True Link Financial Advisors, LLC (“True Link Financial Advisors”, the “Firm”, or “we” or “us”) is a limited liability company organized under the laws of Delaware that commenced operations in 2015. True Link Financial Advisors is a wholly owned subsidiary of its parent company, True Link Financial, Inc. Kai Stinchcombe serves as the Chief Executive Officer of True Link Financial, Inc. and the Managing Director of the Firm. The foundation of the Firm’s business is based on maintaining a culture of ethics and integrity with the highest possible emphasis on clear and transparent communications. Embedded within the Firm’s culture is its embrace of True Link Financial Advisors, LLC Form ADV Part 2A Page 3 of 16 the fiduciary duty to put client interests first. We foster a culture that hires, trains, and rewards employees in direct support of the values of humility, inclusion, caring, ambition, and excellence. Given our culture of transparency we are available to answer questions in as much detail or as frequently as our clients would like. While this Brochure generally describes the business of True Link Financial Advisors, certain sections also discuss the activities of its certain persons, called “Supervised Persons” who provide investment advice on True Link Financial Advisors’ behalf and are subject to the Firm’s supervision and control. Services We provide investment management services to our clients on either a discretionary or non-discretionary basis. When a client grants us discretion to manage their account, they grant us the authority to determine the securities and amount to be bought or sold without their consent prior to each trade, as well as the broker-dealer to be used and the commission rates to be paid for their securities transactions. Our discretionary authority also generally includes authority to select, hire and fire sub-advisers to manage client accounts. If a client does not grant us discretion to manage their account, the Firm makes recommendations regarding the purchase and sale of securities and the client makes the decision regarding the purchase or sale of securities. The Firm’s non-discretionary clients are under no obligation to act on the recommendations we make. Generally, True Link Financial Advisors works with clients to establish investment objectives, advise on asset selection, monitor assets under management, evaluate cash flow and liquidity needs and consult with the client upon request. For our clients, investment management services are provided pursuant to terms of an Investment Advisory Agreement between True Link Financial Advisors and the client. In the case of a trust, it is important to understand the different roles each party plays. True Link Financial Advisors does not provide investment advice to the beneficiaries of the trust. The Firm's client is the trust, not any of its individual beneficiaries. Accordingly, the Firm relies heavily on the representatives of the trust – the trustee, co-trustee, or similarly situated person, including anyone hired by them, or who they have otherwise delegated authority to (for ease of reference, referred to hereinafter as the "Trustee"). For both discretionary and non-discretionary relationships, the Trustee is the one who signs the investment advisory agreement and creates the client relationship. The Firm works with the Trustee to assess the investment objectives and risk tolerance of the trust itself, given its purpose and liquidity requirements, and the Firm relies on the Trustee to give it the information

needed to understand the trust’s situation. The Firm does not tailor its advisory services or investment objectives or strategies to the requests or needs of underlying beneficiaries of our pooled trust clients, nor do we accept investment restrictions from underlying beneficiaries of our pooled trust clients. Pooled trust beneficiaries must rely on their own professional support, which includes the Trustee, as to the appropriateness of joining a pooled trust and what portfolio to select in the event there are multiple allocation options. The investments in clients’ accounts can include, but are not limited to, exchange traded funds (ETFs), stocks, bonds and mutual funds, equity options and futures. However, the Firm primarily invests client funds in low cost ETFs. For certain clients, as part of our management services, we create an Investment Policy Statement (“IPS”) to serve as the roadmap to guide the investment management. In performing these services, True Link Financial Advisors does not verify any information received from the client or from the client’s other professionals (e.g., trustees, attorneys, True Link Financial Advisors, LLC Form ADV Part 2A Page 4 of 16 accountants, etc.,) and is expressly authorized to rely on such information. Clients can impose reasonable restrictions on the management of their account, including the ability to instruct the Firm not to recommend or purchase certain mutual funds, ETFs, stocks, or other securities. This should be documented between True Link Financial Advisors and the client in the IPS or other similar type of written document that is agreed to by the parties. Clients are obligated to notify us promptly in writing when their financial situation, goals, objectives, investment time horizon or needs change for the purpose of reviewing, or revising recommendations and/or services. True Link Financial, Inc.,the Firm’s parent company, also provides products and services to trusts and their trustees, such as a trust administration and record-keeping platform, prepaid cards, and tax preparation facilitation services; these services are not investment advisory in nature and are provided by True Link Financial, Inc. Non- investment advisory services are not governed by the Advisers Act. See Item 10 (Other Financial Industry Activities and Affiliations) below for additional information regarding these products and services and the conflicts of interest associated therewith. In the event the client (or a representative of the client) transfers in-kind securities into a new client account advised by the Firm and asks the Firm not to incorporate those securities into the portfolio(s) managed by the Firm, or requests that the Firm purchase specific securities for a client’s account outside of the portfolio strategy managed by the Firm and the Firm agrees to do so (at the Firm’s discretion), it will do so as an accommodation only. Clients will maintain exclusive ongoing responsibility for monitoring any and all such securities, and the disposition thereof. The Firm has no responsibility for such securities, regardless of whether any such security is reflected on any quarterly or other account reports prepared by the Firm or the custodian. Such securities will not be subject to the Advisory Fee (defined below). We do not participate in wrap fee programs. Assets Under Management As of December 31, 2023, we had a total of $1,063,868,316.19 in discretionary assets under management and $76,997,137.03 in non-discretionary assets under management.