Peak Investment Advisors, Inc. (Peak) has been in operation in Colorado since 1993. Peak and its predecessor firm have been in the investment management business since 1988. The firm is primarily owned by Richard A. Mueller, while Lisa A. Mueller owns a minority stake. Peak Investment Advisors, Inc. filed its initial application to become registered as in investment adviser with the U.S. Securities and Exchange Commission in May 2024. Peak provides investment advisory and financial consulting services primarily to individuals, families and businesses. Peak may also serve pension funds, banks, trusts, endowments and estates. Tax planning services are also provided to both individuals and small businesses. Investment and tax advisory services are tailored to meet the needs of individual clients, as each client situation is unique with regard to risk tolerances and return objectives. Investment strategies and policies are arrived at after meeting with clients and determining their goals, objectives and risk tolerances. Clients may limit or restrict investing in certain securities or types of securities. If Client is currently receiving asset management services from Peak for an asset management fee, Peak provides consulting services for no additional charge. It will be incumbent upon Client to identify the issues for which you are seeking our advice or consultation on. Retirement Plan Rollover Recommendations When Peak provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that {Investment Adviser Firm} is a “fiduciary” 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. The way Peak makes money creates conflicts with your interests so Peak operates under a special rule that requires Peak to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Peak must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Peak ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures

designed to ensure that Peak gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Peak; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Peak, please know that Peak and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Peak. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Peak. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Peak receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Peak and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Peak or our affiliated personnel. Client assets under management as of March 31, 2024, were $130,474,788 Of these assets under management, $96,165,831 were managed on a discretionary basis and $34,308,957 were managed on a non-discretionary basis.