Item 5 - Additional Compensation .......................................................................................................................... 23 Item 6 - Supervision ..................................................................................................................................................... 23 Item 7 - Requirements for State-Registered Advisors ................................................................................... 23 v Brochure Supplement (Part 2B of Form ADV) .......................................................................... 25 Principal Executive Officer - Nicholas K. Heyer ................................................................................................ 25 Item 2 - Educational Background and Business Experience ....................................................................... 25 Item 3 - Disciplinary Information ........................................................................................................................... 25 Item 5 - Additional Compensation .......................................................................................................................... 25 Item 6 - Supervision ..................................................................................................................................................... 25 Item 7 - Requirements for State-Registered Advisors ................................................................................... 25 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 27 Marc C. Hadley, CFP® .................................................................................................................................................... 27 Item 2 - Educational Background and Business Experience ....................................................................... 27 Item 3 - Disciplinary Information ........................................................................................................................... 28 Item 5 - Additional Compensation .......................................................................................................................... 28 Item 6 - Supervision ..................................................................................................................................................... 28 Item 7 - Requirements for State-Registered Advisors ................................................................................... 28 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 30 Timothy S. Fahey ............................................................................................................................................................ 30 Item 2 - Educational Background and Business Experience ....................................................................... 30 Item 3 - Disciplinary Information ........................................................................................................................... 30 Item 5 - Additional Compensation .......................................................................................................................... 30 Item 6 - Supervision ..................................................................................................................................................... 30 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 32 Nathan Travis .................................................................................................................................................................. 32 Item 2 - Educational Background and Business Experience ....................................................................... 32 Item 3 - Disciplinary Information ........................................................................................................................... 32 Item 5 - Additional Compensation .......................................................................................................................... 32 Item 6 - Supervision ..................................................................................................................................................... 32 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 34 Susan Jalics Becker ........................................................................................................................................................ 34 Item 2 - Educational Background and Business Experience ....................................................................... 34 Item 3 - Disciplinary Information ........................................................................................................................... 34 Item 5 - Additional Compensation .......................................................................................................................... 34 Item 6 - Supervision ..................................................................................................................................................... 34 Firm Description Nicollet Investment Management, Inc. (“Nicollet”) was established in 1971 in Minneapolis, Minnesota. Mark C. Hoonsbeen is the Principal of Nicollet. Nicollet's investment services and fees are charged for the work done in structuring and managing portfolios of stocks and bonds for clients. The portfolios may be 100% individual stocks, 100% individual bonds, 100% exchange traded funds or similar security, 100% mutual funds, or a blend of individual stocks, bonds, exchange traded funds (or similar security), and mutual funds. Most of our clients will have their portfolio managed using individual stocks and bonds in some blend. Nicollet also offers the option to do financial planning with or without investment management. This includes cash flow, retirement, education, estate planning and financial goal analysis. Types of Advisory Services Investment Management Services Offered Nicollet has two internally managed stock strategies. One is a large capitalization growth stock strategy that primarily invests in companies whose market capitalization is greater than $40 Billion. This strategy is diversified by both owning at least 20 individual companies, but more typically by holding 30 to 40 individual company stocks. The strategy is also diversified in that we select companies in a broad range of economic sectors and industries. Nicollet also manages a mid-to-small capitalization growth stock strategy. This strategy primarily invests in companies whose market capitalization is less than $40 Billion. This strategy adheres to the same criteria on diversification (discussed above) as does our large capitalization growth stock strategy. Nicollet offers an alternative method for clients to have their money invested in stocks using mutual funds or exchange traded funds. Typically the investments used in this strategy employ an indexed approach to investing. Clients of Nicollet who prefer to have their stock investments managed in funds are subject to a different fee structure than those investing in individual stocks. Nicollet also buys fixed income securities for its clients. Unlike our stock strategies where clients using one or both of our stock strategies would typically be invested in a similar portfolio of holdings, our bond strategy does not seek to own the same securities in each client's portfolio. Nicollet's fixed income strategy is to customize a fixed income portfolio for each client based on the client's circumstances, including their cash requirements, need to preserve the value of their portfolio, income tax rates, and/or other criteria specific to the client. In our fixed income strategy, we take into consideration general conditions in the fixed income market that may influence our decisions on purchases or sales of fixed income securities in all clients' accounts. Our fixed income strategy will examine and consider all fixed income securities in the market when making decisions for clients. These securities include: securities issued by Governmental bodies (all levels of government), securities issued by agencies of Governmental bodies, securities issued by corporations, securities issued by limited partnerships. Typically, we will not consider for investment any fixed income security that is not at least of investment grade rated (BBB- or Baa) by the major credit reporting agencies. However, in limited cases, we may have in