Item 5 – Additional Compensation ...................................................................................................... 21 Item 6 – Supervision ........................................................................................................................... 21 Item 7 – Requirements For State Registered Advisers ...................................................................... 21 Peak Investment Advisors, Inc. is a state-registered investment advisor and a corporation formed under the laws of the State of Maryland.
• The firm’s controlling owner is Sean E. Falk. Full details of his education and business background are provided at Item 19 – Requirements for State-Registered Advisers of this Disclosure Brochure.
• The firm has been registered as an investment advisor since June 15, 1998. At Peak Investment Advisors, we strive to help you understand and achieve your investment goals. We are independent investment advisors. As independent investment advisors we are obligated to our clients. Your financial well-being is important to us because we are passionate about helping clients fully understand their financial situation and investment opportunities. Our professionals work with each client by taking an in-depth approach to their unique situation and applying their knowledge to provide timely and personalized advice. We strive to be known not only as an advisor, but also as a partner in our clients’ financial needs. Description of Advisory Services Asset Management Services Peak Investment Advisors provides “in-house” asset management services. Asset management services involve providing clients with continuous and on-going supervision over client accounts. This means we will continuously monitor a client’s account and make trades in client accounts when necessary. Through this service, Peak Investment Advisors implements a customized and individualized investment program for each client signing up for this service by applying our investment strategy and philosophy (please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details). We will actively manage client investment portfolios in accordance with each client's individual needs, return objectives and risk tolerance. Our services involve the following. 1. Investor Profile – We will meet with each client to obtain detailed financial information and other pertinent data to prepare an Investor Profile Worksheet/Plan. This information will help determine appropriate investment guidelines, risk tolerance and other factors that we can use to determine proper suitability of the client’s managed account(s) and appropriate investment holdings. 2. Portfolio Management Selection – We diversify and manage each client's portfolio. Investments are determined based upon each client's investment objectives, risk tolerance, net worth, net income and other, various suitability factors. All accounts are managed on an individualized basis. Further restrictions and guidelines imposed by clients affect the composition and performance of portfolios. For these reasons, performance of portfolios within the same investment objective may differ and clients should not expect that the performance of their portfolios would be identical to other clients. 3. Performance Evaluation and Monitoring Service - We will furnish quarterly performance reports to its clients. The reports area intended to inform clients as to the performance of their investments for the selected period. See Item 13 – Review of Accounts for more information. 4. Discretionary Authority – All clients are required to allow Peak Investment Advisors to manage accounts on a discretionary basis. Please refer to Item 16 – Investment Discretion for more information. Our services are typically provided through accounts opened at Charles Schwab which acts as its own clearing firm and/or Morningstar using Charles Schwab or Fidelity Investments as its clearing firm and results in our participation in their investment advisor institutional platforms. Charles Schwab and Morningstar are registered broker/dealers, members of the Financial Industry Regulatory Authority (FINRA) and the Securities Investors Protection Corporation (SIPC). Charles Schwab acts as the client’s qualified custodian and maintains physical custody of all client funds and securities. Charles Schwab or Fidelity Investments acts as the client’s qualified custodian and maintains physical custody of all client funds and securities invested at Morningstar. You must designate Peak Investment Advisors as your investment advisor on the accounts you’d like us to manage. You will need to grant Peak Investment Advisors with limited power-of-attorney on the account so that we can implement trades within the account and (if okay by you) deduct our advisory fees from the account. Although we recommend, and in some cases require, the use of Charles Schwab and/or Morningstar, some clients may be able to pick a broker/dealer or other qualified custodian of the client’s own choosing. Please refer to Item 12 – Brokerage Practices for more information. Clients are always responsible for notifying us of any changes to their financial situation or investment objectives. At least annually, we will contact each client for the specific purpose to determine whether the client’s financial situation or investment objectives have changed, or if the client would like to impose and/or modify any reasonable restrictions on the management of their accounts. We are always reasonably available to consult with clients relative to the status of their accounts. A client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the accounts. A separate account is always maintained for each client with the broker-dealer/custodian and the client retains all rights of ownership to their accounts (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). It is important that you understand we manage investments for other clients and may give them advice or take actions for them or for our own personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own personal accounts. Conflicts may arise in the allocation of investment opportunities among accounts we

manage. We strive to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Recommendation of Third-Party Investment Advisors In addition to offering in-house asset management services, we also offer advisory services by referring clients to outside, or unaffiliated, money managers that are registered as investment advisors. When we refer a client to a third-party investment advisor, the third-party investment advisor will provide asset management and investment advisory services directly to the client. Thus, the third-party investment advisor is responsible for continuously monitoring client accounts and making trades in client accounts when necessary. When a client agrees to engage a third-party investment advisor that we recommend, our firm is considered a solicitor and/or Sub-Advisor to the third-party investment advisor and, as a result, our firm is paid a portion of the fee charged and collected by the third-party investment advisor in the form of solicitor fees or consulting fees. Each solicitation arrangement is performed pursuant to a written solicitation agreement and is in compliance with SEC Rule 206(4)-3 and applicable state securities rules and regulations. We are always responsible for assisting clients with identifying their risk tolerance and investment objectives. We will recommend third-party investment advisors and help determine appropriate investment strategies in relation to the client’s stated investment objectives and risk tolerance. Clients will enter into an agreement directly with the unaffiliated third-party investment advisor. Although the third-party investment advisor will be responsible for making all investment decisions, we will be available to answer questions the client may have regarding their account and act as the communication conduit between the client and the third-party investment advisors. Third-party investment advisors we recommend generally require discretionary authority to determine the securities to be purchased and sold in client accounts. Neither Peak Investment Advisors nor its advisor representatives will have any trading authority with respect to the client’s managed account(s) with the third-party investment advisor(s). Although we review the performance of numerous third-party investment advisor firms, we enter into only a select number of relationships with third-party investment advisor firms that have agreed to pay us a portion of the overall fee charged to our clients. Therefore, Peak Investment Advisors has a conflict of interest in that it will only recommend third-party investment advisors that will agree to compensate us for referrals of our clients. Clients are advised that there may be other third-party managed programs, not recommended by our firm, that are suitable for the client and that may be more or less costly than arrangements recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a third-party investment advisor recommended by our firm. Further, no guarantees of performance can ever be offered by our firm (please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details). Types of Investments Peak Investment Advisors is willing to provide advice on any type of investments held by a client. For example, the following list contains some of the investments we discuss with our clients.
• Exchange-listed securities (i.e. stocks)
• Securities traded over-the-counter (i.e. stocks)
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Annuities
• Mutual fund shares
• United States government securities
• Options contracts on securities
• Exchange Traded Funds (ETF) When providing Asset Management Services, the firm will typically construct each client’s account holdings using mutual funds, exchange traded funds and equities to build diversified portfolios. It is not our typical investment strategy to attempt to time the market, but it may increase cash holdings modestly as deemed appropriate, based on a client’s risk tolerance and our expectations of market behavior. We can modify our investment strategy to accommodate special situations like: low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. 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 yours 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 your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of each client. This means, for example, that the client is given the ability to impose restrictions on the accounts we manage, including placing restrictions on specific investment selections and sectors. We work with each client on a one-on-one basis through interviews to determine the client’s investment objectives and suitability information. Client Assets Managed by Peak Investment Advisors, Inc. The amount of clients’ assets managed by Peak Investment Advisors on a discretionary basis totaled $69,729,088 and on a non-discretionary basis totaled $11,011,424 as of December 31, 2022. *This includes Third Party Advisor managed accounts that we work with. *Peak does not participate in sponsoring or managing wrap fee accounts.