Firm Description Valtinson Bruner Financial Planning LLC (“VBFP”) was founded in 2018. Lauris D. Valtinson and Robert J. Bruner are VBFP’s members. Types of Advisory Services ASSET MANAGEMENT VBFP offers discretionary asset management services to advisory Clients. VBFP will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize VBFP discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Wrap Fee Program VBFP also offers discretionary asset management services to advisory Clients through its Wrap Fee Program as described in VBFP’s Wrap Fee Program Brochure – Appendix. Please refer to that Brochure for additional information. VBFP will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize VBFP discretionary authority to execute selected investment program transactions as stated within the Investment Management Agreement. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, a thorough review of all applicable topics including but not limited to, Retirement Planning, Succession Planning, Education Planning, Legacy Planning, Insurance Planning, Investment Planning, Budget Planning, Personal Financial Planning, Tax Planning, Major Purchase Planning, Divorce Planning, Debt Management Planning, Business Exit Planning, and Cash Flow Analysis will be reviewed. If a conflict of interest exists between the interests of VBFP and the interests of the Client, the Client is under no obligation to act upon VBFP’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through VBFP. One-time financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Ongoing services will remain in effect year over year unless cancelled in writing by either party by giving the other party thirty (30) days written notice. ERISA PLAN SERVICES VBFP provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. VBFP may act as a 3(21) Fiduciary: Limited Scope ERISA 3(21) Fiduciary. VBFP may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor VBFP has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using VBFP can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. VBFP acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide non-discretionary investment advice

to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands VBFP’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, VBFP is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. VBFP may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between VBFP and Client. 3. VBFP has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to VBFP on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. PUBLICATION OF PERIODICALS VBFP may publish newsletters providing general information on various financial topics including, but not limited to, estate and retirement planning, market trends, etc. No specific investment recommendations are being provided in any newsletter, and the information provided is not intended and does not purport to meet the objectives, needs or targets of any client or individual. Absent specific advice or services provided by VBFP, clients should not rely upon the information contained in any newsletter. This newsletter would be distributed to our advisory clients, prospects and other professionals. SEMINARS AND WORKSHOPS VBFP holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs All Clients electing for VBFP to manage assets will be placed within VBFP’s Wrap Program as outlined in VBFP’s Wrap Fee Program Brochure – Appendix. Please refer to that Brochure for additional information. Client Assets under Management VBFP has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $293,342,626 $137,990,088 October 25, 2023