a client’s account a security with a rating below investment grade. Nicollet works with each of our clients to establish the appropriate mix of stocks and bonds in that client's portfolio. We do not charge a separate fee for this service when the client hires us for our Investment Management Service Typically, that mix is established for the client's entire portfolio, which includes investment accounts that Nicollet manages and the client’s accounts that we may not manage (in those cases where Nicollet does not manage the client's entire portfolio of accounts). The decision on the appropriate mix will establish for the client, the amount or percentage the client will hold in subclasses of securities like large capitalization stocks verses mid-to- small capitalization stocks. The target mix of investments is established through discussions with the client regarding their goals and needs for their investments and is used by Nicollet as a general guide for allocating investments in the client's accounts. Reviews of client holdings of stocks and bonds and comparisons to original targets are an ongoing part of our operations. The original targeted weighting of stocks and bonds is meant to set initial targets and we fully expect those weightings to change and communicate this to our clients. Some clients of Nicollet may not wish to consult with us on the mix in their investment portfolio but instead make those decisions without consultation with Nicollet. In these instances, the client may either have another adviser assisting them in making these decisions or choose to make those decisions themselves. In these instances, we will rebalance the weighting between stocks and bonds, or in other ways, whenever the client requests. In those cases where Nicollet is asked to assist with the determination of the mix of stocks and bonds in the client's accounts, those choices are reviewed each time we meet with the client, or whenever the client asks us to review those choices. Our client's accounts are also reviewed

when individual investment decisions are being made, anytime a significant deposit of cash or securities occurs in the client's account(s), or periodically as part of a general review of all client accounts. For some of our clients, they may have accounts which are too small to efficiently purchase a portfolio of individual stocks and are accounts whose purpose is distinct from the goals of the client's other accounts. A typical example of this is an account held for children to fund college expenses. In these cases, we may recommend the account be managed using an exchange traded fund (ETF) or a mutual fund where the appropriate investment strategy, because of the small size of the account, can be implemented more cost effectively using that type of security. In other cases, for instance, clients who own a business and the account we are managing is a retirement plan, we may also offer ETFs or mutual funds as investment options for the client. When hired for our Investment Management Service, Nicollet handles the day-to-day management of its clients' accounts by making decisions on buying, selling, or holding securities in our clients' accounts. Our clients' security holdings are not held at Nicollet (we do not custody accounts). Instead, our clients custody their securities at a separate firm, typically a broker/dealer such as Charles Schwab or TD Ameritrade (custody agent). To perform Investment Management Services for our clients' accounts, Nicollet has the authority through its agreement with the client, to make purchases or sales of securities in the clients' accounts held at the custody agency. Based on its agreement with clients, we do not contact the client prior to making a purchase or sale decision in the client's account as the client has granted us authority to make those decisions without consultation. In addition to assisting clients in determining the proper mix of stocks and bonds in their accounts and managing those accounts, we may also assist clients with advice on other financial matters. Clients of Nicollet often ask for our opinion on matters that include: debt and debt refinance, the need for insurance, financing decisions surrounding large expenditures, and other financial matters that families or businesses face. We provide advice and perspective on these matters when asked, but do not hold ourselves out to be experts in all matters outside of structuring and managing investment portfolios. When a client's question requires the assistance of an expert in the field in which the question is being asked, we will suggest the client consult with an expert. If asked by the client, we have participated with our clients in conversations on matters outside Nicollet’s expertise solely on the client’s direction and desire that we either help them frame their questions or provide our opinions on the expert's recommendation. Nicollet also works with clients on matters pertaining to their potential income taxes but does not charge a fee for this service when the client has hired Nicollet for our Services. Typically, towards the end of each year we will contact our clients (or in some cases their accountant) who have taxable accounts under our management. We will discuss with those clients realized gains and losses which are taxable. To the extent that Nicollet is directed by the client (or their accountant) to minimize gains or losses, or maximize gains or losses, based on the client’s (or their accountant’s) assessment of their need for such gains or losses, and to the extent there are unrealized gains or losses in the client’s taxable accounts that allow us to comply with those instructions, we will execute sales of securities solely for the purpose of recognizing gains or losses to assist clients in managing their income tax liability. Financial Advisory Service Nicollet’s Financial Advisory Service includes advice from Certified Financial PlannerTM Professionals on a broad scope of personal financial planning issues including retirement planning and retirement account management strategies, investment planning and asset allocation strategies, income tax and estate planning, college education finance planning, and wealth transfer planning. Our advice is always tailored to meet the specific needs and circumstances of each client. Services are offered using client consultations and company generated written reports that may include advice about investment securities including individual equity and debt securities, mutual funds, exchange traded funds, fixed and variable annuities, unit investment trusts and direct participation programs. Financial Advisory services are offered on a flat fee scale based on clients’ proximity to retirement and complexity of their personal financial picture. These services are offered without requirement to engage in investment management services. ERISA PLAN SERVICES Nicollet provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. Nicollet may act as either a 3(21) and/or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. Nicollet may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor Nicollet has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Nicollet can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. Nicollet acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Nicollet’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Nicollet is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Nicollet may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. 3. Nicollet has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. ERISA 3(38) Investment Manager. Nicollet may also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. Nicollet would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• Nicollet has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands that Nicollet’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Nicollet is not providing fiduciary advice as defined by ERISA to the Plan participants. Nicollet will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Nicollet may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Nicollet and Client. 3. Nicollet has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Nicollet on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs Nicollet does not sponsor any wrap fee programs. Client Assets under Management Nicollet has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $430,713,545 $0 06/30/2023