Firm Description Diversified Portfolio Management, LLC is an Investment Advisor doing business under the name Heritage Financial Solutions, LLC, (we) provide advice to individuals, pension and profit-sharing plan participants, trusts, estates and charitable organizations, corporations, or other business entities, and other retirement accounts (IRA's, SEP's, etc.). Diversified Portfolio Management, LLC was founded in 2004. Principal Owners Diversified Portfolio Management is owned by William Hayden Wealth Mgmt, LLC which is wholly owned by Amber L. Wallis, Chief Compliance Officer. Types of Advisory Services We provide investment management services, also known as asset management services; manage investment advisory accounts not involving investment management services; furnishes investment advice through consultations. On occasion, we may provide consulting services for portfolio review and/or design of same without any on-going supervision and reporting. On more than an occasional basis, we furnish advice to clients on matters not involving securities, including such topics as personal finance, taxation issues, retirement planning, and trust services that often include estate planning. Investment Management Services We provide continuous advice to clients regarding investment of client funds 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, we develop a client’s personal investment policy statement and create and manage a portfolio based on that policy. We will manage advisory accounts on a discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, growth and income, etc.). We will create a portfolio consisting of one or all of the following: individual equities, bonds, other investment products, ETF's (exchange traded funds), and no-load or load-waived mutual funds. We will allocate our client’s assets among various investments taking into consideration the overall management style selected by the client. Mutual funds will be selected on the basis of any or all of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure. Portfolio weighting between funds and market sectors will be determined by each client’s individual needs and circumstances. Clients will retain individual ownership of all securities. When appropriate to the needs of the client, we may recommend the use of margin transactions. Because this investment strategy involves certain additional degrees of risk, it will only be recommended when consistent with the client’s stated tolerance for risk. Financial Planning We also offer investment advice on a more limited basis, at our discretion. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client’s existing portfolio, or any other specific topic. Additionally, we may provide advice on non-securities matters; generally, in connection with the rendering of estate planning, insurance, and/or annuity advice. We provide personalized, comprehensive planning and investment management to individuals, pension and profit-sharing plan participants, trusts, estates and charitable organizations, corporations or other business entities, and other retirement accounts (IRA's, SEP's, etc.). Advice is provided through consultation with 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 planning. Asset Management Assets are invested primarily in no-load or load-waived mutual funds and exchange-traded funds, usually through discount brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. We do not receive any compensation, in any form, from fund companies. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, fixed life insurance, fixed annuities and mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Initial public offerings (IPOs) are not available through the Firm. Retirement Plan Rollover Recommendations As part of our investment advisory services to our clients, we may recommend that clients roll assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the client’s behalf. We may also

recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge the client an asset-based fee as set forth in the advisory agreement the client executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to the client (i.e., receipt of additional fee-based compensation). Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the rollover, clients are under no obligation to have the assets in an IRA advised on by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in our clients’ best interests and not put our interests ahead of our clients.’ Under this special rule’s provisions, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice);
• never put our financial interests ahead of our clients’ when making recommendations (give loyal advice);
• avoid misleading statements about conflicts of interest, fees, and investments;
• follow policies and procedures designed to ensure that we give advice that is in our clients’ best interests;
• charge no more than a reasonable fee for our services; and
• give clients basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, clients should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in the employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide clients with an explanation of the advantages and disadvantages of both account types and document the basis for our belief that the rollover transaction we recommend is in your best interests. Tailored Relationships We tailor advisory services to the individual needs of the client. The goals and objectives for each client are documented in our client relationship management system. Clients may impose reasonable restrictions on investing in certain securities or types of securities. Investment policy statements are created that reflect the stated goals and objectives, including any restrictions imposed by the client. Fiduciary Statement We are fiduciaries. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs We do not participate in a Wrap Fee Program. Client Assets As of June 15, 2023, we manage approximately $84,155,693 in assets, solely on a discretionary basis.