This Disclosure document is being offered to you by Boulder Wealth Advisors (“Firm”). It discloses information about our services and how those services are made available to you (the “Client”). We are an investment management Firm located in Boulder, CO. Boulder Wealth Advisors provides personalized, confidential financial planning, and investment management to individuals, families, trusts, pension and profit-sharing plans, estates, charitable organizations, and corporations. Our Firm was founded in 1997 and registered as an investment advisor since 2001. The firm is owned by Gary Shirman and Michael Hake. We primarily invest in stocks, bonds, mutual funds, BDCs/REITs, ETFs, and ESG/Social securities. A portion of the account may be held in cash, cash equivalents, or money market funds as part of the overall investment strategy. Cash balances may have a higher concentration and represent a significant portion of your overall portfolio depending on the current investment outlook or strategy. Our Firm generally requires a minimum account size of $500,000 for advisory accounts. However, from time to time, at our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets, related accounts, and other individual Client circumstances. We are committed to helping clients build, manage, and preserve their wealth, and to provide assistance to achieve their stated financial goals. We may offer an initial complimentary meeting upon our discretion. However, investment advisory services are initiated only after a Financial Planning Agreement or Investment Management Agreement has been signed. INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES Our Firm manages advisory accounts on a discretionary basis. Advice is provided through consultation with you, the client, and may include determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate plan reviews. We determine your investment objectives, time horizons, risk tolerance, and liquidity needs during our initial discussions. As appropriate, we also review your prior investment history, family composition, and background. Based on your needs, we develop a personal profile of investments to be included in your portfolio and we will provide ongoing portfolio review and management services. We tailor our advisory services to meet our clients' needs and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions to refrain from investing in limited amounts of securities. We will rebalance and/or make changes to the portfolio, as we deem appropriate, to meet your financial objectives. Once we have determined your profile and investment plan, we will execute the day-to-day transactions without seeking your prior consent. It is the client’s obligation to notify us immediately if circumstances have changed with respect to your goals and/or changes in your personal financial condition. You are advised and are expected to understand that our past performance is not a guarantee of future results.

Certain capital market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. 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, 529 Plans, and assets held in employer-sponsored retirement plans. In these situations, Boulder Wealth Advisors directs or recommends FEBRUARY 2024 | PAGE 5 allocating client assets among the various investment options available. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. FINANCIAL PLANNING Through the financial planning process, our team strives to engage our clients in conversations around the client’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each client in mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and client legacy objectives. Our team partners with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include:
• Determination of appropriate income planning strategies for both pre- and post-retirement timeframes.
• Review of existing and proposed investment asset mixes to help you meet your overall financial objectives. This would include a review of risk/return issues and a suggested plan of action consistent with your risk tolerance and overall financial objectives.
• Calculation of your pre-retirement savings and investing needs.
• Assessment of your overall financial position including net worth, cash flow, and debt.
• Analysis of IRA-related issues including rollover, distribution, and inheritance planning options.
• Estimates of your federal estate taxes and a suggested plan of action to help meet estate planning objectives.
• Review and determination of your life and disability insurance needs.
• Suggestions for minimizing your federal and state income tax obligations.
• Development of investment strategies consistent with your business ownership succession and transition planning, if applicable. Our financial planning services provide you with a personalized financial model to help you make financial decisions. We have designed a unique financial planning software program to create personalized retirement plans. This service helps you make important financial decisions throughout your lifetime. WRAP FEE PROGRAM We do not place clients in a wrap fee program. ASSETS As of December 31, 2023, Boulder Wealth Advisors managed $246,278,983 in Assets under Management. We do not manage assets on a non-discretionary basis. FEBRUARY 2024 | PAGE 6