Carlson Capital Management, LLC (“CCM”) is a fee-based financial advisory firm that offers wealth management, financial advisory and institutional (retirement plan) services to clients. CCM was established as an LLC in 2015. CCM is principally owned by Carlson Capital Management Inc., which was founded in 1987 and was previously registered with the SEC as an Investment Adviser from September 21, 1990 until January 5, 2016. Principal owners of Carlson Capital Management Inc. include Gregory A. Carlson, Jeffrey R. Carlson and Justin D. Stets. As of December 31, 2023, CCM had $3,485,161,177 of client assets under discretionary management and $17,532,464 of client assets under non-discretionary management. “Assets Under Management,” as defined by Section 203A(a)(2) of the Investment Advisors Act of 1940, are the “security portfolios” for which an advisor provides “continuous and regular supervisory or management services.” We have five Minnesota meeting office locations: Northfield, Bloomington, Hastings, Coon Rapids and Rochester. We have a sixth meeting office located in Sioux Falls, SD. The majority of our clients reside in the greater Twin Cities area, but we serve clients from all over the country. Types of Advisory Services CCM offers investment advisory services using its Integrated Wealth Management platform approach. The following advisory services are included:
• Integrated wealth management
• Investment management
• Financial planning services including: - Retirement planning - Estate and advanced estate planning - Tax planning - Insurance planning - Education planning and - Philanthropic planning At CCM, our advisory services are customized based on the individual needs of our clients. We meet with prospective clients to assess their needs, goals, and objectives prior to making specific recommendations. We assist prospective clients in determining their short-term and long-range investment goals and objectives. We ask prospective clients to complete a custom inventory form and questionnaire to assist us in obtaining information about their financial situation and history. We gather various financial information and history including, but not limited to:
• Retirement and financial goals
• Investment objectives
• Investment horizon
• Financial needs
• Cash flow analysis
• Cost of living needs
• Education savings needs
• Savings tendencies
• Debt, assets, and liabilities Form ADV Part 2A Firm Brochure (March 2024) 5
• Wills and trusts
• Investment and bank accounts
• Other applicable financial information required in order to provide the investment advisory services requested Upon completing our analysis of your situation, we work with you to determine an asset allocation strategy customized to your financial goals, objectives, and risk tolerance. CCM designs portfolio allocation strategies with objectives ranging from principal preservation to aggressive growth. After evaluating the information provided to us, we determine which of our portfolio allocation strategies would be most suitable for you. From there, we customize your portfolio allocation taking into consideration your limitations or restrictions, the market and economy at the time and your financial situation, goals, and objectives. Managed portfolios are constructed using primarily open-ended mutual funds and exchange traded funds (ETFs). CCM will also use its affiliated ETF in constructing a managed portfolio. For more information about the affiliated ETF, please see the section on “Affiliated ETF” below. When appropriate, we will also utilize fixed income securities. Upon your specific request, CCM will maintain individual stock holdings for tax purposes. You also have the ability to impose restrictions and/or limitations on investing in certain securities or types of securities. After we have done the work necessary to create a recommended portfolio, we will schedule a meeting with you (a Plan Presentation) and present the recommended investment strategies. Upon your approval of our recommendations, you will sign an Investment Advisory Agreement, which establishes the fiduciary relationship between CCM and you, the client. Additionally, you will sign an Investment Policy Statement which grants CCM discretionary authority to trade on your behalf, meaning that we can execute without prior consultation with you. The Investment Policy Statement specifically outlines the type of investments that will govern the account, including any possible restrictions on investing or selling certain securities on your behalf. We will then implement the portfolio strategy. Thereafter, we will manage the account by making appropriate changes to the strategies, and determining and potentially altering, from time to time, the securities to be purchased and sold in the account. CCM may actively trade securities and hold such securities for periods of 30 days or less or maintain positions for longer- or shorter-term periods. CCM generally requires a minimum investment (currently $1,000,000 in cash or securities) that can be deposited with an independent, qualified custodian or broker-dealer in order to provide Integrated Wealth Management services. Under certain circumstances, CCM may waive the minimum account requirement and accept accounts less than $1,000,000. Such circumstances may include, but are not limited to, the fact that additional assets will soon be deposited, or you have other accounts under management with CCM. FINANCIAL PLAN PRESENTATION In addition to presenting you with a recommended portfolio we will also present our analysis of your broader financial situation along with recommendations for steps to be taken to assist you in working toward your financial and life goals. Your financial plan will be based on your financial situation at the time and the financial information that you disclose to CCM. As requested by clients, and as part of a client’s financial plan, CCM also may provide advice on stock option analysis and education funding. You are not obligated to implement investment recommendations through CCM. Form ADV Part 2A Firm Brochure (March 2024) 6 CARLSON PORTFOLIOS CCM provides an alternative offering for prospective clients who do not have the complexity in their financial situations that require the array of solutions provided by our Integrated Wealth Management platform. Carlson Portfolios provides the investment discipline and structure of our portfolio allocation strategies and leverages the investment research capabilities, portfolio management team and technology previously