We are a federally registered investment advisor specializing in the following types of services: asset management, financial planning and consulting, referrals to independent money managers. Our total assets under management as of December 31, 2023 are approximately $375,344,000 on a discretionary basis, and $30,074,000 on a non-discretionary basis. Description of our advisory firm, including how long we have been in business and our principal owner(s). We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed in the State of California. Our firm has been in business as a registered investment adviser since 2011 and is owned as follows: Richard Schuette – 80% Owner Kathryn Courain – 10% Owner Peter Madlem – 10% Owner A. Description of the types of advisory services we offer. (i) Asset Management: We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. We utilize Independent Money Managers, where we may design an investment portfolio and provide ongoing corresponding asset management services on a fee-only basis for a percentage of assets in conjunction with another investment advisory firm. Before selecting other advisers, we make sure that the other advisers are properly licensed or registered. We offer an automated program that is an online investment platform to assist clients in meeting their savings and retirement goals. The online investment platform will provide the following: 1. Risk assessment for client to determine appropriate investment model for their goal(s). 2. Portfolio rebalancing at least quarterly. 3. Online planning tools for savings and retirement goals. 4. Access to a financial advisor at Avalan for up to one hour per year. (ii) Financial Planning and Consulting: We provide a variety of financial planning and consulting services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or

consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. We disclose that: (a) a conflict exists between our interests and the interests of our client, (b) our client is under no obligation to act upon our recommendation, and (c) if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through our firm. (iii) Private Funds / Limited Partnerships Currently, one of Avalan’s clients is a Private Fund (Avalan Opportunity Fund I, LLC). This LLC was formed for the purpose of purchasing a 10% interest in a Master General Insurance Agency Limited Liability Company. . All Funds are sold via the Funds’ Governing Documents. Please refer to the Governing Documents of the Funds for complete information about the fees, risks, strategies, expenses, legal and regulatory disclosures and other important information about the Funds. Discretionary Distributions. To the extent the Managers determines in its sole discretion that there is sufficient distributable cash, the Company anticipates that distributions will be made on an annual basis as follows: (i) First, distributable cash shall be distributed to the Members until each of the Members shall have received from aggregate distributions of distributable cash an amount equal to such Member's respective unreturned capital contributions; and (ii) Thereafter, any remaining distributable cash shall be distributed to the 80% to the Members, pro rata in accordance with each Member's respective Shares in relation to the aggregate Shares of all Members and 20% to the Manager. We disclose that: (a) a conflict exists between our interests and the interests of our client, (b) Rich Schuette and Kathryn Courain, both executives of Avalan, LLC are also owners of Avalan Opportunity Fund Class B shares. B. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients, whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to clients utilizing the following services offered by our firm: Asset Management. Additionally, we offer general investment advice to clients utilizing the following services offered by our firm: Financial Planning and Consulting and Portfolio Monitoring. (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their account. In the rare instance that we would allow restrictions, it would be limited to the following services: Asset Management. We do not manage assets through our other services. C. Participation in wrap fee programs. We do not offer wrap fee programs. D. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.