Overview CliftonLarsonAllen Wealth Advisors, LLC (“CLA Wealth Advisors” or the “Firm”) is an investment advisor registered with the U.S. Securities and Exchange Commission (the “SEC”) since 2000. CLA Wealth Advisors is a wholly-owned subsidiary of CliftonLarsonAllen LLP, a professional services firm that provides a variety of services including audit and assurance, consulting, international, outsourcing, and tax services. CliftonLarsonAllen LLP was formed on January 2, 2012 through the merger of two established CPA firms: Clifton Gunderson LLP and LarsonAllen LLP. Prior to that merger, CLA Wealth Advisors was known as LarsonAllen Financial, LLC and was solely owned by LarsonAllen LLP. Clifton Gunderson LLP, in turn, owned another investment advisor – Clifton Gunderson Wealth Advisors LLC - which combined with CLA Wealth Advisors after the merger of the accounting firms. CLA Wealth Advisors’ primary place of business is in Minneapolis, Minnesota. The firm has approximately 38 additional offices located across the U.S. CLA Wealth Advisors is also registered as a broker-dealer and has been a member of the Financial Industry Regulatory Authority (“FINRA”) since 1995, and of the Municipal Securities Rulemaking Board. As a broker- dealer, CLA Wealth Advisors conducts brokerage activity for its clients primarily, but not exclusively, related to variable life insurance products and variable annuity products. CLA Wealth Advisors may also conduct brokerage activity related to mutual fund trades and merger and acquisition services on behalf of its clients. CLA Wealth Advisors is also licensed as an insurance agency in Minnesota and other states. As an insurance agency, CLA Wealth Advisors offers clients fixed and variable life insurance products and variable annuity products. In this brochure, “we,” “our,” “us” and similar words mean CLA Wealth Advisors. CLA Wealth Advisors primarily provides wealth advisory and asset management services. The largest part of our asset management service is the management of client accounts on a discretionary basis. We also manage accounts on a non-discretionary basis, furnish investment advice through consultation, and furnish advice on matters not directly involving securities, including financial planning. For each client account we provide services to on an on-going basis, we review and assess the client’s overall risk and return objectives periodically by questionnaire, interview, and verify investor return and risk goals at least one time per year. When applicable, we help clients execute a financial plan and Investment Objective Statement (referred to as “IOS”). Based on the client’s particular circumstances, including asset levels, risk tolerance, and short- or long-term goals, we tailor our advisory services and recommend to each client one or more investment portfolio solutions that are appropriate to the client’s individual needs. When recommending multiple portfolio solution options, we will explain the relative merits of each one and assist the client in determining which solution is right for them. Clients having multiple accounts under our management may elect to use different investment advisory solutions to meet their unique needs for each account. Revised 03/29/2024 Page 6 Wealth Advisory Services Financial and Estate Planning Services We provide consulting services in connection with personal financial matters. These services are offered through private consultations. Our services range from one-time consultations to a long-term relationship during which we provide financial planning services to fit client needs on a non- discretionary basis. We provide a modular approach to planning services to meet the client's specific needs. Areas of service include:
• Retirement planning
• Estate planning
• Investment advisory
• Education funding
• Risk management* *This service is provided free of charge in states which prohibit receipt of such fees when commissions or compensation is received for purchases of insurance products. In performing its services, CLA Wealth Advisors will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. If requested by the client, we may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from CLA Wealth Advisors. Private Client Services CLA has recently launched the Private Client Services (PCS) model that seeks to bring the experience and breadth of CLA knowledge to high-net-worth clients in a seamless way. PCS incorporates professionals from across all of CLA with deep industry experience in wealth advisory, estate, tax, risk and insurance planning. This approach is geared towards clients looking for a more wholistic experience to planning for their future. CLA believes that bringing multiple disciplines of professionals together to give a more unified and comprehensive approach will enhance the client experience. This is not a WRAP program as the services are billed individually by CLA LLP and CLA Wealth Advisors according to the engagement letters associated with each service. Business Succession Planning Services CLA provides business succession planning services and is compensated for such services based on a fixed fee arrangement (plus direct costs) or on a time and materials basis. Most often, this service is performed as part of an investment banking transaction. These succession planning services are often completed by a member of CLA LLP and billed according to the engagement agreement in place regarding those services if not included in the investment banking agreement. Individual Asset Management Services Revised 03/29/2024 Page 7 As discussed above, CLA Wealth Advisors provides both discretionary and non-discretionary investment advisory services to assist clients in developing and implementing comprehensive investment strategies for their investable assets consistent with their goals and objectives. We manage discretionary accounts primarily by using model portfolio solutions that consist of selected mutual funds and Exchange Traded Funds (“ETF”). The Firm has historically provided many of its clients with investment solutions that consist of model portfolio strategies that the Firm itself constructs and manages. In the past several years, we have added additional portfolio solutions that reflect the investment management strategies of recognized major third-party investment firms. We believe that each investment solution offers its own advantages, and we consider individual client needs, goals, and objectives in helping