offered exclusively to high-net-worth clients. Carlson Portfolios is a practical option for clients with $500,000 or more to invest. For some clients, starting on the Carlson Portfolios path is the beginning of engaging CCM and may progress to the Integrated Wealth Management platform as the need arises for more advanced financial planning. For others, the solutions and advisory experience of Carlson Portfolios could meet their investment needs for years to come. AFFILIATED ETF CCM’s affiliate, CCM Investment Group, LLC, serves as a subadvisor to an affiliated exchange traded fund—the CCM Global Equity ETF (the “Affiliated ETF”). CCM frequently recommends and uses its investment discretion to invest clients in the Affiliated ETF. Depending on a client’s investment strategy and asset allocation, CCM can invest up to 100% of a client’s account in the Affiliated ETF. CCM intends to generally (though not always) use the Affiliated ETF for the equity allocation in a client’s account. This arrangement creates a conflict of interest because CCM Investment Group, LLC stands to receive a portion of the fee a client incurs investing in the CCM Global Equity ETF in addition to the fees described in Item 5 below. As of November 2023, the adviser to the Affiliated ETF is entitled to receive an advisory fee based on the Affiliated ETF’s average daily net assets for the services and facilities it provides payable at the annual rate of 0.34%.1 The adviser pays CCM Investment Group, LLC as subadvisor to the Affiliated ETF a fee, which is calculated daily and paid monthly, at an annual rate of 0.17% based on the fund’s average daily net assets2. CCM mitigates this conflict of interest by disclosing it to clients, providing clients with an opportunity to ask questions, and seeking a clients informed consent to manage their account in this manner in our Investment Policy Statement3. A client may also limit CCM’s ability to invest in the Affiliated ETF by informing CCM of that restriction. Any such restriction should be memorialized in an Investment Policy Statement. The Affiliated ETF’s prospectus details the investment objectives, strategy, and the schedule of fees to be received by CCM Investment Group, LLC, and clients should carefully review this document, as well as the statement of additional information. CARLSON RETIREMENT PLAN SERVICES In addition to the services CCM offers to individuals and families, Carlson Retirement Plan Services serves clients by offering comprehensive and customized 401(k) plan and other retirement plan solutions, proudly serving as a fiduciary for plans and extending personalized guidance and financial education to plan participants. We work with small and mid-sized business owners to address the five 1 A client should receive notice from the adviser to the Affiliated ETF in the event of any changes to the fees incurred by the Affiliated ETF. CCM will not update this reference in this Form ADV Part 2A on an interim basis. 2 As of November 2023. Subject to change. CCM will not update this reference in this Form ADV Part 2A on an interim basis. 3 Current clients of CCM at the launch of the Affiliated ETF have not been asked to execute a new Investment Policy Statement but will have consented to invest in the Affiliated ETF through a separate acknowledgement. Form ADV Part 2A Firm Brochure (March 2024) 7 key areas that contribute to successful retirement outcomes for plan participants, while providing foundational fiduciary stewardship for plan sponsors that includes the following: Plan Design - Carlson Retirement Plan Services develops customized retirement plans specifically designed and optimized to meet our plan sponsor goals and objectives. Fiduciary Governance - Carlson Retirement Plan Services advises on the plan sponsor’s fiduciary responsibilities. The process may include the following:
• A CEFEX certified fiduciary governance process that allows for the plan sponsor to follow global standards of fiduciary excellence
• Fiduciary education training and communication programs offered to plan sponsors
• Advisement on development, maintenance, and adherence to an appropriate Investment Policy Statement (IPS) Plan Benchmarking - Carlson Retirement Plan Services assists clients in ensuring their plans are competitive in total cost structure for the services they are receiving. Investment Management – Carlson Retirement Plan Services acts as a 3(38) investment manager to our client plans ensuring that investment options include a diversified menu of covering the full spectrum of equities, fixed income, and cash equivalents. Participant Education and Communication - We focus on delivering personal service and care to plan participants—offering relevant education and advice. Financial Wellness Programming – for an additional fee, Carlson Retirement Plan Services provides access to a financial wellness technology platform and programming designed to:
• Increase overall financial literacy and efficacy for plan participants, decrease absenteeism and turnover related to financial stress, develop financially well employees that are able to meet current obligations and address future planning/preparedness, and meet employees where they are in their own personal financial journey. CARLSON FOUNDATIONS AND ENDOWMENTS CCM works with foundation and endowment stewards, offering access to CCM’s investment advisory services and related consultation regarding fiduciary responsibility and practices. Pricing and other terms of these engagements are negotiated with each organization to be specific to the needs associated with the relationship. Advisory Business Disclosures Disclosure Brochure. A copy of CCM’s written Brochure and Client Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, will be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. Client Obligations. CCM makes certain assumptions with respect to interest and inflation rates and may rely on past trends and prior performance of the markets and the economy in general. However, past performance is in no way an indication of future performance. CCM cannot offer any

