Cutler Investment Counsel, LLC (“Cutler” or the “Firm”) is an investment advisory firm founded in 2003. Cutler & Company, Inc. was founded in 1977, and reorganized to Cutler Investment Counsel, LLC in 2003. Cutler is headquartered in Jacksonville, Oregon. Cutler provides the following services:
• Investment consulting and portfolio management for 401(k) and other retirement plans.
• Individual investment portfolios, using a full spectrum of asset classes and different types of securities (for example stocks, mutual funds, exchange traded funds (“ETFs”), and bonds). These investment programs are both risk-based portfolio and target-date portfolios. Certain Cutler employees advise clients on which investment portfolio is in their best interest.
• Dividend‐based equity strategy for individuals, institutions, and foundations. This strategy, called Cutler’s Equity Income Strategy, buys large, US‐based companies with a defined dividend history. This strategy is also available as a mutual fund, the Cutler Equity Fund (DIVHX), of which Cutler is the investment adviser.
• An automated investment program through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds and a cash allocation. We use the Institutional Intelligent Portfolios® platform, offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors to operate the Program. Please review our Wealth Management ADV 2A brochure for additional disclosures on this program.
• Cutler will occasionally act as an expert witness in a court of law. Cutler generally charges $300-$400 per hour

for this service. Cutler will occasionally customize the above strategies, depending on the needs and objectives of individual clients. At the onset of the client relationship, Cutler obtains each client’s investment objectives, risk tolerance, and other information relating to the client’s overall financial circumstances, which may be written or verbal. Whether provided verbally or in written form, Cutler will allocate assets according to these guidelines, until our client directs us to do differently. In this Brochure, we refer to any of these directives as “Investment Guidelines”, although they are also referred to as an Investment Policy Statement. These Investment Guidelines are used to determine the suitable portfolio asset allocation and investment strategy for the client and/or the appropriate investment choices available for their participants. Cutler does not assume any responsibility for the accuracy of such information provided by the client, is not obligated to verify any information received from a client or from a client’s other professionals (e.g., attorney, accountant, etc.), and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying Cutler in writing of any material changes to their Investment Guidelines. In the event that a client notifies Cutler of changes in such information, Cutler will review the changes and recommend any necessary revisions to the client’s portfolio or investment line-up. Assets Under Management As of December 31, 2023, Cutler managed client assets totaling $1,177,313,040. Of those assets, $1,106,189,429 are managed on a discretionary basis and $71,123,611 on a non-discretionary basis.