A. Firm Description Our firm is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a corporation formed under the laws of the State of Iowa. We have been in business as an investment adviser since 2009. Our firm is one hundred percent (100%) owned by Brian J. Nikulski, President and Chief Compliance Officer. The purpose of this Brochure is to disclose the conflicts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. Our firm provides comprehensive financial planning that includes asset management and investment consulting services for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance, income needs and financial goals. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process facilitates the kind of working relationship we value. B. Types of Advisory Services Asset Management: We emphasize continuous and regular account supervision based on our firm’s Investment Strategy. Our Investment Allocation Strategy primarily uses individual stocks, bonds, and ETFs. There are three risk bands that we create customized portfolios within: Moderately Conservative, Moderate, and Moderately Aggressive. A Risk Tolerance Questionnaire is completed to determine which risk band the client’s customized portfolio will be managed in accordance with. When appropriate, the Adviser may also incorporate covered options strategies and use closed end funds for income. We do not generally use mutual funds unless required by the client. Mutual funds may be incorporated when the asset class or strategy warrants it (i.e. Private Equity or Private Debt). Various quantitative trading systems will be used to generate investment decisions. The objective in this strategy is to balance protecting wealth and growing wealth based upon a client’s risk profile (as opposed to buying and holding investments through times of severe market depreciation). 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 annually and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals, risk tolerance and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Financial Planning & Consulting: Financial Planning and Consulting Services will be offered to all clients. For Financial Planning, we may investigate all nine of the services defined below to the extent applicable to the client and their respective needs, in order to create a detailed financial plan. Financial Consulting will include one or more of the services below or any other ad-hoc request made by a client, e.g., in-person meetings, video conferences or conference calls to discuss investment advice, meetings with other advisers, etc. These services may be engaged for a fixed fee or on an hourly basis, determined on a case-by- case basis as needs dictate. We and the client will work together to comply with relevant state statutes and rules and give the client investment advisory services at fair and reasonable rates that are determined on an equitable basis adequately disclosed to the client in writing. Our 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 financial planning engagements, we provide our clients with a summary of their financial situation and observations. For financial consulting engagements, we usually do not provide our clients with a 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, if 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. In general, Financial Planning and Consulting Services may include some or all of the following: 1. Cash Flow and Debt Management – This involves advice with respect to cash accounts, financial obligations, and cash management. 2. Risk Management and Insurance Planning – This includes risk management associated with advisory recommendations based on the combination of insurance types that best meet a client’s specific needs, e.g. life, health, disability, and long-term care, and others as appropriate. 3. Investment Planning – This involves advice with respect to asset selection and allocation, as well as investment income accumulation techniques. Evaluations are made of existing and, when applicable, potential

investments in terms of their economic and tax characteristics as well as their suitability for meeting the client’s objectives. Tax consequences and their implications are identified and evaluated in general terms. 4. Retirement Planning – This involves advice with respect to alternatives and techniques for accumulating wealth for retirement income or advice relative to appropriate distributions of assets following retirement. Tax consequences and their implications are identified and evaluated in general terms. 5. College Planning – This includes alternatives and strategies with respect to the complete or partial funding of college or other post-secondary education experience. Tax consequences and their implications are identified and evaluated in general terms. 6. Estate Planning – This service generally involves advice with respect to property ownership, distribution strategies, estate tax reduction, and tax payment techniques. It involves a discussion of gifts, trusts, etc. and the disposition of business interests. Tax consequences and their implications are identified and evaluated. At the request of the Client, Adviser will engage the client’s chosen personal estate attorney or planner, with regard to advising the wealth management of the estate planning. 7. Tax Planning – Tax planning services are referred to the client’s chosen personal tax advisor. Advisers may offer advice as to how tax laws may affect various financial decisions, e.g. acquisitions, pension strategy, investing in new opportunities or consolidation of existing investments, and individual taxation issues, among others. 8. Business Succession Planning – This includes alternatives and strategies with respect to continuity or disposition of the business upon the business owners’ retirement, death, disability, or decision to sell. Tax consequences and their implications are identified and evaluated. 9. Consolidation of Financial Situation – As a result of performing some or all of the services listed in points 1 through 9 above, Adviser may be able to recommend strategies or methods for consolidating the client’s financial situation in order for the client to manage their financial situation more easily and to obtain efficiency, cost savings, and diversification. 401(k) Management Services: Clients that are participating in this service work with their employer to determine if the advisor can have “third- party authorization” on the 401(k) account. This authorization allows for the advisor to manage the account on a discretionary basis inside the 401(k) but does not allow the advisor to make disbursements or change client information in the account. Depending upon the investment options available, the appropriate fee will be charged. Please refer to Item 5 ‘401(k) Management’ for further information on fees. Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment options, plan structure and participant education. Retirement Plan Consulting services typically include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs. (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointments to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. C. Tailoring of Advisory Services Our firm offers individualized investment advice to our Asset Management and 401(k) Management clients. General investment advice may be offered to our Financial Planning & Consulting clients. Each Asset Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. D. Wrap Fee Program Our Firm does not offer a Wrap Fee Program. E. Regulatory Assets Under Management We manage $305,541,790 on a discretionary basis as of 12/31/2023.