Firm Description GrowStrong Wealth Strategies, LLC (“GrowStrong”) was founded in 2020 and became licensed as a Registered Investment Advisor in July of 2020. Clayton Olson is the Managing Member and Chief Compliance Officer. Clayton Olson, Gina Waite, and Erik Utzinger are equal owners. Types of Advisory Services ASSET MANAGEMENT GrowStrong offers discretionary asset management services to advisory Clients. GrowStrong will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize GrowStrong discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Variable Annuity and Life Management GrowStrong offers discretionary direct asset management services to advisory Clients on their variable annuities and variable life products. GrowStrong will work with individuals to assemble an appropriate portfolio of investment options as provided through the insurance company that services variable annuity investment. The accounts will be monitored at least on an quarterly basis. THIRD PARTY MANAGERS When deemed appropriate for the Client, GrowStrong may recommend that Clients utilize the services of a Third-Party Managers (TPM) Global View Capital Management, LTD., Howard Capital Management, Inc. (“HCM”), or The Pacific Financial Group, Inc. (“TPFG”) to manage a portion of, or your entire portfolio. All TPMs that we recommend must either be registered as investment advisers with the Securities and Exchange Commission or with the appropriate state authority(ies). After gathering information about your financial situation and objectives, an Associated Person of our firm will make recommendations regarding the suitability of a TPM and investment style based on, but not limited to, your financial needs, investment goals, tolerance for risk, and investment objectives. Upon selection of a TPM(s), we will monitor the performance of the TPM(s) to ensure their performance and investment style remains aligned with your investment goals and objectives. Howard Capital Management, Inc. (“HCM”) includes two types of accounts.
• Separately Managed Accounts (SMA): Assets are placed with Howard Capital for them to manage at one of the custodians that they have an agreement with. HCM can manage most types of accounts through this program and GrowStrong can choose between any of HCM’s strategies subject to strategy minimums.
• Self-Directed Accounts (SDBA) If a Client’s employer’s 401k plan has a SDBA option and allows for a Third-Party Money Manager then GrowStrong can choose to use HCM to manage a portion the 401k without the funds leaving the 401k plan. The custodian is determined by the 401k plan. HCM uses their mutual funds as the investment options for the SDBA. In such circumstances, GrowStrong receives solicitor fees from the TPM. We act as the liaison between the Client and the TPM in return for an ongoing portion of the advisory fees charged by the TPM. We help the Client complete the necessary paperwork of the TPM, provides ongoing services to the Client. Ongoing services include but are not limited to: 1. Deliver the Form ADV Part 2, Privacy Notice and Solicitors Disclosure Statement of the TPM to the Client. 2. Meet with the Client to discuss any changes in status, objectives, time horizon or suitability; 3. Update the TPM with any changes in Client status which is provided to GrowStrong by the Client; 4. Review the statements provided by the TPM and provide ongoing account monitoring. GrowStrong will provide the TPM with any changes in Client status as provided to us by the Client and review the quarterly statements provided by the TPM. GrowStrong will deliver the Form ADV Part 2, Privacy Notice and Solicitors Disclosure Statement of the TPM. Clients placed with TPM will be billed in accordance with the TPM’s Fee Schedule which will be disclosed to the Client prior to signing an agreement. This is detailed in Item 10 of this brochure. FINANCIAL PLANNING AND CONSULTING If the client engages the firm for financial planning services, a comprehensive evaluation of an investor's current and future financial state will be provided by using currently known variables to predict future cash flows, asset values and withdrawal plans. GrowStrong will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Typical topics reviewed in a financial plan may include but are not limited to:
• Financial goals: Based on an individual's or a family's clearly defined financial goals, including funding a college education for the children, buying a larger home, starting a business, retiring on time or leaving a legacy. Financial goals should be quantified and set to milestones for tracking.
• Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution.
• Comprehensive risk management plan: Identify all risk exposures and provide the necessary coverage to protect the family and its assets against financial loss. The risk management plan includes a full review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage.
• Long-term investment plan: Include a customized asset allocation strategy based on specific investment objectives and a risk profile. This investment plan sets guidelines for selecting, buying and selling investments and establishing benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include identification of tax- favored investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. Because the firm can recommend to a financial planning client that they engage in investment management services a conflict of interest exists between the interests of GrowStrong and the interests

of the Client, the Client always has the right to decide whether to act upon GrowStrong’s recommendation. If the Client elects to act on any of the recommendations, the Client has the right to effect the recommended transactions through the professional of their choosing. Financial plans will be completed and delivered inside of sixty (60) days contingent upon timely delivery of all required documentation. ERISA PLAN SERVICES Non-Fiduciary Services. GrowStrong 401k may provide retirement plan consulting services in regard to plan selection and design. GrowStrong 401k may also provide general education and enrollment support to the participants of the plan and other services that do not fall under the scope of a fiduciary under ERISA. GrowStrong provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. GrowStrong may act as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. GrowStrong may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor GrowStrong has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using GrowStrong can help the plan sponsor delegate liability by following a diligent process. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. GrowStrong acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. ERISA 3(38) Investment Manager. GrowStrong can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. GrowStrong would then become jointly responsible with the plan trustees and liable for the selection, monitoring and replacement of the plan’s investment options. Fiduciary Services are:
• GrowStrong has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5).
• Meet with Client on a periodic basis to discuss the investment fund lineup. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands the GrowStrong’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the GrowStrong is not providing fiduciary advice as defined by ERISA to the Plan participants. GrowStrong will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees.
• Consulting on the plan type and design of the retirement plan. GrowStrong 401k will also assist in periodic review of the Recordkeeper and Third Party Administrator (if applicable) in regard to their fees and services offered. GrowStrong may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between GrowStrong and Client. 1. GrowStrong has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Advice on participants stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. SEMINARS AND WORKSHOPS GrowStrong holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without prior written Client consent. Client Assets under Management As of April 23, 2023, GrowStrong had $83,000,000 in client assets under management on a discretionary basis and $4,400,000 on a non-discretionary basis.