Description of Firm Twin Peaks Wealth Advisors, LLC is a registered investment adviser based in Burlingame, CA. We are organized as a limited liability company under the laws of the State of California, and became a registered investment adviser in November 2022. Tushar Kumar and Vishal Kumar are the owners of our firm. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this Brochure, the words "we," "our," and "us" refer to Twin Peaks Wealth Advisors, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Wealth Management Services Wealth management services consist of ongoing financial planning and discretionary investment management services where we manage our clients’ investments within the larger context of the client’s overall wealth management and planning process. These services are tailored to clients (individuals or families) with $2,000,000 or more of investable assets. These services include an initial consultation along with follow up consultations, as may be agreed, to discuss your unique investment objectives, time horizon, risk tolerance, tax circumstances, and various other financial factors. Based on our evaluation of the foregoing factors, we will use the information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our wealth management services, we will customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will periodically rebalance the portfolio as required by, among other things, changes in market conditions and in your financial circumstances. Clients are required to notify our firm immediately if their financial circumstances and/or investment objectives change from what has already been disclosed to our firm. If you engage our firm for wealth management services, you must grant our firm discretion over the selection and number of securities to be purchased or sold for your account(s). Discretionary authority enables our firm to execute transactions within your account without obtaining your consent or approval prior to each transaction. In limited circumstances and in our sole discretion, we may accept instructions from you that limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account). Such requests must be presented to our firm in writing. This discretionary authority will also provide our firm with authorization to delegate discretionary investment management services to other unaffiliated Sub-Advisors selected by our firm based on your investment objectives and portfolio strategy. Please refer to Item 16 of this Brochure for more information on how we manage your account(s) with discretion. For clients with less than $2,000,000 in assets under management, our wealth management services consist solely of investment management services and do not include complimentary ongoing financial planning and consulting services. In these instances, clients have the option to engage our firm for stand-alone financial planning and consulting services for a separate and stand-alone fee. Management of Held Away Assets As part of our wealth management services, we provide asset allocation review, rebalancing and management services for accounts that are not held in custody of the qualified custodian(s) recommended by our firm. These services are provided through an account aggregation service called Pontera. The service primarily applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in custody of the plan custodian(s). We regularly review the available investment options in these accounts, monitor them, and periodically rebalance and implement our strategies using different tools,

as necessary. If you elect to allow our firm to manage your assets through Pontera, you will be notified via email when we place trades through Pontera. Under no circumstances will we possess privileges that would impute custody to our firm under applicable rules and regulations, including, but not limited to: maintaining your account log-in credentials on file; having the ability to change your address on record or ability to authorize distributions from your accounts; or authorization to open any new accounts on your behalf through the web-based platform. LPL Financial Sponsored Advisory Programs We may provide advisory services through certain programs sponsored by LPL Financial LLC (“LPL”), a registered investment advisor and broker-dealer. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please see the program account packet (which includes the account agreement and LPL Form ADV program brochure that we provide you). Below is a brief description of the LPL program(s) that we generally use: Model Wealth Portfolios Program (MWP) - MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. We will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department, a third-party portfolio strategist and/or Advisor, through its IAR, may act as a portfolio strategist responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $10,000. In certain instances, a lower minimum for a portfolio is permitted. Financial Planning and Consulting Services We offer financial planning and consulting services where we provide a variety of advisory services to clients regarding the management of their financial assets based upon an analysis of their individual needs. These services can range from broad-based financial planning with investment recommendations to consultative or single subject planning. Financial planning and consulting services are based on your financial situation at the time we present our recommendations to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial recommendations. Should you choose to act on any of our recommendations you are not obligated to implement such recommendations through any of our other investment advisory services, and you may act on our recommendations by placing securities transactions with any brokerage firm. Types of Investments We may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client’s specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. We do not participate in a wrap fee program. Assets Under Management As of January 30, 2024, we manage approximately $318,501,282 in client assets on a discretionary basis.