This Disclosure document is being offered to you by Peak Asset Management, LLC (“Peak”) about the investment advisory services we provide. It discloses information about the services that we provide and the manner in which those services are made available to you, the Client. We are an SEC-registered investment adviser with its principal place of business located in Louisville, Colorado. We began conducting business in 1994. Listed below are the firm's managers, owners and advisers:
• Terrance William Hefty (Manager, CRD No. 2766094);
• Noel Fletcher Bennett (Manager, CRD No. 4359632);
• John Neal McCorvie Jr., CFA (Manager and beneficial owner through McCorvie Financial, LLC, CRD No. 1509677);
• Tara Jill Hefty, CFA, FRM (Manager and beneficial owner through Tara J. Hume Financial Consulting, LLC. CRD No. 5469036);
• Terry L. Robinette (Manager, CRD No. 4355257);
• Brent C. Yanagida, CFP®, EA (Financial Planner and Manager, CRD No. 2393687);
• Julie F. Pribble, CFA (Manager, CRD No. 2319095);
• John H. Russell, CFA (Associate Adviser, CRD No. 7289033);
• Bethany A. Aylor, CFP® (Associate Adviser, CRD No. 6353182);
• Sophie Berglund, (Associate Adviser, CRD No. 7688713);
• Jason Foster, JD, AEP® (Director of Wealth Strategies and Legacy Planning, Manager, CRD No. 6592312);
• Grant Bugner, CFP®, (Associate Adviser, CRD No. 7306730). We will offer an initial complimentary meeting in our discretion; however, investment advisory services are initiated only after you execute an Investment Advisory Agreement (“Agreement”). Investment and Wealth Management and Supervision Services We offer discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. (In limited circumstances, we also offer non-discretionary investment management.) These services include investment analysis, allocation of investments, quarterly portfolio statements, financial commentaries, and ongoing monitoring of client portfolios. We primarily allocate client assets among cash, individual stocks, individual bonds, exchange traded funds (“ETFs”), mutual funds and other public securities or investments. We generally invest Client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the prudent return on our client’s cash balances through relatively low-risk and conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to this service. We primarily provide portfolio management to accounts belonging to individuals based on their specific needs. During our data-gathering process, we determine each client’s individual investment objectives, goals, time horizons, risk tolerances, restrictions, liquidity needs and any legal or regulatory constraints. As appropriate, we may also review and discuss a client’s prior investment history, as well as family composition and background. From this information, we develop a custom investment policy statement (IPS) with the client that we use to create and manage their portfolio. Since we are an independent registered investment adviser, our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Although we do not limit management to specific types of securities, we will only use types of investments we feel are consistent with a client’s objectives, tolerance for risk, liquidity, etc. In addition, clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors in their IPS. We will review with clients their IPS as needed or periodically. We will rebalance the portfolio as we deem appropriate to meet your financial objectives. We trade these portfolios and rebalance them on a discretionary basis based on our market views and on your objectives, using our investment process. 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. In all cases, you, the Client, have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate authorization from you. Where appropriate, we may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage us to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). 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 may adversely affect an account’s performance. This could result in capital losses in your account. Peak requires an initial minimum portfolio value of $1,000,000 for new investment advisory clients. In limited circumstances, this minimum portfolio value requirement is negotiable. Participant Account Management (Discretionary) We use a third-party platform, Pontera, to facilitate 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, Adviser will review the current account allocations. When deemed necessary, Adviser 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. Financial Planning Financial Planning services are included with our investment management services. In limited circumstances, our Firm offers stand-alone financial planning services. For clients engaging our Firm for financial planning services only, financial planning is offered under a separate agreement and separate fee. The specific services and deliverables will be defined in the Financial Planning Agreement. For clients participating in our financial planning services, we conduct an analysis of your current situation and identify and implement appropriate financial planning and investment management techniques to help you meet your specific financial objectives. Such services may include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance regarding outside assets and periodic updates. In preparing your analysis, we may address any or all of the six areas of financial planning established by the National Endowment for Financial Education and endorsed by the Certified Financial Planner Board of Standards, depending on your specific needs. These include: financial position, risk

management, protection planning, investment planning, income tax planning, retirement planning, and estate planning. Our specific services in preparing your plan may include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position, including cash flow, balance sheet, investment strategy, risk management and estate planning.
• Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession and other personal goals.
• Development of a goal-oriented investment plan around tax suggestions, asset allocation, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans, taxable and trust accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation and transfer, including liquidity as well as various insurance and possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax adviser, an estate plan to provide for you and/or your heirs in the event of an incapacity or death.
• Generation of a benefits plan, risk management plan and succession plan for your business, if applicable. Periodic reviews may also be provided to review specific courses of action recommended in the financial planning process. More frequent reviews may occur but are not necessarily communicated to the you unless immediate changes are recommended. SMA Sub-Advisor (“SMA”) Occasionally our firm will recommend utilizing the services of a Sub-Adviser in a “Separately Managed Account” (SMA) for the management of municipal bond portfolios in specific accounts. Upon the recommendation, we will review with the client initial due diligence on the SMA Managers we work with, and if the client agrees with the recommendation, the SMA’s Manager will be engaged to handle security selection and trading within the parameters we establish with the client and the SMA Adviser. We currently work with two SMA managers. One of the managers allows Peak to enter into the agreement on behalf of our clients, while the other requires a direct agreement with the specific client. In both cases, a separate account is set up at the custodian (Charles Schwab) for the assets that will be contributed to the SMA. Within the parameters established the SMA manager selects and executes all security purchases and sales. Peak monitors all account activity and performance and reports the SMA account information on our regular quarterly report to the respective client. If, at any time, Peak no longer believes that the SMA is still a good solution, we will contact the respective client to discuss changes. Retirement Plan Advisory Services We make available management services to assist businesses with administration of their participant directed defined contribution retirement plans. The scope of a retirement plan engagement, which may include selecting of investment options, monitoring of these options, and any performance reporting to the plan, is negotiated on a case by case basis in advance and agreed upon contractually. Disclosure Regarding Rollover Recommendations We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you, the Client, 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. An individual 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) rollover 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, income and other factors, result in adverse tax consequences). Our Firm may recommend an investor rollover plan assets into an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives will 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 that Peak will not provide investment advisory services on, will generally result in no compensation to our Firm (unless our firm has been specifically engaged to manage those assets). 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. Newsletters We publish a newsletter, Financial Intelligence, that provides general information on various financial topics including, but not limited to, financial planning, estate planning or retirement planning, and economic trends. The information provided is intended to be educational in nature and does not include specific investment or planning recommendations to meet the objectives or needs of any specific individual. Financial Intelligence is distributed free of charge to our advisory clients (as well as to prospective clients, business contacts, friends and relatives). We also distribute a general client letter with our quarterly account reports to clients. The client letter is intended to provide insight regarding our perspective on the financial markets and economic events. This client letter is distributed free of charge to our advisory clients (as well as to prospective clients, business contacts, friends and relatives). We also publish and distribute a blog on our website, The Peak Perspective. The blog is intended to complement our Financial Intelligence publication and quarterly client letters with additional insights and commentary on financial planning topics, financial markets, and economic events. The information provided is intended to be educational in nature and does not include specific investment or planning recommendations to meet the objectives or needs of any specific individual. The blog is distributed free of charge to our advisory clients (as well as to prospective clients, business contacts, friends and relatives) and can be accessed at any time on Peak’s website or via Peak’s company page on LinkedIn. Wrap Fee Programs We do not place Client assets into a wrap fee program. Assets As of December 31, 2023, we have $816,847,480 under discretionary management and $8,284,820 in non- discretionary assets under management. Our total assets under management are $825,132,300.