We offer a variety of advisory services, including investment management, financial planning, and consulting services. We first registered as an investment adviser in May 2016 and are wholly owned by Nicolet Bankshares, Inc. As of December 31, 2023, we had $3,664,001,650 of assets under discretionary management and $1,410,099 under non-discretionary management. Prior to us rendering any advisory services, clients are required to enter into one or more written agreements with us setting forth the relevant terms and conditions of the advisory relationship. This brochure generally discusses the services we offer, but certain sections also discuss the activities of our supervised persons (e.g., our officers, partners, directors, and employees). Financial Planning and Consulting Services We offer clients a broad range of financial planning and consulting services, including business planning, estate planning, investment consulting, insurance planning, retirement planning, risk management, and corporate retirement planning. These services are generally provided in connection with our investment portfolio management services as part of a comprehensive wealth management engagement. We often recommend that clients engage us or our supervised persons (in their individual capacities as insurance agents, registered representatives of a broker-dealer, or other professional capacities) to implement recommendations made as part of our financial planning and consulting services. When making such recommendations, a conflict of interest exists when our employees offer to implement financial planning and consulting services recommendations by executing transactions that pay commissions to or otherwise benefit us. This conflict is mitigated by each Client retaining absolute discretion over all decisions regarding the implementation of any recommendations made by us or our employees and remaining under no obligation or expectation to implement any recommendations through us or our employees—or to act upon any of recommendations made at all. In performing financial planning and consulting services, clients expressly authorize us to rely on information received from their other professional advisors (e.g., attorneys, accountants, etc.) without taking additional steps to verify any such information. Clients retain the sole responsibility of promptly notifying us of any changes to their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our recommendations. Investment Management and Wealth Management Services We generally manage client investment portfolios on a discretionary basis. In addition, we can be engaged to provide wealth management services which include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non- discretionary management of investment portfolios. We primarily allocate client assets among various mutual funds, exchange-traded funds (ETFs), and individual debt and equity securities. Where appropriate, we also provide advice about legacy positions or other investments held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by us unless specifically agreed upon. In order to receive investment management services, clients must open institutional brokerage accounts at a third-party custodian (unaffiliated with us) by completing a client agreement directly with the custodian. We have existing relationships with certain custodians, such as Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Brokerage Services LLC (“Fidelity”). Clients can engage us to manage and/or advise on certain investment products 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, we direct or recommend the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. We tailor our advisory services to meet the needs of our individual clients and seek to ensure that client portfolios are managed in a manner consistent with those needs and objectives. We consult with clients on an initial and ongoing basis to assess their individual risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify us if there are changes in their financial situations 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 we determine, in our sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to our management efforts. Alternative Solutions We also offer alternative investment options such as access to limited public and private offerings as well as a separately managed account solution for high-net-worth individuals. Limited Offerings We work with service providers who act as a marketers or placement agents for a selection of investment offerings in securities products (particularly, private and registered investment funds, such as hedge funds). Product offerings available through these providers are limited to the menu of products of which they have completed operational due diligence and opted to make available on their platforms. Most of the products that are available through these platforms have minimum investment requirements, some of $100,000 or more. These platforms do not open or hold accounts for our clients, rather, products are purchased through them and are held by FORM ADV PART 2 | N i c o l e t A d v i s o r y S e r v i c e s , L L C 5 | P a g e the custodian (or

