Fort Vancouver Investment Management, LLC (“FVIM” or “we”) is a fee-only investment advisory firm based in Vancouver, Washington. FVIM was founded in 2010 by Robert Pool. We specialize in investment management. As a fee-only advisory practice, we receive compensation only from our clients. We do not sell any financial products, do not collect sales commissions, and do not accept referral fees. We receive no benefits from custodians/broker-dealers based on client securities transactions (so-called “soft dollar benefits”). As of January 1, 2024, the principal owners of FVIM are Robert Pool, Matthew Ebeling and Andrea Silbernagel. Investment Management FVIM provides investment management services. We manage portfolios that often consist of multiple types of accounts, which may include joint, trust, IRA, etc. Portfolios are constructed in a manner that is appropriate for our client’s life circumstances. Our investment philosophy is grounded in Modern Portfolio Theory, which refers to the process of reducing risk in a portfolio through systematic diversification across and within asset classes. We typically adhere to an evidence-based approach to investing and, thus, implement, asset-class mutual funds and exchange-traded funds, but may use actively managed mutual funds. FVIM typically does not recommend individual stocks or bonds. FVIM analyzes mutual funds based on the fund’s total operating expenses, portfolio turnover, investment objective and investment restrictions and limitations. We typically invest in no-load institutional mutual funds including funds managed by Dimensional Fund Advisors (DFA), Vanguard, Avantis Investors, BlackRock and Schwab that have low operating expenses, low portfolio turnover, below-average capital gains distributions and a fundamental investment objective of investing in a particular asset class. Some mutual funds are available for investment only by clients of registered investment advisors, and all investments are subject to the approval of the advisor. This means that you may not be able to make additional investments in DFA mutual funds if you terminate your agreement with FVIM, except through another advisor authorized by DFA. By developing a personalized investment strategy for each client, we are able to help our clients manage both their short-term and long-term financial objectives. This process includes the construction of a well-diversified portfolio consistent with the client’s appetite for risk in conjunction with an ongoing assessment of the portfolio’s performance. The investment strategy is monitored continually to ensure alignment with the client’s long-term goals and financial objectives. We do not sponsor or participate in any wrap-fee programs. Per CCR Section

260.238 (k), FVIM will disclose material conflicts of interest regarding FVIM, representatives or any of our employees which could reasonably be expected to impair the rendering of unbiased and objective advice. As of December 31, 2023, FVIM managed $165,900,497 in assets, all on a discretionary basis. 5 | P a g e Retirement Rollovers & Conflicts of Interest If we make recommendations or provide advice related to a retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. When we recommend a client rollover their retirement plan assets into an account to be managed by FVIM, such recommendation creates a conflict of interest because we will be compensated if you follow our advice. To manage this conflict, we operate under a special ERISA rule relating to retirement assets that requires us to act in your best interest and not put our interests ahead of yours. Under this 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. While not always the case, a client or prospective client leaving an employer typically has the following four options regarding an existing retirement plan: 1. Retain the assets in the former employer’s plan; 2. Rollover the assets to a Traditional IRA or Roth IRA; 3. Rollover the assets to the plan of a new employer; or 4. Receive a cash distribution. Deciding which of the above options are right for you can be a complex process. For that reason, we will review and discuss each option with you. Additionally, we provide a written “Retirement Advice Disclosure” to assist our clients when making these decisions. Please let us know if you did not receive the above disclosure so we can provide it to you. Retirement Planning FVIM offers retirement planning for a fixed fee. This analysis reviews retirement planning, asset allocation, investment strategy among other analyses. FVIM will provide the client with a written report. The client will be responsible for executing any recommendations made by FVIM unless they choose to hire FVIM as their investment manager. 6 | P a g e