Copper Harbor Investment Advisors, LLC began operations in 2014. Copper Harbor Investment Advisors, LLC provides investment advice and financial planning advice to individuals, high net worth individuals, pension and defined contribution plans, trusts, estates, charitable/non-profit entities, corporations, and other business entities. Copper Harbor Investment Advisors, LLC is not engaged in any other lines of business. Copper Harbor Investment Advisors, LLC is wholly owned by Steve N. Hooyman, Amy J. Sitter, Jesse L. Nelson, Ramon Garrido Mateos and Robert J. Moore. Copper Harbor Investment Advisors, LLC is not under common control with another firm, nor does it control any other firm. The advisory services of Copper Harbor Investment Advisors, LLC are described in detail below. Copper Harbor Investment Advisors, LLC provides investment advice and financial planning advice through its Investment Advisor Representatives. Such Investment Advisor Representatives are known as Investment Managers and are the primary client contact person for a given relationship. Services for clients vary by both individual client and the type of investment advice requested. Copper Harbor Investment Advisors, LLC services can be divided into the broad categories of Investment Advisory Services, Retirement Plan Services and Self-Directed Accounts. Form ADV: Part 2A Page 3 Investment Advisory Services Copper Harbor Investment Advisors, LLC provides Investment Advisory Services which involve giving continuous advice to a client and making investments for a client based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, Copper Harbor Investment Advisors, LLC develops a client's personal investment objective statement and creates and manages a portfolio based on that policy. Copper Harbor Investment Advisors, LLC will manage advisory accounts on a discretionary basis. Account supervision is guided by the personal investment objective statement of the client. Copper Harbor Investment Advisors, LLC will also hold self-directed accounts for either retirement plan sponsored accounts or for individuals. Copper Harbor Investment Advisors, LLC will create a portfolio consisting of the following investments: individual stocks, bonds, mutual funds, exchange traded funds (ETF’s) and other investment vehicles. Copper Harbor Investment Advisors, LLC will allocate the client's assets among various investments, considering the overall risk tolerance outlined by the client. The investment vehicles will be selected based on any or all the following criteria: the performance history; investment cost structure, tax considerations, management stability, the industry sector allocation; market capitalization; mutual fund investment style; mutual fund consistency of return (standard deviation); and risk/volatility among other investment criteria that may be investment vehicle specific. Portfolio weighting will be determined by each client's individual needs and circumstances including cash flow needs, investment time horizon, Investment Policy Statement, and risk tolerance. Clients can place reasonable restrictions or constraints on the way their accounts are managed and retain the right to modify Account restrictions at any time by providing written notice of such changes to Copper Harbor Investment Advisors, LLC. Clients will retain individual ownership of all securities. As a rule, Copper Harbor Investment Advisors, LLC believes that investing is most successful when investors take a longer-term view defined of at least 5-7 years for more volatile investments such as stocks. Therefore, clients should not expect frequent investment changes in the portfolio particularly in periods of extreme stock market volatility. Most investment changes will be made because of the following conditions: investment allocations that deviate from the clients signed Investment Policy Statement; macro trends in the investment environment; investment vehicles that stray from original investment expectations; fundamental changes in investment vehicle structure such as changing expense structure in a mutual fund; etc. Investments are not held by Copper Harbor Investment Advisors, LLC. Instead, all investments managed by Copper Harbor Investment Advisors, LLC are usually held at the brokerage firm ("Custodian") through which transactions are placed. Copper Harbor Investment Advisors, LLC will most often utilize the services of either Charles Schwab Institutional or Fidelity Investments who will be employed as the Custodian (holder of the assets). Copper Harbor Investment Advisors, LLC does not assure or guarantee the results of its Investment Advisory Services; thus, losses can occur from following Copper Harbor Investment Advisors, LLC advice pertaining to any investment or investment approach, including using conservative investment strategies. Form ADV: Part 2A Page 4 Use of Sub-Advisors Copper Harbor Investment Advisors, LLC may recommend the use of independent investment advisors (“Sub-Advisors”) to manage all or a portion of investments within a client's Account. Clients may be required to enter into a separate investment management agreement with a Sub-Advisor for services provided by a Sub-Advisor. Each Sub-Advisor is granted discretion by the client to buy and sell securities for the client's Account. Clients are encouraged to carefully review each Sub Advisor’s Form ADV disclosure brochure for service level, fee, conflicts, and professional background information applicable to each Sub-Advisor's staff before entering into the agreement. It is important to note that even though certain Sub-Advisors may have achieved higher performance returns than others, they may not be recommended to a client by Copper Harbor Investment Advisors, LLC due to the influence of other factors, including the nature of a Sub- Advisor’s investment

