client reporting. ‐ party vendors for the ‐ Schwab and Fidelity also offer other services intended to help us manage and further develop our business enterprise. These services often include: (i) compliance, legal, and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants, and insurance providers. Schwab and Fidelity make available, arrange, and pay third types of services rendered to us. They are allowed to discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third party ‐ 19  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A providing these services to our firm. They also provide other benefits such as educational events or occasional business entertainment for our personnel. In evaluating whether to recommend Schwab or Fidelity we consider the availability of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely the nature, cost, or quality of custody and brokerage services. This creates a potential conflict of interest. dealer with whom we have contracted for prime brokerage clearing services. Certain When beneficial to the client, individual fixed income transactions are effected through a broker account minimums apply for a client to be eligible for prime brokerage services. ‐ Client Referrals Neither we, nor any of our principals or associated persons receive any portion of the brokerage commissions or transactions fees charged to clients. As noted in Item 14—Client Referrals and Other Compensation, we participate in the Schwab Advisor Network® referral program. Schwab also provides client referrals to us; however, we are under no obligation to, and do not, direct trades to Schwab in return for client referrals. Aggregated Trades As a matter of policy and practice, we do not generally aggregate client trades; we implement client transactions separately for each account. Consequently, certain client trades are executed before others at a different price or commission rate. Additionally, our clients might not receive volume discounts available to advisers who aggregate client trades. 20  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 13 – Review of Accounts Investment Management Client portfolios are reviewed at least annually and rebalanced to the investment objective found in the client’s IPS. In reviewing a client’s portfolio, we assess diversification by asset class, and compare the portfolio with the investment strategy in the IPS. The annual review form is completed by Operations and reviewed by the assigned portfolio manager. If the review results in action items, the assigned portfolio manager is responsible to address the action items. We provide an inventory of assets showing market value and cost of each security to each client on at least an annual basis unless directed otherwise by the client. The custodian provides detailed transactions and holdings at least quarterly. We calculate and provide portfolio performance information to clients on at least an annual basis, unless directed otherwise by the client. Financial Planning and Consulting Our financial planning and consulting clients receive a Retirement Model which includes financial objectives and a net worth statement. We provide and update additional analyses and reports as needed and requested by the client. We review and update Retirement Models as necessary. Reviews are conducted by either the portfolio manager or a dedicated financial planner, and sometimes both. More comprehensive financial planning reviews are done at the client’s request, if the client relocates to a new state or country, or if the client’s estate planning documents are outdated. In these cases, we typically recommend the client review and update those documents with their attorney. 21  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 14 – Client Referrals and Other Compensation Our referral agreements comply with Rule 206(4)-1 under the Investment Advisers Act of 1940 as applicable. Referral payments are made at our expense solely and do not result in additional fees to our advisory clients. Referral fees are based on a percentage or portion of the advisory fees we earn or on the dollar amount of the self-reported investable assets of a referral or matched client that originates from a lead-matching service. We receive client referrals from Schwab through our participation in Schwab Advisor Network® (the “Service”) mentioned in Item 12 – Brokerage Practices. We pay Schwab a referral fee (“Participation Fee”) quarterly at an annualized rate of 0.1050% to 0.2625% of the average daily total assets we manage for each client referred to us through the Service, subject to a minimum Participation Fee. Different fee schedules exist for previously referred Schwab clients. Under these previous Schwab referral fee schedules, we pay Schwab a Participation Fee equal to 15% of the amount collected from referred clients during the previous quarter. The Service is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with us. Schwab does not supervise us and has no responsibility for our management other advice or services to our clients. We pay Schwab a Participation Fee on all referred clients’ accounts that are maintained in custody at Schwab and a Non-Schwab Custody Fee on all accounts that are maintained at, or transferred to, another custodian. We pay Schwab the Participation Fee for so long as the referred client’s account remains in custody at