A.) Description of the Advisory Firm. Boston Mountain Money Management, Inc. was incorporated in 2007. Since inception we have operated in one and only one business ‐ providing personalized financial advice and investment management services to individuals. The firm is majority owned by its founder, Scott Alaniz. B.) Types of Advisory Services. We provide advisory services in two areas: financial planning and discretionary investment management. Mr. Alaniz, with the support and supervision of the firm’s employees, performs all planning and investment services to clients. Mr. Alaniz possesses thirty‐one years of investment experience, has earned the Chartered Financial Analyst designation and is able to advise clients regarding a broad range of investment scenarios. Our financial planning advice and investment management counsel are integrated as we believe that integration of these responsibilities is the most effective approach to helping our clients achieve their financial objectives. Our approach to investment management is best described as classical. Each client’s portfolio is comprised of individual stocks and bonds and low‐cost exchange‐traded funds that we have carefully evaluated as to quality and price. Our approach encompasses both top‐down and bottom‐up analysis. We believe in the financial tenets of diversification and compounding. As such, we seek to identify and own investments for long periods of time. Our top‐down analysis includes seeking to understand key investment trends and themes across asset classes, styles, and sectors and incorporates both qualitative and quantitative methods. Additionally, our individual stock analysis consists primarily of fundamental analysis, and we may rely on ratings and reviews from third parties. We target low‐turnover and seek to minimize taxes and transaction costs. Further, we do not “sell” any financial products. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment

objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken 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 accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be 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. C.) Client Tailored Services and Client Imposed Restrictions. Our financial advisory services are tailored to each individual and/or their family. Our financial planning advice is based on in‐depth interviews with our clients and prospective clients where we seek to learn as much as possible about their needs and resources. Based on the clients’ income, expense, asset and liability information and goals, we develop individualized, detailed projections of future income and obligations under various scenarios to show clients their options and related risk for achieving their goals. We develop a long‐term investment strategy to achieve their objectives. Our approach to investment management is best described as classical. Each client portfolio is created and managed for that client based upon their individual goals and risk tolerance. We offer our clients the choice of excluding from their portfolios certain securities to meet diversification, socially responsible or other concerns. D.) Wrap Fee Programs. We do not offer or participate in wrap fee programs. E.) Assets under Management. As of December 31, 2022 we manage $165,042,524 in client assets on a discretionary basis. We do not manage any assets on a non‐discretionary basis.