style and time under which securities were managed to produce returns and other factors. Thus, Copper Harbor Investment Advisors, LLC may decide to select Sub- Advisors from a limited pool of firms based on objectives, manager experience, familiarity, costs, and performance, among other criteria. We do not judge performance only. Thus, as indicated above, each client grants each Sub-Advisor limited discretionary trading authority so the Sub-Advisor can place transaction orders at will for a client’s account. Each client can instruct the Sub-Advisor about investment restrictions the client would like followed during the management of the client’s account. There is no restriction on a client contacting the Sub-Advisor directly to discuss portfolio issues. Each client’s account is managed individually by a Sub-Advisor and is separate from other accounts managed by the Sub-Advisor. Each client receives a confirmation for each securities transaction placed by the Sub-Advisor and periodic custodian Account statements. The Client can terminate the relationship with the Sub-Advisor at any time in accordance with the separate Investment Management Agreement signed with the Sub-Advisor. Copper Harbor Investment Advisors, LLC also provides periodic assistance in evaluating the Sub- Advisor’s performance and, if necessary, recommends replacement of a Sub-Advisor when it is deemed necessary. Copper Harbor Investment Advisors, LLC does not recommend the replacement of a Sub-Advisor based on short-term performance. In the event there is meaningful change in the Sub-Advisor’s investment philosophy, loss of significant investment management personnel or a change in ownership, Copper Harbor Investment Advisors, LLC will re-evaluate the Sub-Advisor to determine whether the Sub-Advisor's services or performance have changed and whether to recommend a Sub- Advisor change to a client. Retirement Plan Services Copper Harbor Investment Advisors, LLC provides the following service(s) to a client's retirement plan ("Plan") account. 1. Assist each client with the development of an Investment Policy Statement (“IPS”), along with investment guidelines and restrictions. Clients agree to notify Copper Harbor Investment Advisors, LLC promptly of any change in such guidelines or restrictions that might affect the IPS. Clients also agree to provide additional information as Copper Harbor Investment Advisors, LLC may request from time to time to assist it in advising its client. Form ADV: Part 2A Page 5 2. Provide the other services described in the IPS. 3. Identify specific investment options within each asset category. If Copper Harbor Investment Advisors, LLC has been granted discretionary fiduciary authority, it will select money managers in each asset category in accordance with the IPS. 4. Monitor and report the performance of all selected investment choices. 5. Recommend changes to the investment portfolio and, if discretionary services are being provided, affect purchases and sales as it deems appropriate. 6. Review periodically the suitability of the Plan investments; and The following additional services will be provided upon request by the client and may be subject to additional fees: 1. Conduct periodic participant education and plan-related meetings (live or web); and 2. Assist with provider review and searches, negotiation of fees; and 3. Other services mutually agreed upon by Copper Harbor Investment Advisors, LLC and the client Plan clients are free to contact their Advisor Representative at any time, and to place restrictions on the types of securities Copper Harbor Investment Advisors, LLC may recommend for use by the Plan. Copper Harbor Investment Advisors, LLC does not offer any service that guarantees a gain, or that a loss will not occur. All clients assume the risk that investment returns may be negative or below the rates of return achieved by other investment managers, market indices, or specific investments. Investment Advisory accounts include all accounts except those where individual 401(k) plan participants direct the investment of their balances or clients ask for a personal non-managed account. These non-managed accounts are known as self-directed accounts. Self-Directed Accounts Self-Directed Accounts include all non-managed personal accounts and qualified retirement plans where individual 401(k) plan participants direct the investment of their balances. The following steps are taken with these types of clients: 1. Initial Establishment. Copper Harbor Investment Advisors, LLC works with the individual to estimate a risk profile that the investor is trying to achieve. Or in a retirement plan, sponsors determine a written Investment Policy for the plan. This Policy will usually include the types of investments to be offered to individuals/participants and other investment criteria. The objective of Copper Harbor Investment Advisors, LLC is to offer individuals/participants a broad array of investment options with varying degrees of risk. Form ADV: Part 2A Page 6 2. Individual/Participant Interaction. Copper Harbor Investment Advisors, LLC works with the plan sponsor or individual investor to determine if investment goals are being realized. Although investment decisions are being made by the individual investor or the plan participant Copper Harbor Investment Advisors, LLC will be available for guidance. 3. Periodic Review. At least annually Copper Harbor Investment Advisors, LLC will review the account. Based upon such an evaluation, Copper Harbor Investment Advisors, LLC may open a discussion with either the plan sponsor or the individual investor based on that review. As these accounts are in fact self-directed, the criteria used to suggest changes will be at a lower level than with a fully directed account and will be made on an individual case basis. Copper Harbor Investment Advisors, LLC does not use wrap fee programs.