other financial intermediary) holding our clients’ assets. These service providers do not separately monitor any client’s specific investments in an ongoing manner. In addition to product offerings through third-party marketers and placement agents, we also consider direct investments with private hedge funds, private equity, and debt funds. Such direct investments are discussed individually with qualified clients who meet applicable minimum investment criteria and for whom such investments can provide a suitable option as part of a broader investment strategy. Unified Managed Accounts We also offer access to a unified managed account (“UMA Platform”) that provides our clients an opportunity to invest in some or all of the following products within a single unified account: mutual funds (including open-end and closed-end funds), exchange-traded funds, and separately managed accounts (“SMAs”). An SMA is a portfolio of individually owned securities that can be tailored to fit each client’s investing preferences. For clients participating in the SMA program, we recommend an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each, a “Sub-Manager”) with a variety of disciplines. In your agreement with us, you authorize designated Sub-Managers to exercise discretion to select securities for your account. The UMA Platform helps us identify individual asset managers and investment vehicles that correspond to the asset classes and styles we propose. We also have the option to independently identify and utilize the services of specific Sub- Managers. The UMA Platform retains Sub-Managers who provide portfolio management services under the SMA program through separate agreements entered into directly between the UMA Platform and the Sub-Manager. For many Sub-Managers, the UMA Platform has entered into a licensing agreement with the Sub-Manager, under which the UMA Platform performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the Sub-Manager. For clients participating in the UMA Platform, we generally recommend a single customized portfolio consisting of one or more asset managers (including Sub-Managers) or funds representing various asset classes. We utilize the tools available through the UMA Platform to customize asset allocation models or select from proposed asset allocations for types of investors fitting the client’s profile and investment goals. We can further customize portfolios by selecting specific underlying investment strategies or funds to meet each client’s specific needs. Once we establish the content of the portfolio, the UMA Platform provides overlay management services for UMA accounts and directly places trade orders with the custodian based on the investment strategies contained in the UMA portfolio. Envestnet charges an annualized fee to access its platform in addition to the fees charged by the individual sub-managers selected to manage client assets. Additional services, such as tax overlay and impact overlay services, are also available at an additional cost. In negotiating the platform fee with Envestnet to minimize the additional costs to our clients, we committed to placing enough assets on the Envestnet platform to reach a certain minimum aggregate platform fee. If we do not reach that minimum, we agreed to directly compensate Envestnet on a quarterly basis the difference between the committed amount and the actual aggregate platform fees received by Envestnet from the clients on the platform. Accordingly, we have an incentive to recommend the Envestnet platform to clients to reduce any out-of-pocket expense we would have to cover if we do not reach the minimum commitment. Sponsor and Manager of Wrap Program We also provide investment management services as the sponsor and manager of the Nicolet Advisory Services Wrap Fee Program (the “Wrap Program”). A wrap program is an arrangement under which fees for advisory services and certain brokerage commissions and transaction costs are combined (or, wrapped) as one fee paid by the client. We pay a portion of the fee we receive for sponsoring and managing the Wrap Program to the broker-dealer executing transactions in client accounts to cover transaction costs. We manage assets in the Wrap Program in substantially the same manner as those we manage under a non-wrap arrangement. Participants in the Wrap Program may pay a higher or lower aggregate fee than if each service was purchased separately. Additional information about the Wrap Program is available in our Wrap Brochure. Many custodians, including Schwab, have eliminated many transaction fees for online trades of U.S. equities, ETFs, options, and certain classes of Mutual Fund shares. This means that transactions in these types of securities are excluded from the asset-based fee we pay to cover transaction fees in client accounts. This presents a conflict of interest because we have a financial incentive to maximize our compensation by seeking to invest in securities for which transaction fees have been eliminated (i.e., securities exempted from the ongoing asset-based fee to cover transaction costs). This conflict arises in situations, among others, where a certain mutual fund offers both a no-transaction fee share class and an institutional class that is subject to transaction fees. No- transaction fee share classes are often subject to higher ongoing costs that are priced into the ongoing internal costs of these securities (lowering overall returns) but would be exempt from the asset-based fee covering transaction costs that we pay as part of your agreement with us. We seek to minimize or eliminate this potential conflict by first selecting appropriate securities through our internal due diligence process and then investing in share classes with the lowest ongoing internal expenses, irrespective of whether they are no-transaction fee funds or subject to the asset-based fee we pay to cover transaction costs.