Firm Information This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications, business practices, and the advisory services provided by CLS Financial Advisors, Inc. (CLS or “the Firm”, “we”, “us”, “ours”). We are a federally Registered Investment Adviser with the U.S. Securities and Exchange Commission (“SEC”).We were founded in 2001 and are owned and operated by Lori L. Pajunen- Luck, Ryan A. Genor and Sarah L. Lane. Our investment advisory services are driven by and coordinated with each client’s individual financial goals. Our approach uses broadly diversified portfolios and a systematic strategy to manage investments. Our Process Wealth Management We set up an initial meeting at no charge to get to know potential new clients, so we understand who they are and what they need. We assess whether our approach is a good fit for their needs. Assuming there is a good fit, we then help clients define goals, organize their financial assets and formulate a systematic strategy to manage them. We incorporate risk tolerance technology, asset allocation design, and asset monitoring tailored to each unique situation. We coordinate employer retirement account choices with other investments to build a diversified portfolio. After the strategy is implemented, we are available to answer questions and help with financial decisions. We meet with clients quarterly, or as needed, to review portfolio performance, discuss current issues, and re-assess goals and plans. We include ongoing planning work and investment monitoring in our advisory fees. We prepare and update retirement planning projections and work with our clients and their attorneys on estate planning issues. We review risk management needs and coordinate with insurance agents. We address cash flow and budgeting issues and planning for college costs for clients who have those needs. We consider tax planning in all financial and investment plans. Our investment recommendations generally include mutual funds, exchange-traded funds, and exchange-listed equity securities. We also recommend certificates of deposit, municipal securities, U.S. government securities, and money market funds. If clients want to hold other types of investments, we will advise them on these investments if we think we are qualified to do so. For example, we do not advise on privately held real estate. Limited Consulting Services We also offer investment advice on a more limited basis. This may include advice on reviewing a client’s existing portfolio only in an isolated area(s) of concern such as estate planning, retirement planning, or other specific topic. Advice is provided through consultation with the client and may include determination of financial objectives, identification of financial problems, cash flow management, tax planning, risk management review, investment management, education funding, retirement planning, and estate

planning. Tailored Relationships We tailor investment advisory services to the individual needs of the client. Our clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to us in writing. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. We do not sponsor, manage or participate in a Wrap Fee Program. Fiduciary Statement 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. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when dealing with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Assets Under Management As of December 31, 2022, we manage $142,748,501 of client assets; $123,261,966 on a discretionary basis and $19,486,535 on a non-discretionary basis.