guarantees or promises that your financial goals and objectives will be met. After you engage CCM, it is important that you continue to review the plans presented to you and update us on changes in your financial situation, goals, or objectives. Should your financial situation or investment goals or objectives change, Form ADV Part 2A Firm Brochure (March 2024) 8 it is important to notify CCM promptly. Failure to notify CCM of any such changes could result in investment recommendations or planning solutions not meeting your needs. You are advised that the advice offered by CCM does not include drafting legal documents or providing legal advice. Therefore, you will need to seek the services of an attorney as needed. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, CCM may provide financial planning and related consulting services. Neither CCM nor its investment adviser representatives assist clients with the implementation of any financial plan unless they have agreed to do so in writing. CCM does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with CCM, if desired. CCM may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. CCM does not serve as an attorney or accountant, and no portion of our services should be construed as legal or accounting services. Accordingly, CCM does not prepare estate planning documents or tax returns. To the extent that you request such services, CCM may recommend the services of other professionals for certain non- investment implementation purpose (i.e., attorneys, accountants, insurance agents, etc.), including representatives of CCM in their separate individual capacities as licensed insurance agents. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from CCM or its representatives. If you engage any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional (i.e., attorney, accountant, insurance agent, etc.), and not CCM, shall be responsible for the quality and competency of the services provided. Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If CCM recommends that a client roll over their retirement plan assets into an account to be managed by CCM, such a recommendation creates a conflict of interest if CCM will earn new (or increase its current) compensation as a result of the rollover. If CCM provides a recommendation as to whether a client should engage in a rollover or not, CCM is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by CCM. Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by CCM independent of engaging CCM as an investment advisor. However, if a prospective client determines to do so, he/she will not receive CCM’s initial and ongoing investment advisory services. Use of DFA Mutual Funds. CCM utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers. Therefore, if the client were to terminate CCM’s services, and not transition to another adviser who utilizes DFA funds, Form ADV Part 2A Firm Brochure (March 2024) 9 restrictions regarding additional purchases of, or reallocation among other, DFA funds will generally apply. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by CCM CCM), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. CCM does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. Cryptocurrency. Cryptocurrency is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, CMM does not recommend or advocate the purchase of, or investment in, cryptocurrencies and will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Portfolio Activity. CCM has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, CCM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when CCM determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Cash Positions. CCM continues to treat cash as an asset class. As such, unless determined to the contrary by CCM, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating CCM’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), CCM may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, CCM’s advisory fee could exceed the interest paid by the client’s money market fund. ByAllAccounts: Account Aggregation. CCM, in conjunction with the services provided by ByAllAccounts, 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 managed Form ADV Part 2A Firm Brochure (March 2024) 10 by CCM (the “Excluded Assets”). CCM’s service relative to the Excluded Assets is limited to reporting services only, which does not include investment implementation. Because CCM does not have trading authority for the Excluded Assets, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not CCM, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The client and/or their other advisors that maintain trading authority, and not CCM, shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, CCM shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that CCM provide investment management services with respect to the Excluded Assets, the client may engage CCM to do so pursuant to the terms and conditions of an appropriate agreement between CCM and the client. Cybersecurity Risk. The information technology systems and networks that CCM and its third-party service providers use to provide services to CCM’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in CCM’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and CCM are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although CCM has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that CCM does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Independent Managers. CCM may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Managers”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Managers shall have day-to-day responsibility for the active discretionary management of the allocated assets. CCM shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. CCM generally considers the following factors when considering its recommendation to allocate investment assets to Independent Managers: the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Managers is separate from, and in addition to, CCM’s investment advisory fee as set forth in Item 5. Scope of Work. You are advised that investment recommendations and advice offered by CCM are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney or accountant. Potential Tax Implications. You are advised that transactions in your account, account re-allocations, and the rebalancing of your account may trigger a taxable event, with the exception of IRA accounts, 403(b) accounts and other tax-exempt qualified retirement accounts. Form ADV Part 2A Firm Brochure (March 2024) 11 Performance of Smaller Accounts. You are advised that performance may suffer due to difficulties with diversifying smaller accounts. In addition, performance of smaller accounts may vary from the performance of larger accounts due to fluctuations in the market that may affect smaller accounts more and the effects of compounding may be greater in larger accounts. Wrap Fee Program. You are advised that CCM does not participate in a wrap fee program.