Overview Old Peak Finance is a registered investment advisor that helps individuals and families achieve their financial goals through comprehensive planning and wealth management. We seek to work with a variety of clients (“Clients”), including individuals, families, trusts, and estates. Our Clients may have different objectives, given their different stages of a financial life cycle. They may also have different risk profiles. Whatever these objectives (building a nest egg, paying for college, saving for retirement, or creating wealth for future generations) and risk profiles, we apply an objective approach to creating and implementing a financial plan appropriate to the Client. Old Peak is a fee-only advisor. We do not receive any income when a Client buys or sells a stock or other asset. We are only paid for our time. We believe this fee structure eliminates the conflicts of interest brokers, insurance agents and other financial professionals can have. Brokers generate fees if a client trades frequently and / or buys high-fee, often complex investment products. Insurance agents generate commissions if clients buy insurance products, particularly annuities or more complex whole or universal policies. Old Peak believes that if you trade less often and buy low-fee products, you increase your chances of building wealth. Old Peak is a fiduciary advisor. The fiduciary standard requires that we put our clients' interests above our own. We commit to disclose, clearly, to all clients, the fees we charge, and to avoid conflicts of interest. Old Peak Finance is registered with the US Securities and Exchange Commission (SEC) as an investment advisor. Old Peak will only transact business in those states in which it is registered, or in which we qualify for an exemption or exclusion from registration requirements. Rick Waechter founded Old Peak in 2010 to offer comprehensive, fee-only, independent financial advice with an emphasis on low-fee, evidence-based investment strategies. He believes this is the best approach to financial advice. Rick, a CERTIFIED FINANCIAL PLANNER™ professional and the sole owner of Old Peak, has over 25 years’ experience providing financial advice. Old Peak employs five other advisors, all of whom are CERTIFIED FINANCIAL PLANNER™ professionals: Dan Routh joined in 2019; Erin Vickery joined in 2022; Danielle Hochstetter joined in 2022; Justin May joined in 2023; and Grant Mosher joined in 2024. Old Peak also employs one operations director, Donna Reaves, two client service associates, Johanna Hammond and Laura Borowski, and one financial planning associate, Audrey Kayser. Types of services Old Peak provides on-going, fee-only wealth management services to individuals, families, trusts, and estates. Most of our clients are in their prime earning years and have assets we manage in excess of $1 mm. Our services: 1. Old Peak will work closely with the Client to understand their financial situation, goals, time horizon and ability to bear risk. We will base our analysis on discussions with the Client and on documents provided by the Client, for example recent bank and brokerage account statements, company benefit plans (retirement, medical, benefits, etc.), tax returns, insurance policies and estate planning documents. This phase may include developing personal cash flow and financial position statements. 2. Old Peak will consider tax issues, specifically the allocation of investments to taxable or tax- advantaged accounts

(IRA, 401k, 403b, etc.); estate planning; and insurance needs. Old Peak and its representatives are not attorneys or accountants, and do not offer accounting or tax advice, nor do we prepare legal documents. Clients should discuss suggestions with an attorney, tax advisor or insurance specialist before implementation. 3. Old Peak will develop a plan (“Financial Plan”) based on these factors. The Financial Plan will include a broad investment policy, individualized asset allocations and specific investment recommendations. It may also include suggestions regarding personal budgeting, insurance, estate planning and tax strategy. 4. Old Peak will implement the plan. This may include purchases or sales of investments; establishment of new securities accounts and/or closing of existing accounts; purchase, cancellation, or amendment of existing or new insurance policies; or recommended consultation with an attorney, tax advisor or other professional. Third parties execute those transactions. Old Peak receives none of the fees / commissions for such transactions. Clients may opt to execute any of these transactions directly. 5. Old Peak will monitor the Client’s portfolio regularly and communicate with the Client as necessary to discuss changes in market conditions or changes in the Client’s situation. 6. Old Peak will, on a quarterly basis, prepare a review of the Client’s portfolio and, if appropriate, suggest actions. 7. Old Peak will adjust the Client's Financial Plan and portfolio (or will recommend to the Client to make such adjustments) in response to changes in the Client's situation or to rebalance the portfolio if the weighting of specific investments has changed significantly. As explained in “Fees and Compensation”, Old Peak provides these services on an on-going basis to Clients who pay a quarterly fee. Investment services are provided on a discretionary basis. Clients grant Old Peak discretionary authority in their accounts to execute investment recommendations in accordance with the clients’ objectives without prior approval of each specific transaction. There are legacy clients of Old Peak who have different arrangements under different service agreements in whose accounts Old Peak has non- discretionary authority; however, those arrangements are no longer offered to new clients. Client may impose restrictions on investing in certain securities, at Client’s discretion. Old Peak will not advise Client to invest in, will not provide advice or any services regarding, and will not collect any fees with respect to the following securities: options, futures, warrants and derivatives. This exclusion will not apply to employer-granted stock options (both nonqualified and incentive stock options). Old Peak does not provide or participate in wrap fee programs. When Old Peak provides investment advice to a Client regarding their 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 a Client’s interests, so we operate under a special rule that requires us to act in a Client’s best interest and not put our interest ahead of the Client’s. As of December 31, 2023, Old Peak managed $267,331,766 in client assets on a non-discretionary basis and $204,543,436 in client assets on a discretionary basis.