them select a solution that is most appropriate for them. An Investment Committee meets regularly to review technical and fundamental research data and discuss and formulate solutions and strategy. The committee discusses and reviews investment instruments for use within the Firm’s own model solutions, as well as selecting, designing, and monitoring portfolio solutions that are managed by or through third party providers. In connection with our investment advisory solutions, there are several business practices that create actual or potential conflicts of interest with our clients. Please see Section 10 below for information concerning conflicts. Clients may impose reasonable restrictions on their account, i.e. socially responsible investing, managing around concentrated positions and other assets held outside CLA Wealth Advisors. We will discuss such restrictions with clients and advise them immediately if we are not able to accommodate the restriction(s) for any reason. Clients are advised to provide their advisor with updated information about their financial situation or objectives for the purpose of reviewing, evaluating, or revising our previous recommendations or services. Information concerning the investment advisory solutions we use is contained below in Section 8. As of December 31, 2023, CLA Wealth Advisors managed $6,018,588,054 of assets on a discretionary basis, and $1,959,213,309 on a non-discretionary basis. Advisory Services to Qualified Retirement Plans We also provide advisory services to pension, profit sharing and 401(k) plans. These services typically include the following:
• Investment Objective Statement (Plan IOS) Preparation - We will meet with the client (the plan or plan sponsor) to determine an appropriate investment strategy that reflects the plan’s stated investment objectives for management of the overall plan. Our Firm then assists the client in preparing a written Plan IOS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The Plan IOS also lists the criteria for selection of investment vehicles, as well as the procedures and timing interval for monitoring investment performance.
• Selection of Investment Vehicles - We will construct appropriate asset allocation models and help plan sponsors open investment accounts with an appropriate custodian. We will then review various mutual funds (both index and managed) to determine which Revised 03/29/2024 Page 8 investments are appropriate to implement the client's Plan IOS.
• Monitoring of Investment Performance - We monitor client investments, based on the procedures and timing intervals outlined in the Plan IOS.
• Employee Communications - For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self- directed plans''), we may also provide educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will not provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. CLA Wealth Advisors will, however, provide such individualized services if the participant enters into a separate individual engagement agreement. Retirement Plan Administration Services CLA Wealth Advisors also provides separate Third-Party Administrator ("TPA") services to a limited number of sponsors of qualified retirement plans. The TPA provides back-office support services, and in particular, a full spectrum of account recordkeeping services. These TPA services are separate and distinct from the advisory services we provide and are provided under a separate engagement agreement and for separate compensation. We may refer clients to the TPA practice, and it may refer clients to us, but there is no referral fee arrangement. No advisory client who is a sponsor or trustee of a qualified retirement plan is obligated to use the TPA for third-party administrative services, and no client of the TPA is obligated to utilize our advisory services. Sponsors or trustees of pension, profit-sharing, 401(k), IRA or other client accounts subject to the provisions of ERISA or the prohibited transaction provisions of the Internal Revenue Code are solely responsible for determining whether to engage the services of the TPA. Capital Markets Activities In December of 2022, the Firm transitioned from an active participant in the Capital Markets space, conducting capital raising activities to a passive participant. The Firm will no longer actively raise capital for real estate developers or their projects. The Firm will continue, from time to time, to act as a broker for certain projects with institutional investors going forward. Prior to this change in approach, the Firm acted in the capacity as a placement agent for certain firm clients with real estate development projects. The Firm assisted these clients in raising capital from institutional investors that meet certain investment asset thresholds with the ability to conduct an independent due diligence process. Investment Banking and Sell-Side Representation The Firm will engage as a broker dealer in certain sell-side business succession representation. As part of this activity, our representatives will represent business owners in the marketing and sales process for their businesses including valuation, quality of earnings and in the identification of potential buyers. Educational Seminars/Workshops/Speaking Engagements Revised 03/29/2024 Page 9 CLA Wealth Advisors occasionally conducts educational wealth and life management seminars for select high net worth clients and potential clients. The seminars typically involve presentations on various life and wealth planning topics including retirement and lifestyle strategies, investment markets and strategies, and services offered by CLA Wealth Advisors and its affiliated entities. The seminars are typically one to three days in length and are provided by the firm at no charge. Certain third-party firms who sponsor and manage investment opportunities that CLA Wealth Advisors recommends to its clients often provide financial support for the planning and conduct of these seminars. No investments are offered at these seminars and attendees are under no obligation to either invest with any investment managers who may appear at or sponsor the seminars, nor are they under any obligation to become a client of CLA Wealth Advisors after attending any of our seminars. For third-party speaking engagements, fees for such engagements are negotiated on a case-by-case basis.