1. Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). Elevate Capital Advisors (“Elevate”, “Elevate Capital”, “the firm”, “our firm”, “we”, “us”, “our”) is a Corporation in Eagle, Colorado, USA. The firm was founded in March 2017 by our principal owners Ken Armstrong and Shane Fleury and started operations in July 2017. 2. Describe the types of advisory services you offer. Elevate provides advisory services related to Portfolio Management, Pension Consulting, and Financial Planning. Our services cover various types of investments, investment vehicles, and methods of analysis. A. Portfolio Management Services Elevate offers discretionary and non-discretionary portfolio management services. a. Discretionary Agreements: Elevate is responsible for production and execution of the Investment Policy Statement (IPS). A risk analysis is performed to produce an IPS for each client. i. Portfolio Management Process: o Identify and specify investment objectives and constraints
• Detailed risk analysis. o Develop and maintain investment strategy
• The firm maintains several primary investment strategies which are often combined in some form to align with each investor’s willingness and ability to take risk and the size of their portfolio. o Determine portfolio composition
• Generally composed of proprietary investment strategies developed and maintained by Elevate (See Item 8, Section 1).
• Custom-designed strategies are also available. o Execute transactions to bring portfolio into alignment with target allocations
• Consideration is given to taxes, transaction costs and market conditions o Measure and evaluate portfolio performance
• Clients are provided online access to robust performance reporting software o Monitor investor behavior and market conditions
• Using internally generated and independent third- party research, commentary, analysis, and software o Rebalance as necessary to maintain alignment with objectives and constraints
• Consideration is given to taxes and transaction costs b. Investment Policy Statement: The Investment Policy Statement (IPS) formalizes the scope of the engagement and sets guidelines for risk, return, allocations, review, rebalancing, restrictions, performance reporting and ongoing monitoring and management of accounts. At this time, we will also produce all forms required to open any new accounts and arrange for transfer of assets from existing accounts. We manage assets held with Charles Schwab due to our existing business relationship. In addition to providing information regarding their personal financial circumstances, investment objectives, risk tolerance, time-horizon and any other constraints, clients are obligated to provide to the firm timely notifications of any changes to these circumstances. Monthly, we send an email encouraging clients to review their accounts, allocations, and performance via our online performance portal. We also contact clients at least annually to conduct a review meeting to determine whether there have been any changes in a client’s financial circumstances, investment objectives, risk tolerance, time-horizon, or any other considerations. Market conditions will continuously cause a portfolio’s investments to vary from the original allocations that were established. To remain consistent with the overall guidelines established in the IPS, each security in which the portfolio is invested will be continually monitored for variance and rebalanced back toward the target weighting when appropriate. The Chief Investment Officer will determine the amount of variance allowed. c. Non-Discretionary Agreements: In our non-discretionary accounts, the client retains ultimate responsibility for portfolio decisions. No market actions are taken in non-discretionary accounts without verbally confirmed instructions from the client. Elevate’s proprietary investment strategies are not available under non-discretionary agreements and no investment policy statement will be created or maintained by the firm for these accounts. Elevate may from time to time make recommendations to Client but the client retains responsibility for deciding what securities are to be bought and sold. Elevate will track non-discretionary account holdings with trailing stops and alert the client when particular levels are hit. All other firm services such as advice on position size, fundamental value, technical analysis, entry and exit prices, financial planning services, and trade execution, are included. Using third party software, Elevate monitors positions in non- discretionary accounts and advises clients accordingly. The client always has the right to disregard our advice. B. Pension Consulting Services a. General Consulting Services – Elevate assists plan sponsors in managing their fiduciary obligations to defined contribution plans. We schedule and keep minutes from trustee meetings. We work directly with various vendors that

come together to make a retirement plan work, while serving as a single point of contact for plan sponsors. In this capacity, we advocate for plan sponsors and bring them ideas for changes or improvements to plan documents or IPS based on changes in law or industry developments. Finally, we assist with participant and eligible-employee education regarding plan options, general investment concepts, and benefits of participation. b. Requests for Proposals – Elevate assists plan sponsors in requesting new proposals from plan providers, third-party administrators, fiduciary service providers, and others. Through consultations with plan sponsors, we identify desirable plan characteristics and find vendors who can meet those goals. We generally identify alternatives for each decision point and after acquiring relevant data from potential vendors arrange for presentations from those vendors to plan sponsors/plan trustees. We provide advice related to final decision-making and vendor selection. C. Financial Planning a. Financial Planning Services – Services offered to 'Portfolio Management' clients at no additional cost. It is our opinion that a comprehensive understanding of a clients' complete financial plan allows us to do a better job of constructing portfolios that meet client objectives. 3. Explain whether you tailor your advisory services to the individual needs of clients and whether clients may impose restrictions on certain securities or types of securities. Elevate offers investment advisory services that are tailored to the specific needs of our clients. Our client may be an individual, family, or entity and may engage us for Portfolio Management, Pension Consulting, and/or Financial Planning Services. A. Portfolio Management We maintain an active management approach to markets. Our proprietary investment strategies are used either as standalone portfolios or in various combinations that most closely align with our client’s investment goal and risk tolerance. If an optimal portfolio cannot be designed using any of these approaches a custom strategy may be designed and implemented. Clients may impose reasonable restrictions on securities owned in their accounts. Restrictions must be imposed by providing the symbol for each security to be restricted from investment. B. Pension Consulting Each company, benefit plan, and census are unique. Our compensation is not dependent on the selection of any vendor, product, or investment. Each time we are engaged by a plan sponsor, our analysis and service are specifically tailored to that engagement. C. Financial Planning Elevate offers financial planning, which may include project-based analysis, market research and consulting services, that are not tied directly to managing assets. Using our state-of- the-art financial planning software and decades of experience and professional education, we will identify areas where there may be opportunity to improve your situation and ways to optimize the efficiency and effectiveness of your financial plan. a. Elevate Planning Process: i. Discovery: We ask questions and listen carefully. Two sets of information are involved. First are your desires and goals, and second are the facts and data. ii. Clarification: Once a first draft of your plan is created, we meet to feed back to you what we heard you say and refine the information until it is accurate. iii. Share Ideas: We will make specific recommendations on actions to take and explain the pros and cons of each recommendation. iv. Implementation: This is the process of executing on the recommendations we make. We will prepare all necessary forms for signature. Execute transactions to bring portfolio into alignment with target allocations. v. Periodic Review: Review the financial plan and IPS and adjust the plan and portfolio as needed. Elevate is neither a law firm nor a tax advisor, and we do not provide legal or tax advice of any kind. To the extent requested by a client, we may recommend the services of professionals in these areas of expertise. The client is always free to choose to work with any professional they wish, regardless of our recommendation. The client retains absolute discretion over all decisions. The recommendation that a client engage the services of an Elevate representative in his/her capacity as an insurance agent represents a conflict of interest, as the payment of commissions for insurance sales may provide an incentive to recommend such products based on said compensation rather than the client’s need. Clients may implement our recommendations with anyone they wish, including other non- affiliated professionals. 4. Wrap Fee Programs Elevate does not participate in any wrap fee programs. Wrap fee programs offer services for one all-inclusive fee. 5. Assets Under Management As of December 31, 2023, Elevate managed $139,761,945 with $126,294,906 managed on a discretionary basis and $13,467,039 managed on a non- discretionary basis.