This Disclosure document is being offered to you by Bruce G. Allen Investments, LLC (“Bruce G. Allen Investments”, “we”, “our” “us”) about the investment advisory services we provide. It discloses information about the services we provide and how those services are made available to you, the client. We are an investment management firm located in Denver, Colorado. The firm was established by Bruce G. Allen in 2017. We specialize in investment advisory services for individuals, high-net-worth individuals, charitable organizations, foundations, corporations, trusts, and retirement plans. We are committed to helping clients build, manage, and preserve their wealth and providing assistance that helps them achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and Bruce G. Allen Investments execute an engagement letter or client agreement. Investment and Wealth Management and Supervision Services We offer discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. These services include investment analysis, allocation of investments, quarterly portfolio reports, financial commentaries, and ongoing monitoring of client portfolios. We primarily allocate client assets among equity securities (stocks), individual debt (bonds), cash, various mutual funds, and exchange-traded funds (“ETFs”), in accordance with their stated investment objectives. If deemed appropriate, we may select ESG holdings for various clients if requested. We will work with you to obtain the necessary information regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This information enables us to determine the portfolio best suited for your investment objective and needs. In performing our services, we shall not be required to verify any information received from you or other professionals. If you request, we will recommend you engage the services of other professionals for implementation purposes. You have the right to decide whether or not to engage the services of any recommended professional. Once we have determined the types of investments to be included in your portfolio and allocated them, we will provide ongoing investment review and management services. This approach requires us to review your portfolio at least quarterly. We will rebalance the portfolio as we deem appropriate to meet your financial objectives. We trade these portfolios and rebalance them 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. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with your appropriate written authorization. We provide advice on legacy positions or other investments held in client portfolios. Clients will engage us to advise on certain investment products that are not maintained by their primary custodian, such as variable life insurance and annuity contracts and assets held in employer-sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and expected to understand that our past performance does not guarantee future results. Certain market and economic risks may adversely affect an account’s performance. This could result in capital losses in your account. Nitrogen (Formerly RISKALYZE) To further fine-tune our understanding of a client’s risk tolerance, our Firm utilizes Nitrogen, a third-party vendor tool, to assist in identifying the client’s risk tolerance. Nitrogen technology assists financial planners in two critical tasks: (1) measuring the risk preferences of investors and (2) applying these preference measurements to portfolio selection. Nitrogen summarizes an investor’s mean-variance risk aversion on a 99-point scale. In connection with this output, the Nitrogen tool “quantifies” the client’s indicated investment risk tolerance through the illustration of expected return (plus/minus) and investment volatility (investment variance), which uses past data to calculate expected variance. Financial Planning Through the Financial Planning process, we strive to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term and future generations. With each family's unique goals and circumstances in mind, we offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and family legacy objectives. We partner with your other advisors (CPA, Estate Attorney, Insurance broker, etc.) to ensure a coordinated effort of all parties toward your stated goals. Such services include various reports on specific goals and objectives, general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management and estate planning.
• Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans and 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.
• 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. A written evaluation of your initial situation or Financial Plan is provided to you. An annual review will be provided by us, if indicated by you and per the Financial Planning Agreement. More frequent reviews occur but are not necessarily communicated to you unless immediate changes are recommended. MoneyGuide Pro Advisor Platform Our Firm makes available to Clients the “MoneyGuide Pro” platforms to provide periodic comprehensive reporting services that can incorporate all the Client’s investment assets, including those investment assets that are not part of the assets managed by our Firm (“Excluded Assets”). The Client and their other advisors that maintain trading authority, and not our Firm, shall be exclusively responsible for the investment performance of the excluded assets. Unless otherwise expressly agreed to in writing, our Firm’s service relative to the excluded assets is limited to reporting only. Therefore, we shall not be responsible for the investment performance of the excluded assets. Instead, the Client and the Client’s designated outside investment professional(s) maintain supervision, monitoring, and trading authority for the excluded assets. If our Client prefers, we’ll make recommendations as to any excluded assets. The Client has no obligation to accept the recommendation, and we shall not be responsible for any

