4a: Firm Description Ironwood Wealth Management, LLC (“Ironwood”) was established in March 2006 by the managing members, but applied for registration as an investment adviser in May 2015. Ironwood (CRD# 200511) is a spin-off from Ironwood Wealth Management, LLC (CRD# 151004). Ironwood Wealth Management, LLC (CRD# 151004) has changed its name to Ironwood Financial, LLC. Our office is located in Chandler, Arizona. 4a1: Principal Owners Ironwood is owned principally by Ironwood Wealth Management Holdings, LLC, which is primarily owned by the following individuals:
• Cean N. Kenefick-Rogers, CFA, Managing Member: [email protected]| (480) 776-5960
• Alexander D. Marek, Managing Member: [email protected] | (480) 776-5960
• Rydan D. Case, CFP, Managing Member: [email protected] | (480) 776-5960 4b: Types of Advisory Services INVESTMENT ADVISORY SERVICES Ironwood offers a variety of investment advisory services to its clients. Ironwood may be engaged to provide discretionary or non-discretionary investment advisory services as described below. FULL-SERVICE OFFERING Before Ironwood provides investment advisory services, we work with our clients to identify their investment goals, objectives and risk tolerance in order to create an initial portfolio allocation consistent with the client’s designated investment objectives. Ironwood primarily allocates client investment assets among mutual funds and exchange-traded funds (“ETFs”) consistent with one or more of Ironwood's asset allocation strategies. Once the appropriate portfolio has been determined, we will review the portfolio and rebalance the account based upon our client’s individual needs, stated goals and objectives. See disclosure below at Miscellaneous section regarding Conflicts of Interest. Ironwood offers financial planning services for our clients. We will prepare a written financial plan for all financial planning clients. The plan considers all of your assets, liabilities, goals and objectives and includes gathering all information necessary to provide you with appropriate and agreed upon services, which may include one or more of the following:
• Investment Strategies
• Investment supervisory services
• Consultations
• Financial planning
• Pension and profit sharing planning
• Endowments
• Foundations
• Business Accounts You are encouraged to review your plans on a regular basis. For new clients, we generally charge financial planning fees, which are described in Item 5 below. We use a platform provided by Pontera Inc. ("Pontera") to manage with discretion held away assets such as defined contribution plan participant accounts (“held away accounts”). The Pontera platform allows us to manage your account(s) without us having to obtain and maintain your login credentials. A link will be provided to the Client allowing them to connect an account(s) to the platform provided by Pontera. Once a client account is connected to the platform, Ironwood will review the current account allocations. When deemed necessary, Ironwood will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Client account will be reviewed periodically, and allocation changes will be made as deemed necessary by Ironwood. Client will receive an email notification each time their account is reviewed. Clients will be responsible for paying advisory fees managed through the Pontera platform in the same manner as their other accounts in accordance with Item 5. FOUNDATIONS/LEGACY PROGRAM The Foundations Program is intended for young professionals accumulating assets with a goal of becoming Full-Service Offering clients. The Legacy Program is designed so that we can continue to provide services to retired clients in the decumulation phase with assets that do not meet the Full-Service Offering account minimums. The Foundations Program and Legacy Program are otherwise the same. We make these offerings available in addition to the Full-Service Offering described above. We generally manage client portfolios in an identical manner in this offering, with one exception. When we provide our advice, we consider each client account enrolled in this offering as its own separate portfolio when making investment decisions, whereas in our Full-Service Offering, we manage all accounts as one portfolio and try to minimize the impact of tax inefficient assets by holding them in tax favorable accounts if possible. This concept is known in the industry as asset location and is only available in our Full-Service offering. The Foundations/Legacy Program do not use asset location as each account is managed on its own. This can result in the client being subjected to a less tax efficient total portfolio and clients should consult with their tax consultant prior to determining to enroll in this offering. Other than the difference noted above, we have created different pricing arrangements and impose constraints on the availability of our human capital to ensure that we have sufficient resources to service all our clients. Clients in this offering are not typically invited to all client service and appreciation events hosted by us. Clients in this offering will receive up to two meetings each year with a Foundations Program or Legacy Program planning team member each year. Clients will also have access to planning software that can enable them to make financial decisions. Clients in the Foundations/Legacy Programs will receive the same quarterly performance report that all of our other clients receive. MISCELLANEOUS Retirement Rollovers. A client leaving an employer typically has four options (and may engage in a combination of these options): i) leave the money in his former employer’s plan, if permitted, ii) roll over the assets to his new employer’s plan, if one is available and rollovers are permitted, iii) rollover to an IRA, or iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Ironwood may recommend an investor roll over plan assets to an Individual Retirement Account (IRA) managed by Ironwood. As a result, Ironwood and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave his or her plan assets with his or her previous employer or roll the assets to a plan sponsored by a new employer will generally result in no compensation to Ironwood (unless you engage Ironwood to monitor and/or manage the account while maintained at your employer). Ironwood has an economic incentive to encourage an investor to roll plan assets into an IRA that Ironwood will manage or to engage Ironwood to monitor and/or manage the account while maintained at your employer. There are various factors that Ironwood may consider before recommending a rollover, including but not limited to: i) the investment options available in the