Schwab. The Participation Fee is billed to us quarterly and can be increased, decreased, or waived by Schwab from time to time. The Participation Fee is paid by us and not by the client. We do not charge clients referred through the Service fees or costs greater than the fees or costs we charge clients with similar portfolios who were not referred through the Service. We pay Schwab a Non-Schwab Custody Fee if custody of a referred client’s account is not maintained by, or assets in the account are transferred from Schwab. This fee does not apply if the client was solely responsible for the decision to maintain custody outside of Schwab. The Non-Schwab Custody Fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. The Non-Schwab Custody Fee is higher than the Participation Fees we generally would pay in a single year. Thus, we have an incentive to recommend that client accounts be held in custody at Schwab. The Participation and Non-Schwab Custody Fees will be based on assets in accounts of our clients who were referred by Schwab and those referred clients’ family members living in the same household. Accordingly, we have an incentive to encourage household members of clients referred through the Service to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit our fees directly from the accounts. For accounts of our clients maintained in custody at Schwab, Schwab does not charge the client separately for custody but receives compensation from our clients in the form of commissions or other transaction-related compensation on trades executed through Schwab. Schwab also receives fees (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. 22  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker- dealer’s fees. Thus, we have an incentive to cause trades to be executed through Schwab rather than another broker-dealer. We nevertheless seek best execution of trades for client accounts. Trades for client accounts held in custody at Schwab can be executed through a different broker-dealer than trades for our other clients. Accordingly, trades for accounts custodied at Schwab can sometimes be executed at different times and different prices than trades for other accounts that are executed at other broker-dealers. Different fee schedules exist for previously referred clients. We also receive client referrals from SmartAsset Advisors, LLC (“SmartAsset”), through SmartAsset’s proprietary lead-matching process (“Leads Service”). The Leads Service is designed to match investors based on specific criteria selected by the investors and us, which includes geography, minimum asset requirements, and types of services offered and desired. We pay SmartAsset a set amount for each matched lead (“Contracted lead Fee”). The Contracted Lead Fee is paid by us and not the investor and is based on the self-reported investable assets such matched investor has convey to SmartAsset. SmartAsset is a registered investment advisor independent of and unaffiliated with us. SmartAsset does not supervise us and has no responsibility for our management or services to our clients. We enter into referral agreements with and make payments to our affiliates’ employees for client referrals. Similarly, our employees enter into referral agreements with our affiliates and receive payment for client referrals or otherwise marketing products and services of those affiliates. Certain employees of Stoker Ostler or our affiliates will be compensated for client referrals which could include the introduction of new clients or the retention of existing clients. This compensation is paid directly or through a discretionary bonus. Our Portfolio Managers are paid a base salary and have potential to earn additional compensation based on a percentage of fees collected from the accounts they manage. We do not charge you additional fees to pay the Portfolio Managers. The more assets in your advisory account, the more we will make in fees. We do not receive any compensation for the specific investments used in your portfolios. 23  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 15 – Custody We are deemed to have custody of clients’ funds or securities when the clients authorize us to deduct our management fees directly from clients’ accounts. We are also deemed to have custody of clients’ funds or securities when clients have a standing letter of authorization (“SLOA”) with their custodian to allow us to move money from clients’ accounts to a third-party and designate the amount or timing of transfers with the custodian. All client assets are held at unaffiliated qualified custodians. Clients sign an account application with a custodian upon opening their investment advisory account with us. The custodian will notify us of the custody account number and other pertinent information. At least quarterly, clients should receive statements directly from the qualified custodian that holds and maintains their investment assets. We urge clients to carefully review such statements and compare the custodian’s statements to the reports that we provide. In some situations, our reports vary from the custodian’s statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. As is stated in Item 12—Brokerage Services, our clients are under no obligation to use any of our affiliated entities to provide custodial services. If a client selects an affiliated entity to provide custodial services, we do not receive any compensation based upon the client’s selection and use of the affiliated entity’s custodial services. 