implementation error (timing, trading, etc.) relative to the excluded assets. The Client may engage us under the terms and conditions of a Consulting or Investment Advisory Agreement between our Firm and the Client. MoneyGuide Pro Platform may also provide access to other types of information, including financial planning concepts, which should not be construed as our Firm’s personalized investment advice or recommendations. We shall not be held responsible for any adverse results a Client may experience if the Client engages in financial planning or other functions available on the MoneyGuide Pro Platform without our assistance or oversight. Third-Party Managers We provide investment advice and recommendations on the investment strategies of Third-Party Managers (“Managers” or “TPM”). Selected Managers are evaluated by Bruce G. Allen Investments for client use. Our services include assisting you in identifying your investment objectives and matching personal and financial data with a select list of Managers. The intent of this service is to have a selected list of high-quality and recognizable third-party investment management firms from which you select one or more Managers to handle the day-to-day management of your account(s). Following our recommendations, you will have final authority to select a Manager. We will assist you in completing the appropriate documents. We will assist you with identifying their risk tolerance and investment objectives. We will recommend TPMs in relation to your stated investment objectives and risk tolerance. You select a recommended TPM based on your needs. Clients will enter a Third-Party Advisory Program Agreement directly with Bruce G. Allen Investments. Managers selected for your investments must meet several quantitative and qualitative criteria established by Bruce G. Allen Investments. Among the criteria that may be considered are the Manager’s experience, assets under management, performance record, client retention, the level of client services provided, investment style, buy and sell disciplines, capitalization level, and the general investment process. You are advised and should understand that:
• A Manager’s past performance is no guarantee of future results;
• There is a certain market and/or interest rate risk that may adversely affect any Manager’s objectives and strategies and could cause a loss in a client's account(s); and
• Client risk parameters or comparative index selections provided to Bruce G. Allen Investments are guidelines only; there is no guarantee that they will be met or exceeded. We will be available to answer questions you may have regarding your account and act as the communication conduit between you and the Manager. Managers will have discretionary authority to determine the securities to be purchased and sold for your account. Neither Bruce G. Allen Investments nor its associated persons will have any trading authority with respect to a client’s managed account with the TPM(s). All accounts are managed by the selected Manager, and we do not have any discretionary trading authority with respect to such accounts. Information collected by our Firm regarding Managers is believed to be reliable and accurate, but we do not necessarily independently review or verify it on all occasions. All performance reporting will be the responsibility of the respective Manager. Such performance reports will be provided directly to you and Bruce G. Allen Investments. We do not audit or verify that these results are calculated on a uniform or consistent basis as provided by a Manager directly to us or through the consulting service utilized by the Manager. Bruce G. Allen Investments has entered into agreements with various independent Managers. Under these agreements, we offer clients various types of programs sponsored by these Managers. All third-party Managers to whom Bruce G. Allen Investments will refer clients will be licensed as registered investment advisors by their resident state and any applicable jurisdictions or registered investment advisors with the Securities and Exchange Commission. Third-party managed programs generally have account minimum requirements varying from investment advisor to investment advisor. Account minimums are generally higher on fixed income accounts than equity-based accounts. A complete description of the Manager’s services, fee schedules and account minimums will be disclosed in the Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at the time an agreement for services is executed and an account is established. Retirement Plan Advisory Services Retirement Plan Advisory Services consists of helping employer plan sponsors to establish, monitor and review their company's retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment selection and monitoring, plan structure, and participant education. We offer management of 401(k), 457, and 403(b) accounts both on a plan level and on the individual participant level. On the plan level, we manage the investment line-up making changes as necessary as well as providing risk-based investment models for the participants. On the individual participant level, we manage risk-based models using the current investment lineup based on risk tolerance of the individual investor. Plan Level We will establish the plan’s needs and objectives through an initial meeting to collect data, review plan information, and assist in developing or updating the plan’s provisions. Ongoing services may include recommendations regarding the selection and review of unaffiliated mutual funds that, in our judgment, are suitable for plan assets to be invested. We periodically review the investment options selected and make recommendations to keep or replace plans investment options as appropriate. We perform a comprehensive review of Investment options and will assist with converting from incumbent service providers to a new service provider if appropriate. We will provide quarterly recommendations for the plan’s investment allocation. Upon receipt we will review the investment options and provide positions for accounts in accordance with the management style chosen by the client. Analysis is provided for each fund held by the Plan. A report shows historical performance, asset allocation, and the performance of each fund, including its performance in comparison to its appropriate benchmark. The report also contains information regarding each Fund’s managers, capitalization, investment style, expenses, portfolio composition and other qualitative factors relevant to the Fund’s performance and adherence to the Plan’s Investment Policy Statement. Clients are responsible for making the fund changes within the account. Participant Level 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. Consulting Services We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice or any other business advisory / consulting services for equity or debt investments in privately held businesses. Wrap Fee Programs We do not place client assets into a wrap fee program. Assets As of December 31, 2023, our Firm manages $210,514,027 regulatory assets under management on a discretionary basis.