Cherry Creek Investment Advisors, Inc. (CCIA) was founded in 1994 by Sean Castle and Patricia McNamara. CCIA offers professional investment advisory services to the private investor. These services include analyzing the client’s current financial objectives, risk constraints, designing and implementing an individually tailored investment portfolio to meet these needs. As of December 31, 2023, we managed $245,125,424 in client assets on a discretionary basis for 254 clients. We do not manage non-discretionary accounts. Robo Advisory services (Right Track). We also offer an automated investment program (the “Program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETF”s) and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc, (“CS&Co”). We use the Institutional Intelligent Portfolios platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program.. We are independent of and not owned by, affiliated with, or sponsored or supervise by SPT, CS&Co., or their affiliates. We and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the program. The platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the system in response to the client’s answers to the online questionnaire. The client may then indicate and interest in a portfolio that is one level less or more conservative or aggressive that the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge a flat .75bps as described below in Item 5. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Because we maintain $100 million in client assets in accounts at CS&Co that are not enrolled in the program we do not pay SWIA and fees for its services in the Program. The Right Track offering is a digital limited contact program. These clients are not entitled to our full

suite of services. Occasional contacts by phone or Email, a weekly digital newsletter, as well as an annual meeting opportunity, as requested by the client are included. As an independent firm, we work for our clients only and base all of our investment decisions on objective analysis and independent research. All client account information is kept in strict confidence. Each account is managed individually by a professional portfolio manager. Some of the additional services we offer include but are not limited to retirement planning, monthly investment plans for education and retirement, consultation on estate planning, asset valuation and strategies for financial planning. Retirement Plan Rollovers When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. By acting in your best interest, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1. Leaving the funds in your employer's (former employer's) plan 2. Moving the funds to a new employer’s retirement plan 3. Cashing out and taking a taxable distribution from the plan 4. Rolling the funds into an IRA rollover account Each of these options has advantages and disadvantages and prior to making a decision you should carefully review the information regarding your rollover options and discuss any questions with your investment adviser representative. In the event CCIA recommends that a client roll over their retirement plan assets into an account to be managed by the Firm, such a recommendation creates a conflict of interest. The conflict of interest exists because the Firm will receive compensation (management fees) if the money is rolled over. No client is under any obligation to rollover retirement plan assets to an account managed by CCIA. CCIA’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation.