This Disclosure document is being offered to you by WhippleWood Advisors, LLC (“WWA” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. We are an investment advisory firm located in Littleton Colorado, specializing in investment management, financial planning and tax and estate planning. Client’s CPA renders tax advice, not WWA. The firm was established by Rick Whipple and Mona Feeley, the firm’s principal owners, in January 2016 and became a registered investment adviser with the SEC in August 2020. The Firm’s current ownership includes Rick Whipple, Mona Feeley and Joe Hubbard. We are committed to helping clients build, manage, and preserve their wealth, and to provide guidance that helps clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services and planning are initiated only after you and WWA execute an Investment Management Agreement. Investment Management Services We manage advisory accounts on a discretionary and non-discretionary basis. Once we determine a client’s profile, income need, and investment plan, we execute the day-to- day transactions with or without prior consent, depending on the client’s agreement with our Firm. Account supervision is guided by the client’s written risk profile and investment plan. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among cash, equities, debt securities, exchange traded funds (“ETFs”), [no-load or load-waived mutual funds options], equities, and Alts in accordance with their stated investment objectives. When appropriate, we recommend Private Fund investments to certain suitable clients. We generally invest Client’s cash balances in money market funds, FDIC Insured Cash deposits or FDIC Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. In most cases, at least a partial cash balance will be maintained in a money market account or FDIC insurance deposit so that our firm may debit advisory fees for our services related to this service. In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and income needs. As appropriate, we also review their prior investment history, as well as family composition and background. Based on client needs, we develop the client’s personal risk profile and investment plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals and income needs. As determined through our firm’s initial due diligence with the client, we will determine if clients are seeking an actively managed investment strategy for their account(s). Our firm will provide ongoing investment review and management services. This approach requires us to periodically review client portfolios. With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios based on the combination of our market views and your objectives, using our investment philosophy and strategies as described in Item 8 of this Brochure. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. If a non-discretionary relationship is in place, calls will be placed to the client presenting the recommendation made including a rebalancing recommendation and only upon your authorization will any action be taken on your behalf. It is the decision of the client on what type of account they elect to open with our firm – a discretionary account without prior notification of investment trades or a non-discretionary account as described above. Financial Planning Most of our investment management clients receive financial planning services at some point throughout their engagement. Our team strives to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each family in mind, our team offers financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow and retirement income, wealth transfer and family legacy objectives. Our team often works closely with our client’s other advisors (CPA, estate attorney, insurance broker, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets and periodic updates. Our specific services in preparing a client’s formal financial plan may include: ● Review and clarification of financial goals; ● Assessment of overall financial position including cash flow and income, balance sheet, investment strategy, risk management and estate planning, and other practice areas covered by the CFP Board of Standards; ● Creation of a unique plan for each goal, including personal and business real estate, education, retirement, financial independence, charitable giving, estate planning, business succession and other personal goals; ● Development of a goal-oriented investment and income plan, with input from various advisors to our clients around tax strategy, asset allocation, asset location, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans (limited to education only), taxable and trust accounts that require special attention. When investment management or both plan implementation and investment management services are offered, there is a conflict of interest since there is an incentive for us offering investment management services to recommend products or services for which our Firm receives compensation. However, our Firm will make all recommendations independent of such considerations and based solely on our obligations to consider your objectives and needs. As an investment management client, you have the right not to act upon any of our recommendations and not affect the transaction(s) through us if you decide to follow the recommendations. It should be noted that at all times WWA will act in your best interest and act as a fiduciary in carrying out services provided to you. Consulting Services We provide investment advice on isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide non- securities advice related to estate planning, insurance, real estate, and annuity. In these cases, you will be required to select your own investment managers, custodians, and insurance companies to implement consulting recommendations. If you need brokerage and/or other financial services, we will recommend one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals ("Firms"). You must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm you choose. You have the right to choose whether to follow the consulting advice that we provide. For clients interested in mitigating certain tax consequences of selling appreciated real property, our Firm will inform, educate, and advise such clients with respect to the exchange of such property for securitized interests in other real property while conforming to Internal Revenue Code Section 1031 (more commonly known as a “1031 Exchange”). In connection with this service, our Firm will evaluate the client’s current real property and the likely tax consequences if sold at its present market value, help locate a suitable Qualified Intermediary, perform internal due diligence on potential 1031 Exchange providers that can offer an appropriate securitized interest in like‐kind property (via a Delaware Statutory Trust or “DST” structure), utilize multiple third‐party due diligence service providers that issue reports on prospective DSTs, coordinate with the client’s tax professional or CPA and model projected tax savings (especially as it relates to DST income tax deferral), and – if the client elects to avail him or herself of the 1031 Exchange – review financial and compliance reports of the DST on an ongoing basis for a fee. Our Firm will also incorporate the addition of the DST into the applicable client’s overall portfolio management and/or financial planning services, focused on proactive reviews and updates with the client, if client directs and engages with WWA Sub-Advisory Services Our firm may determine that engaging the expertise of an independent sub-advisor is best suited for your account. Our firm will have the discretion to utilize independent third- party investment advisers to aid in the implementation of investment strategies for your portfolio. In certain circumstances, we may allocate a portion of a portfolio to an independent third-party investment adviser (“Manager”) for separate account management based upon your individual circumstances and objectives, including, but not limited to, your account size and tax circumstances. Upon the recognition of such situations, in coordination with you, we will hire a Manager for the management of those assets. These advisers shall assist our Firm in managing the day-to-day investment operations of the various allocations, shall determine the composition of the investments comprising the allocation, shall determine what securities and other assets of the allocation will be acquired, held, disposed of or loaned in conformity with the written investment objectives, policies and restrictions and other statements of each client comprising the allocation, or as instructed by our Firm. Managers selected for your investments need to meet several quantitative and qualitative criteria established by us. Among the criteria that may be considered are the Manager’s experience, assets under management, performance record, client retention, the level of client services provided, investment style, buy and sell disciplines, capitalization level, and the general investment

process. You are advised and should understand that: ● A Manager’s past performance is no guarantee of future results; ● There is a certain market and/or interest rate risk which may adversely affect any Manager’s objectives and strategies, and could cause a loss in a Client's account(s); and ● Client risk parameters or comparative index selections provided to our firm are guidelines only and there is no guarantee that they will be met or not be exceeded. Managers may take discretionary authority to determine the securities to be purchased and sold for the client. As stated in the Discretionary Advisory Agreement, our Firm and its associated persons will have discretionary authority to hire and fire the Manager. Our firm will work with the sub-advisor to communicate any trading restrictions or standing instructions to refrain from a particular industry requested by the Client. In all cases, trading restrictions will depend on the sub-advisor and their ability to accommodate such restrictions. All performance reporting will be the responsibility of the respective Manager. Such performance reports are provided directly to you and our firm. Disclosures will indicate what firm is providing the reporting. In addition, WWA does provide more specific client reporting at the request of a client or portfolio statistics and performance. We review the performance of our Managers on at least a quarterly basis or as needed. More frequent reviews may be triggered by changes in Manager’s management, performance or geopolitical and macroeconomic specific events. Our discretionary portfolio management services are provided to you primarily, but not exclusively, through the investment management platform sponsored by SEI Investments Management Corporation, and its affiliates, SEI Private Trust Company and SEI Global Services, Inc. (collectively, "SEI"). Our agreement with SEI allows us to offer SEI's "Mutual Fund Models Program," "Managed Account Program," "Custody-Only Program", and “Hybrid custody”, which includes SEI co-management of portions of the account program to you (collectively, the "SEI Programs"), bundled together with SEI's custodial and execution services. Our arrangement with SEI further provides us with a variety of account, performance, due diligence, research and risk management tools and administrative services that allow us to deliver advisory services more efficiently to you. A summary description of the SEI Programs is as follows: SEI Asset Management Programs The SEI "Mutual Fund Models Program," and "Managed Account Program," are institutional asset allocation programs that our firm uses in the management of assets for