4a: Firm Description Portland Private Wealth Management, Inc., also doing business as Eugene Private Wealth Management and Bend Private Wealth Management. (“PPWM,” “we,” “us,” “our,” and “firm”), is an SEC registered investment advisor established in 2014 by its principals, Jason McMillen and Jacob Becker. Prior to that, Mr. McMillen was an investment advisor representative of First Allied Advisory Services and registered representative with First Allied Securities, Inc. since 2007, providing investment advisory and brokerage services as an independent financial advisor under the assumed business name Portland Private Wealth Management, Inc. Mr. Becker joined PPWM in 2010. Mr. McMillen has been in the financial services industry since 1996. Mr. Becker has been in the financial services industry since 2000. Our main office is located in Portland, Oregon. We also maintain branch offices in Eugene, Oregon and Bend, Oregon. Contact information for each of our offices is as follows: City Street Address Phone Portland (Main Office) 1834 SW 58th Ave., Suite 101, Portland, OR 97221 (503) 405-9472 Eugene 321 Mill Street, #6, Eugene, OR 97401 (541) 484-1444 Bend 532 SW 13th Street, Ste. #100, Bend, OR 97702 (541) 323-3455 4b: Types of Advisory Services Wealth Management Services PPWM provides ongoing and continuous wealth management services to individuals, corporations, and non-profit organizations. We are not a custodial firm, nor do we offer any brokerage services for a commission. We provide investment advice, counsel, and consultation to investors for a fee. Clients deposit their assets to an account held in their name at an independent custodial firm, such as Charles Schwab & Company, Inc. (“Schwab”), and grant us limited authority to buy and sell securities either on a discretionary or non-discretionary basis. When we are engaged on a discretionary basis, you authorize us to implement our investment recommendations within your account without obtaining your approval of each specific transaction. When you engage us on a non-discretionary basis, we must obtain your approval prior to implementing our investment recommendations in your account and you are free to accept or reject any of our advice. We act as your fiduciary, responsible for the supervision and management of your investment account(s) at the custodian in a manner that comports with your investment goals, needs, limitations, and best interests. Advisory fees are generally charged based on a percentage of the value of the assets you place under our management at the qualified custodian (i.e., and asset-based fee). Please see Item 5 of this brochure for a detailed description of our fee arrangements. PPWM utilizes a disciplined investment advisory process for each client. Portfolio solutions are based on the traditional client profile and an Investment Policy Statement (“IPS”) we will prepare on your behalf (the IPS is described in further detail below in this Item 4). From this information, we attempt to determine your willingness and ability to withstand short-term declines in portfolio value in pursuit of longer-term performance and investment objectives. We consider a wide range of asset classes, markets, and securities for inclusion in your portfolio. Each quarter, we review the results in an attempt to improve our process with the goal of producing better outcomes in the future. Based on our process, clients generally receive the following advisory services inclusive of our advisory fee: Advisory Services 1) Client Profile and Financial Planning 2) Asset Allocation 3) Risk Number & Stress Testing 4) Preparation of an Investment Policy Statement 5) Portfolio Design and Construction 6) Security Selection 7) Implementation, Execution, Monitoring and Review 8) Research 9) Investor Education We will consult with you at the inception of the relationship and periodically thereafter, as necessary to develop an understanding of your unique client profile. We will gather information regarding your investment objectives and goals, risk tolerance, time horizon for investments, investment experience, and current financial situation. We will use this information to prepare an IPS and, at your request, to prepare a written financial or retirement plan. We will update your IPS and plan periodically based on any material changes in your investment objectives and needs, time horizon for investments, and risk tolerance occurring over time. A description of our financial planning services can be found below. We will use the information contained in your IPS and/or plan to provide you with investment advice and to aid in the design and construction of your investment portfolio, which will typically be implemented through use of proprietary model portfolios we have designed based on the Morningstar Target Risk Asset Allocation framework. Most portfolio designs are a balance of stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), inflation hedges, and cash. We use the Morningstar Target Risk Asset Allocation Framework to help investors understand their general risk exposure to financial markets. We may overweight or underweight various asset classes relative to the client’s target risk benchmark based on our outlook for the investment environment, economic conditions and forecasts. Some clients may have special circumstances where portfolios may differ from our standard investment solutions. Such portfolios will fall under the Private Advisory Accounts described below. Once a client agrees with a recommended portfolio solution, we will make the necessary trades and monitor the portfolio regularly, suggesting changes for non-discretionary accounts or directly implementing such changes for discretionary accounts as we believe to be appropriate, including swapping out positions or rebalancing of your portfolio holdings. Although we typically use our in-house designed model portfolios in managing client accounts, actual account positions may differ from the model portfolios for a variety of reasons, including the existence of legacy positions with low cost basis in the client’s account, the closure of a fund to new investors, or the minimization of trading costs. We allow flexibility because many clients have a unique situation or circumstance which should be considered because it is in their best interest. Rebalancing, in general, is tactical in nature, meaning we do not do automatic rebalancing. Additionally, we may tactically enter a recommended portfolio solution for new clients. This means we might scale into a portfolio over time based on our views of financial markets and the general attractiveness of entry and exit points for the securities in question. Private Advisory Accounts As described above, some clients may want portfolio solutions unique to them and their situation which may differ from our proprietary model portfolio

