Information About the Firm Peak Financial Management, Inc. (Peak, the Firm, we, us, our) is a federally registered investment adviser with its principal place of business located in Wellesley, Massachusetts. Peak began conducting business in 1991. The Firm’s principal owner is Pran N. Tiku, President. We offer the following advisory services to our clients: Portfolio Management We provide continuous advice to clients regarding the investment of client funds assessed on the individual needs of the client. Through personal discussions, in which goals and objectives based on a client’s particular circumstances are established, we assign a client a model investment policy and manage their portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. We provide portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), time horizon, as well as tax considerations. Through personal discussions with the client in which the client’s goals and objectives are established, we determine if the model portfolio is suitable to the client’s circumstances. Once we determine the suitability of the portfolio; the portfolio is managed based on the portfolio’s goal, with adjustments based on each client’s individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. Our Model Portfolios are as follows: Conservative Model: Suitable for investors who desire to preserve portfolio principal with a low tolerance for risk and significant withdrawal needs. Income Model: Suitable for investors who need current income and want to preserve their future purchasing power with some growth. Client has low-moderate risk tolerance with regular and significant withdrawal needs. Balanced Model: Suitable for investors who want to balance income preservation with future growth. Client has moderate-average risk tolerance and semi-regular withdrawal needs. Moderate Growth Model: Suitable for investors who have no near-term income needs, are adding to the portfolio and can withstand market risk to achieve future growth. Client has above average risk tolerance and no withdrawal needs other than unexpected expenses. Growth Model: Suitable for investors who will have other sources of retirement income are adding to the portfolio and can withstand extreme market risk to achieve future growth. Client has very high-risk tolerance and no withdrawal needs. The underlying composition and allocation of asset classes may change in the models from time to time at our discretion based on market conditions and changes in client needs. Our investment recommendations are not limited to any specific product or service offered by a custodian or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over the counter
• Certificates of deposit
• Mutual fund shares We may recommend investments in alternative investments, including real estate limited partnerships, oil and gas partnerships, or private equity and hedge funds. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity and suitability. Financial Planning We provide financial planning services. Financial planning is an integrated evaluation of a client’s current and future financial state by using currently known variables to attempt to predict future cash flows, asset values and withdrawal plans. Throughout the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. We may provide a written report which provides the client with a detailed financial plan designed to assist the client in achieving his or her financial goals and objectives. While the financial plan is based on each client’s goals and objectives, there is no guarantee that these goals will be achieved. In general, the financial plan may address any or all of the following areas:
• PERSONAL: We review family records, cash flow, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; and attempt to illustrate

the impact of various scenarios on the client’s current income tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client’s portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, disability, long-term care, liability.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s predicted cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans. We gather required information through personal interviews. Information gathered includes the client’s investments and investable assets, current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, which may include a questionnaire completed by the client, and we may prepare a written report. Should the client choose to implement certain recommendations identified by the plan, we recommend the client work closely with his/her attorney, accountant, and/or insurance agent, as we do not render legal or tax advice. Financial planning recommendations are not limited to any specific product or security offered by a broker, custodian or insurance company. Implementation of financial plan recommendations is entirely at the client’s discretion. Typically, an initial financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Sub-Advisory Relationships Peak provides sub-advisory services to unaffiliated registered investment advisers. For each sub-advised client, Peak will have discretionary authority to develop and implement an appropriate investment program based upon the client’s investment objectives, guidelines, restrictions. On an ongoing basis, Peak will provide investment advice and recommendations to the client, and place orders for the execution of all purchase and sale transactions. Tailored Relationships Peak tailors investment advisory services to the individual needs of the client. Peak clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to Peak in writing. Clients will retain individual ownership of all securities. 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, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), 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 working 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. Wrap Fee Programs Peak does not participate in a Wrap Fee Program. Assets Under Management As of January 31, 2024, assets under management equaled $404,735,183 and were all managed on a discretionary basis.