Broadview offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Broadview rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Broadview setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Broadview has been registered as an investment adviser since September 2009 and is wholly owned by Joe Dailey, Adam Dodge, Matt Goihl, Angie Pingel and Amanda Taylor. Prior to October 17, 2022, Broadview was formerly SJA Financial Advisory, LLC. As of December 31, 2023, Broadview had approximately $548,972,855 of assets under management, $548,234,059 of which was managed on a discretionary basis and approximately $738,796 of which was advised on a non-discretionary basis. While this brochure generally describes the business of Broadview, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, members, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Broadview’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services Broadview offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Debt Management
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence
• Education Funding In performing these services, Broadview is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Broadview does not serve as an attorney, accountant or insurance agent and does not prepare trust and estate planning documents or tax returns or sell insurance products. If requested by a client, the Firm may recommend certain attorneys, accountants, insurance agents or other professionals to assist with the implementation of its financial planning advice. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Broadview under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Broadview’s recommendations and/or services. When Broadview provides investment advice regarding a client’s retirement plan account or individual retirement account, it is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Broadview makes money creates some conflicts with a client’s interests. To address this conflict, Broadview operates under a special rule that requires it to act in the client’s best interest and not put its interest ahead of the client. In addition, Broadview’s sole source of revenue is fees paid by our clients. Broadview does not receive any other fees or compensation based on product sales. Investment Management Services Broadview manages client investment portfolios on a discretionary or non-discretionary basis using Modern Portfolio Theory, which is a theory that suggests diversification can increase the opportunity for positive relative performance and minimize market risk because certain investments do not move in unison. Using this theory, Broadview attempts to maximize long-term returns (net of inflation and taxes) and minimize volatility for a client’s individual risk tolerance and risk capacity by combining lower-correlation assets in a portfolio consisting primarily of mutual funds and exchange-traded funds (“ETFs”). Under certain circumstances, Broadview may also

utilize the services of unaffiliated third-party investment managers (“Independent Managers”) to invest a portion of a client’s portfolio directly in individual securities. Mutual funds, ETFs and the direct investment in individual securities by Independent Managers are collectively referred to as “Assets.” The Firm’s equity strategy seeks long-term capital appreciation by investing in Assets that provide exposure to domestic and foreign equity securities of various market capitalizations, including emerging and developed market economies, as well as commodities and real estate. The Firm’s fixed income strategy seeks income and reduced volatility by investing in Assets that provide exposure to fixed income securities, including domestic and foreign fixed income securities from emerging and developed market economies. These fixed income securities are of various durations and credit quality, which may include lower or unrated bonds. The Firm seeks to remain fully invested and cash typically represents less than 5% of a portfolio, depending on a client’s anticipated distribution needs and market conditions. The Firm employs these strategies in various combinations depending on each client’s personal financial goals and objectives, as well as time horizon and tolerance and capacity for risk. Asset allocations may vary at times depending on market conditions. Where appropriate, the Firm may also provide advice about any type of legacy investment held in client portfolios. Clients may restrict Broadview’s discretionary authority over legacy investments even when held in a discretionary portfolio. In such situations, Broadview does not research or monitor the legacy investment and is not responsible for the performance, reporting or subsequent events affecting the legacy investment; however, Broadview may take such securities into account when constructing and rebalancing client’s investment portfolio in accordance with the client’s personal financial goals and objectives. Clients may engage Broadview to manage and/or advise on certain investments that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Broadview directs or recommends the allocation of client assets among the available investment options. Broadview tailors its investment management services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Broadview consults with clients on an initial and/or ongoing basis to assess their specific risk tolerance, risk capacity, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Broadview if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Broadview determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, Broadview may select certain Independent Managers to actively manage a portion of its clients’ assets. Clients authorize Broadview to delegate the management of all or part of their assets to one or more Independent Managers without prior consultation, consent or approval. Clients will receive the written disclosure documents of the respective Independent Managers engaged to manage their assets and the platform used to access the Independent Manager, if any. Independent Managers and/or the platforms that offer the Independent Manager’s investment services will charge fees in addition to Broadview’s investment management fee. Broadview continues to provide services relative to the selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Broadview seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.