High Plains Investment Advisors, Inc. (“HPIA”, “We”, “Us”, “The Firm”) was founded in 1998. The principal owner is Timothy D. Mack. Brad Pruitt is also an owner. High Plains Investment Advisors, Inc. manages investment portfolios for individuals, high net worth individuals, businesses, trusts, foundations and charitable institutions. We also provide participant education and advisory services to defined contribution retirement plans. Our investment approach primarily focuses on evidence-based (passive) investing strategies primarily through the use of passively-managed mutual funds, index mutual funds and exchange-traded funds (“ETFs”). We typically utilize model portfolios to ensure that advice given to clients is consistent with the strategies we recommend. We do not provide market timing advice. We do not recommend individual stocks. We provide investment advice only with respect to the following types of investments: exchange- traded funds, open-end mutual funds, stocks, corporate and municipal bonds, certificates of deposit, and treasury securities. Our advisory services are tailored to the unique needs of each individual client. We will work with the client to determine the client’s investment objectives and investor risk profile and will design a written investment policy statement. We will continuously monitor the client’s portfolio holdings and the overall asset allocation strategy and attempt to hold periodic review meetings (via telephone, email, or in person) with the client regarding the account as necessary, and as the client desires. Clients may impose reasonable restrictions on investing in certain securities or types of securities. Our primary service is to provide investment advice. However, as a complement to our investment advice, we also provide financial planning services in one or more of the following areas: retirement planning, tax mitigation and planning, asset transfer assistance, asset protection assistance, estate planning, social security planning and charitable giving planning and/or other related services for certain clients. We use a third-party platform to facilitate the management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, we will review the current account allocations.

When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An employee may use a combination of those options, such as; (i) leave the funds in the former employer’s plan, if permitted, (ii) roll over the funds to a new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the individual’s age, result in adverse tax consequences). If your designated investment adviser representative recommends that you rollover your retirement plan assets into an account to be managed by our firm, such recommendation creates a conflict of interest insofar as we will earn an advisory fee on the rolled over assets. You are under no obligation to roll over retirement plan assets to an account managed by us. As of December 31, 2022, we managed approximately $119,994,000 of client assets on a discretionary basis and approximately $4,994,000 of client assets on a non-discretionary basis.