A. Firm Information Denver Wealth Management, Inc. (“DWM” or the “Advisor”) is a registered investment advisor with the SEC. The Advisor is organized as a Corporation under the laws of the State of Colorado. DWM initiated business in September 2016 and is owned and operated by Bryson (“Blair”) Braden (Principal, Chief Compliance Officer) and Zachary T. Bouck (Principal, Chief Investment Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by DWM. B. Advisory Services Offered DWM offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses and pension/retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. DWM’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services DWM provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. DWM works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. The Advisor manages Client accounts through the investment process known as Plan, Quality, Capture & Collect. This philosophy is based on the historical data of Harry Markowitz that 1) captures a variety of asset classes, which are chosen based on the goal of the investment, 2) annually rebalance the asset weightings back to the intended risk tolerance, and then 3) based on qualitative factors decide which sectors to investment in, while excluding certain sectors based on fundamentals of those companies and markets. DWM will then construct a portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) and no transaction-exchange traded funds (“NTFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, corporate debt securities, certificates of deposit, United States government securities or options contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. DWM’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. DWM will construct, implement and monitor the portfolio to strive to meet the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. DWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Through DWM’s trademarked Summit Investment Process TM, the Advisor incorporates 10 different variables in scoring investment opportunities. One of the variables included in the process is the Environmental Social and Governance (“ESG”) component. Currently DWM does not place an emphasis on the ESG score, but utilizes it as part of its overall due diligence process. DWM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. DWM may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. DWM may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will DWM accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement, please see Item 12 – Brokerage Practices. Investment Management Platforms – DWM may provide advisory services through programs sponsored by LPL Financial LLC (“LPL Financial”), a registered investment advisor and broker-dealer. Below is a brief description of the LPL Financial Guided Wealth Portfolios. For more information regarding the LPL Financial programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Financial Form ADV 2A program brochure) and the Form ADV, Part 2A of LPL Financial or the applicable program. Guided Wealth Portfolios (“GWP”) GWP offers Clients the

ability to participate in a centrally managed, algorithm- based investment program, which is made available to users and Clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL Financial and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although DWM will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory Clients and receive ongoing financial advice from LPL Financial, FutureAdvisor and DWM by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory Clients of LPL Financial, FutureAdvisor or DWM, do not enter into an advisory agreement with LPL Financial, FutureAdvisor or DWM do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. Financial Planning Services DWM will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. For Clients in need of a comprehensive plan this service may include goal setting, cash flow analysis, insurance planning, short-term savings goals, investment analysis, detailed retirement plan forecast, Monte Carlo analysis & estate plan review. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Page 6 DWM may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Certain financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. The Investment Advisor Representatives (herein “Advisory Persons”) will receive commissions for the implementation of recommendations for commissionable brokerage and insurance transactions, in their separate capacity as registered represetatives or insurance professionals. Retirement Plan Advisory Services DWM provides retirement plan advisory services on behalf of retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Oversight Services (ERISA 3(21))
• Ongoing Investment Recommendation and Assistance Certain of these services are provided by DWM serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of DWM’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging DWM to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – DWM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – DWM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – DWM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – DWM will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs DWM does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by DWM. Page 7 E. Assets Under Management As of December 31, 2023 DWM manages $372,594,995 in Client assets, $372,012,913 of which are managed on a discretionary basis and $582,082 of which are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.