plan versus the investment options available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan’s investment professionals versus Ironwood’s, iv) protection of assets from creditors and legal judgments, v) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to rollover plan assets to an IRA managed by Ironwood or to engage Ironwood to monitor and/or manage the account while maintained at your employer. ANY QUESTIONS: Ironwood’s Chief Compliance Officer, Cean Kenefick-Rogers, remains available to address any questions that a client may have regarding its prospective engagement and the corresponding conflict of interest presented by such engagement. Share Class Selection Policy. Ironwood maintains a share class selection policy that it follows in making investment recommendations and selecting investments for discretionary client accounts. This policy is subject to periodic review and may change from time to time, without notice to clients. Ultimately, our policy is intended to purchase the most appropriate share class available. Our policy depends on a client’s investment strategy as follows. For our most aggressive strategies, when Ironwood initially purchases a mutual fund for a client account, it will generally recommend and select an institutional share class when the purchase price is equal to or exceeds $10,000. It will also typically recommend and select an institutional share class for any additional investment in that same mutual fund when the additional purchase value equals or exceeds $4,000 and will typically not sell the institutional share class unless the $4,000 threshold is met. In all other instances, it will select the retail share class or other share class that does not impose transaction fees to acquire the share class. For our less aggressive strategies, when Ironwood initially purchases a mutual fund for a client account, it will generally recommend and select an institutional share class when the purchase price is equal to or exceeds $20,000. It will also typically recommend and select an institutional share class for any additional investment in that same mutual fund when the additional purchase value equals or exceeds $4,000 and will typically not sell the institutional share class unless the $4,000 threshold is met. In all other instances, it will select the retail share class or other share class that does not impose transaction fees to acquire the share class. If a client only has holdings in institutional share classes, then Ironwood would be forced to sell those holdings in the event a client requests a distribution. Although the different share class does not impact the fund's management style or objective, the client will incur higher annual expenses for the retail class shares (approximately 0.25% of the client's assets in the fund). Ironwood has conducted analysis of a sample of its clients’ accounts and has reason to believe that this policy reduces its clients’ investment expenses, but there is no guarantee that this policy will result in lower investment expenses for any individual client. Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, Ironwood may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Ironwood does not serve as a law firm and no portion of Ironwood’s services should be construed as legal advice. To the extent requested by a client, Ironwood may recommend the services of other professionals for certain non-investment implementation purposes (e.g., attorneys and insurance agents.). The client is under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Ironwood and/or its representatives. If the client engages any recommended professional, and a dispute arises, the client agrees to seek recourse exclusively from and against the engaged professional. Tax Preparation Service and Discounts. We may agree to prepare tax returns for clients who request our assistance. We will charge the client an agreed upon fee for the preparation of their individual tax returns. We provide Full-Service clients subject to the minimum annual fee with a discount of 25% off their tax return preparation fees. We reserve the right to provide different discounts than those outlined above, and similarly situated clients may pay different fees for their tax returns. Non-Discretionary Service Limitations. Clients that determine to engage Ironwood on a non-discretionary investment advisory basis must be willing to accept that Ironwood cannot affect any account transactions without obtaining the client’s consent. For instance, although the firm does not recommend market timing as an investment strategy, in the event of a market correction event where the firm cannot reach the client, a client may suffer investment losses or miss potential investment gains. Client Obligations. Ironwood will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on the information in its possession. Clients are responsible for promptly notifying Ironwood if there is ever any change in their financial situation or investment objectives so that Ironwood can review, and if necessary, revise its previous recommendations or services. eMoney. In conjunction with the services provided by eMoney, Ironwood may also provide periodic comprehensive reporting services, which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets that Ironwood manages (the “Excluded Assets”). The client or their other advisors that maintain trading authority, and not us, shall be exclusively responsible for the investment performance of the Excluded Assets. Ironwood's service relative to the Excluded Assets is limited to reporting only, which does not include investment monitoring or implementation. The client may engage Ironwood to manage the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Ironwood and the client. 4c: Client Tailored Relationships and Restrictions Ironwood customizes client portfolios based on each client’s investment objectives. You may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination of our agreement. 4d: Wrap Fee Program Ironwood does not offer a wrap fee program. 4e: Assets under Management (AUM) As of December 31, 2023, Ironwood managed approximately $610,197,450 in assets on a discretionary basis and $7,380,253 on a non-discretionary basis.