solutions. We may, at the client’s discretion, offer such solutions which are generally reserved for accounts exceeding $1,000,000 in value. We refer to these accounts as Private Advisory Accounts (“PAAs”). PAAs may have legacy positions with low-cost basis, concentrated positions, the use of individual securities instead of the mutual funds we commonly use in our model portfolios, a special investment strategy, the use of options, hedging, shorting, or a portfolio where the client will want involvement in the selection and trading of the instruments in the portfolio. Like model portfolio-based accounts, PAAs may be discretionary or non-discretionary in nature. PAAs are not considered “special accounts” by the firm -- these are simply clients that may have a special need or circumstance that is different than most of our clients. Our aspiration is that each client gets the best of what the firm can offer for them and their situation. What is best for one client may not be best for the next client. Financial Planning Services As described above, we offer financial planning services for our clients that are integrated into our suite of wealth management services at no additional cost beyond our asset-based advisory fees. From time-to-time, clients will engage us for financial planning advisory services only or will engage us for financial consulting services beyond our normal advisory services. We may charge either a flat fee for such advisory services or charge an hourly advisory consulting fee. We prepare a financial plan for all financial planning clients using software programs such as eMoney or Morningstar. The plan considers all your assets, liabilities, goals and objectives, and includes gathering all of the information necessary to provide you with financial advice and services which will include some or all of the following, depending on your needs:
• risk tolerance and investment objective review;
• portfolio goal setting;
• retirement planning;
• evaluation of savings in relationship to your retirement goals;
• determination of appropriate vehicles for savings;
• advice regarding cash flow and taxes;
• advice regarding debt management;
• stock option planning;
• tax planning;
• investment review;
• analysis of personal and retirement investments for diversification, internal expenses and volatility;
• discussion of college savings plans and their benefits;
• advice regarding risk management, income protection, disability planning, and other insurance needs;
• estate document review;
• review of wills, trusts and incapacity documents in relation to current objectives;
• evaluation of the need for revisions to your estate plan with your estate planning attorney;
• charitable planning;
• evaluation of current, long-term, and charitable goals and determination of appropriate assets for funding;
• planning of charitable gifts to maximize tax savings;
• determination of priority among competing goals;
• incorporation of common and individual goals of spouses;
• advice regarding family gifting, including evaluation of the timing, benefits, and risks of family gifting;
• advice regarding specific financial considerations or transactions; and
• other wealth management consultation or financial related projects. To correctly and adequately provide financial planning advisory services, clients will need to provide detailed information and documentation. You maintain the sole discretion to accept or reject any of our financial planning recommendations and will be responsible for the implementation and monitoring of your investments. Clients are never required to utilize us to implement any of our financial planning recommendations. We encourage you to review your financial plan on a regular basis, especially if there is any change in your financial situation, investment objectives, plans, goals, risk tolerance or time horizon. Retirement Plan Investment Consulting and Advisory Services For business entity clients, we offer consulting services regarding the design, development, implementation, monitoring, and review of retirement plans for their businesses. We generally provide non-discretionary ERISA fiduciary services and other advisory services not deemed ERISA fiduciary services to these clients. Non- discretionary fiduciary services may include advice consistent with ERISA Section 3(21) which includes advice regarding the selection, monitoring and reviewing of investment plan options. Non-fiduciary services include advising responsible plan fiduciaries on the development of an investment policy statement, review and suggested amendments to existing investment policy statements, quarterly investment monitoring, quarterly meetings with plan fiduciaries or administrators, fee and expense analysis for the plan, benchmarking services and analysis of the operation of the plan, and plan participant group education meetings. 4c: Client Tailored Relationships and Restrictions When you engage us for advisory services we act as your fiduciary. This means that we must act in your best interests. A fiduciary is a professional capacity where we must use care, prudence, diligence, and sound judgment as we render counsel and advice to our clients. Our portfolio solutions and investment selections are based on your investment objectives, risk tolerance, and time horizon. Clients may make requests or suggestions regarding the selection of investments made in their portfolio which may include socially responsible or environmentally friendly mutual funds, as an example. The client may instruct us to exclude certain investments such as companies involved the manufacture of weapons of mass destruction, the production of coal, or animal testing, as examples. In our capacity as a fiduciary, we cannot follow instructions that we believe may not be in your best interest. This may include purchasing a concentrated position in a single security, restricting our ability to make trades or investments that we believe are in your best interest, or any speculation that we believe to be unnecessary and potentially harmful to your financial situation and/or goals. We may terminate a client relationship if we are put in a position that we believe compromises our fiduciary duties. 4d: Wrap Fee Program We do not sponsor, manage, or recommend any wrap fee programs to clients. 4e: Assets under Management (AUM) As of January 18, 2024, PPWM had approximately $194,028,122 in discretionary assets under management (“AUM”) and an additional $6,208,012 of non-discretionary assets under management, for total regulatory assets under management of $200,236,134. Separate and in addition to the foregoing amounts, as of December 31, 2023, we also provide advice to eleven (11) corporate retirement plans containing approximate combined assets of $48,212,724.