24  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 16 – Investment Discretion We have discretionary authority to manage securities accounts on behalf of our clients. Discretionary authority includes the authority to select securities to buy or sell, the number of securities to buy or sell, and the timing of the purchase or sale. We exercise investment discretion in accordance with the investment objectives for each client account. If the client imposes any investment restrictions and we agree to them, these supersede our investment discretion. discretionary accounts will be limited and Under the terms of our standard investment advisory agreement and the custodian account agreements, clients grant us a limited power of attorney with discretionary authority over their investments and have the right to limit this authority either under the IPS or by providing us with separate written instructions. Authority on non is based on the preferences selected on the account application. ‐ 25  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 17 – Voting Client Securities voting policies with certain of our affiliates (together and ‐ We have developed joint proxy individually, the “BMO Organization”). When acting as a fiduciary, the BMO Organization votes proxies in the sole interest of its fiduciary clients. Unless the client has directed otherwise, the BMO Organization generally votes proxies for securities held in client accounts and has adopted policies and procedures designed to help ensure that those proxies are voted in the best interests of fiduciary clients. The BMO Organization has contracted with Columbia Threadneedle Investment’s (“CTI”) Responsible Engagement Overlay (“REO”) team, a third party, to provide proxy voting services for the BMO Organization. The BMO Organization retains the ability to override all votes instructed by REO through read-write access on the voting platform. Through a Business Relationship Agreement with our affiliate, BMO Asset Management, Inc., we can instruct the BMO Organization to override votes directly on our behalf. The BMO Organization’s global proxy voting process is overseen by BMO Organization’s Responsible Investment (“RI”) Team. The RI team along with the Proxy Working Group (“PWG”) administer the global proxy voting framework including interaction with CTI’s REO. Stoker Ostler has representation on the PWG. The PWG consists of representatives of the BMO Organization and is the vehicle through which entities such as Stoker Ostler can escalate, override, or opine on proxy votes to ensure they are cast in the best interest of their respective clients. Clients can retain the right and obligation to vote any proxies relating to securities held in their account by providing written notice to us. Any changes to a client’s proxy voting instructions must be received in writing. Clients can obtain information regarding how we voted proxies for securities in their account, as well as our complete proxy voting policies and procedures, by calling Lee Ann Reitz at (480) 890 8088 or via email at LeeAnn.Reitz@stokerostler.com. ‐ 26  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Item 18 – Financial Information We are not required to include a balance sheet for our most recent fiscal year end because we do not require or solicit more than $1,200 in fees per client, six months or more in advance. We are not experiencing any financial condition that would impair our ability to meet contractual commitments to clients. Additionally, we have never been the subject of a bankruptcy petition. 27  Stoker Ostler Wealth Advisors Inc. Form ADV, Part 2A Additional Information Privacy Notice Our Privacy Notice, which includes information describing how a client’s information is shared with BMO, our affiliates and with others, is available by contacting us at (480) 890 8088 or by emailing Lee Ann Reitz at LeeAnn.Reitz@stokerostler.com. ‐ Money Laundering ‐ Anti To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person that establishes a relationship with the institution. When individual clients open an account with us, we will ask for their name, address, date of birth, and other information that will allow us to identify them. We will also ask clients to provide a copy of their driver’s license or other identifying documents, as needed. If the client is a corporation, partnership, trust or other legal entity, we will ask for other information, such as its principal place of business, local office, employer identification number, organizational documents, government-issued business license, partnership agreement, trust agreement, or other identifying documents. We will also ask for information identifying the control persons and beneficial owners of the entity. The information clients provide is used to verify clients’ identity by using internal sources and third-party vendors. If the requested information is not provided within thirty calendar days, we can suspend services to a client’s account. We are required, if requested, to disclose information collected under our anti-money laundering program pursuant to applicable laws, rules, or regulations. Otherwise, the information will be retained in confidence according to our Privacy Notice. 28