some client accounts. If you enroll in a SEI "Mutual Fund Models Program," or "Managed Account Program," our firm will assist you in the establishment of a SEI Program Account (the Account) at SEI Trust Company (SEI). All Account transactions are processed and cleared through using the SEI systems. The SEI Mutual Fund Models Program and Managed Account Program use asset allocation portfolios developed by SEI Investments. The portfolios consist of SEI Family of Institutional Mutual Funds (Mutual Funds), and other securities approved by SEI or their sub managers to be held in an account. The SEI managed programs use selected portfolio managers that are subject to oversight by SEI and who have entered into a sub-advisory agreement with SEI. SEI can provide us and our clients the Investment Policy Statement based on what strategy(s) you and your investment advisor representative select for your account. We will direct SEI to reallocate your investments in accordance with your Investment Policy Statement. SEI and its portfolio managers will have discretionary authority over the securities and transactions in the Account. SEI has the authority to replace a previously selected portfolio manager or SEI Fund without your prior approval. In addition, SEI has authority, policies and procedures to rebalance the investments within your account at least annually so that the market value of the shares of each security held in your account is the same percentage of the total market value of your account as required by your Investment Policy Statement, or within their tactical allocation limits. As stated in the Discretionary Advisory Agreement, our Firm and its associated persons will have discretionary authority to elect certain asset allocation portfolios on SEI’s platform based on the profile and risk tolerance that we have developed with you, the client. The SEI Custody-Only Program, SEI provides custody services, including block trading for customized WWA strategies and custom models, that do not have any SEI mutual funds or SEI supervised separate account managers. If you enroll in a “SEI Custody-Only Program," our firm will assist you in the establishment of a SEI Program Account (the Account) at SEI Trust Company (SEI). All Account transactions are processed and cleared using the SEI systems. The SEI custody only Program uses asset allocation portfolios or investment strategies developed by WWA’s. The asset allocation portfolios are generally risk- based portfolios of SEI or non-SEI mutual funds or Exchange traded funds. The custom strategy portfolios are not asset allocation portfolios, rather the focus on a specific theme in portfolio construction like “state specific municipal bond mutual funds,” “closed end funds,” “global equity” or Alternative investments of publicly traded mutual funds or ETF’s. These strategies are subject to oversight by WWA’s SEI can provide us and our clients with the Investment Policy Statement based on what strategy(s) you and your investment advisor representative select for your account. We will direct SEI to reallocate your investments in accordance with your Investment Policy Statement or strategy objective. WWA’s will have discretionary authority over the assets and transactions in the Accounts. WWA’s has the authority to replace a previously selected strategy, asset allocation model or underlying investments without your prior approval. In addition, WWA’s has authority, policies and procedures to rebalance the investments within your account at least annually so that the market value of the shares of each security held in your account is the same percentage of the total market value of your account as required by your Investment Policy Statement, or within our tactical allocation limits. Hybrid custody that also includes SEI co-management of portions of the account program. SEI provides custody services including block trading when necessary for all aspects of the account. All Account transactions are processed and cleared using the SEI systems. If you enroll in a SEI “hybrid custody” program, our firm will assist you in the establishment of a SEI Program Account (the Account) at SEI Trust Company (SEI). WWAs maintains discretion over the entire account at SEI. Specifically, WWAs has the complete discretion to allocate funds to any SMA manager, mutual fund, ETF, or specific investment strategy. As it relates to specific SMA managers with specific model investment strategies, those SMA managers have sole discretion to buy and sell securities according to their investment models, just as they would in their own mutual funds that the SMAs mirror. WWA’s will maintain discretion and supervision over any non-SEI (mutual funds or separate account manager investments) and discretion over the entire account as to allocating funds between custody only, SEI mutual funds and SEI supervised separate account managers. The hybrid custody accounts are risk-based asset allocation portfolios that use goals-based planning and tax location for specific client needs and goals. We leverage the investment recommendations and management of the SEI Investment Management Unit for portions of the portfolio but include other investments and our own custom strategies to further build out the investment portfolios. WWA will direct SEI to reallocate your investments in accordance with your Investment Policy Statement or strategy objective on a periodic basis, but not less than annually. Disclosure Regarding Rollover Recommendations We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight. Wrap Fee Programs Our firm does not offer a Wrap Fee Program. Assets As of December 31, 2023, our firm manages a total of $267,381,182 in regulatory assets under management. There are $264,095,129 in discretionary regulatory assets under management and $3,286,053 in non-discretionary assets under management.