A. Firm Information Elk River Wealth Management LLC (“Elk River” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Elk River was organized as a Limited Liability Company (“LLC”) under the laws of the State of Colorado in January 2020 and became a registered investment advisor in February 2020. Elk River is a wholly-owned subsidiary of Elk River Wealth Holdings, LLC, a Delaware Limited Liability Company. The Principal Officer of Elk River is Christopher C. Freimuth (Chief Executive Officer and Chief Investment Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Elk River. For information regarding this Disclosure Brochure, please contact Rita Koch Day (Chief Compliance Officer) at (720) 310-3275 B. Advisory Services Offered Elk River offers wealth management services to individuals, high net worth individuals, trusts, estates, businesses, charitable organizations, and insurance companies (each referred to as a “Client”). Elk River’s Wealth Management Services include continuous Client engagement while providing discretionary investment management and financial planning services tailored to the needs of each 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. The Advisor’s fiduciary commitment is further described in the Code of Ethics. For more information regarding the Advisor’s Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Elk River provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Elk River works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy. The Advisor will then construct the portfolio utilizing its internal investment strategies and/or through allocation[s] to one or more Independent Managers. Internal Investment Management – Elk River will then construct an investment portfolio, consisting of low-cost, diversified individual stocks, individual bonds, exchange-traded funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor may also utilize options contracts or other types of investments, as appropriate, to meet the needs of its Clients. The Advisor may retain certain types of investments held as legacy investments in a Client account based on portfolio fit and/or tax considerations. Elk River’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Elk River will construct, implement and monitor the portfolio to ensure it meets 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. Elk River evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Elk River may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Elk River 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. Elk River 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 Page 5 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. At no time will Elk River 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 the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. 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 sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), 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). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. 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. Use of Independent Managers – Elk River may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services.

The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with the Client’s investment objectives and overall best interests. The Client, prior to entering into an agreement with an unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Advisor Credit Exchange, LLC – The Advisor may introduce certain Clients to the services of Advisor Credit Exchange, LLC (“ACE”). ACE provides the Advisor access to a proprietary platform (“ACx”) which enables matching and pre-qualification of Clients with participating lenders based on credit criteria. ACE offers access to various loans, including non-purpose, revolving line of credits (herein “Lending Program”). In such instances, Client assets held in their account[s] at the Custodian will be used as collateral for the loan. The Advisor will receive compensation from the lender or ACE should clients establish a loan with one of the lenders through the ACx platform. In addition, the Advisor will continue to have investment management responsibility for the collateralized holdings and will receive an investment advisory fee for managing those collateralized assets in the Client’s account[s]. Clients are not obligated to participate in the ACE Lending Program. For additional information related to the risks involved in non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Financial Planning Services – Elk River will typically provide a variety of financial planning services to Clients. Financial planning services may be included in an overall wealth management engagement or provided separately. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial circumstance. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. 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. Elk River may also refer Page 6 Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the 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 (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. 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. Investment Consulting Services The Advisor offers a variety of investment consulting services to individuals and families, pursuant to a written investment consulting agreement. This service is ideal for Clients seeking a smaller scope engagement and to utilize the expertise of the Advisor but without having an account managed by the Advisor or developing a financial plan as described above. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. 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. C. Client Account Management Prior to engaging Elk River to provide wealth management 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 – Elk River, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Elk River will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – Elk River will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Elk River will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Elk River does not sponsor or manage a wrap fee program. E. Assets Under Management As of December 31, 2022, the Advisor managed $830,816,633 in Client assets, $815,867,427 of which are managed on a discretionary basis and $14,949,206 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.