Peak Financial Advisors, LLC founded in 1997, (referred to throughout as we, us, our or the firm) is owned by Brian T. Sells and Debbie J. Freeman. Peak Financial Advisors has been registered as an investment advisor with the United States Securities and Exchange Commission (“SEC”) since September 4, 2001. The full-time team at Peak Financial Advisors consists of:
• Brian T. Sells, Managing Partner & Chief Investment Officer
• Debbie J. Freeman, Partner & Director of Financial Planning
• Lorraine E. Haverley, Chief Compliance Officer & Director of Client Service In addition to the full-time staff, we have a part-time consultant named Steve Ketterling, who assists Brian with portfolio management, research, due diligence and trading. Portfolio Management Services – Portfolio Management Services involves providing clients with continuous and on-going supervision over their accounts. This means we will adjust positions and asset allocations as necessary to help achieve the client’s investment goals. When providing portfolio management services we consider a variety of vehicles including exchange traded equities, no-load mutual funds, exchange traded funds (ETFs), exchange traded notes (ETNs), preferred stocks, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal bonds, convertible bonds, publically traded partnerships, U. S. government securities and options strategies . We build portfolios to help clients achieve their financial goals and objectives; however, we are not limited to those investments. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings as deemed appropriate based on your risk tolerance and short and long-term goals. In our effort to manage the volatility of the portfolio, we use our discretion to keep volatility within the client’s parameters by adjusting the holdings as we deem necessary. Our services are provided based on the needs of each client. This means, for example, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. We will not necessarily verify any information received from the client or from the client’s other professionals, and we are authorized to rely on the information provided. It is each client’s responsibility to promptly notify us if there is ever any change in their financial or personal situation or investment objectives for the purpose of reviewing our previous recommendations. If a client decides to affect an IRA Rollover from a employer retirement plan to an account managed by us, or if we make a recommendation to affect a rollover, we could have a conflict of interest given that our IRA advisory fees can be higher than those within an employer retirement plan. To mitigate such conflicts, we will disclose relevant information about the applicable fees we charge for managing an IRA prior to opening an IRA rollover account. The decision as to whether to take a distribution from any retirement account rests solely with the individual participant. Department of Labor Acknowledgement of Fiduciary Duty - When we provide investment advice to you we are fiduciaries. 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. Under this special rule’s provisions, we must: PEAK FINANCIAL ADVISORS LLC | 155 SOUTH MADISON STREET, #210 | DENVER, CO 80209 5
• 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 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. Financial Planning Services – We offer advisory services in the form of financial planning services. Financial planning

services do not involve the on-going management of client accounts, but instead focuses on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set and achieve financial objectives. Our financial planning process is based on understanding each client’s personal financial situation and objectives. We analyze the client’s financial documentation. As applicable, we then review the client’s assets and liabilities, investment portfolio, retirement plan, education plan, risk management plan, insurance plan, risk tolerance and estate plan as well as other areas relevant to the client’s financial health. We will provide an executive summary highlighting our recommendation and plan of action. We are available to assist with implementation of the plan and to answer any client questions, but the client is ultimately responsible for the implementation or rejection of our recommendations. You are never obligated or required to implement our recommendations. We are available to work with the client throughout the year to implement the plan. It remains the client’s responsibility to promptly notify us if there are any changes in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations. Tax Return Preparation We offer tax preparation and planning services. You are not obligated to use our tax services in any way. Tax preparation work is not included in the financial planning or asset management fees, unless negotiated. Persons Residing Outside of the United States Services for client’s residing outside of the United States may be restricted or limited due to custodial rules or other factors. Investment options and strategies may differ from our typical recommendations, including but not limited to, foreign tax treatment of investment transactions in the United States. In addition, foreign laws or requirements may also impact our ability to service accounts or require additional disclosure as determined on an individual country basis. The client will be responsible for satisfying all legal and tax reporting requirements of both the United States and all applicable foreign governments. Any person located outside of the United States who wishes to open an account, or existing client who re-locates outside of the United States, will be subject to Charles Schwab & Co., Inc.’s policy regarding that country (including their right to decline to open or maintain the account), and all applicable customer identification and anti-money laundering regulations. We reserve the right, in our sole discretion, to decline an engagement with any prospective client outside the United States, or terminate an engagement with an existing client, if they move outside of the United States. PEAK FINANCIAL ADVISORS LLC | 155 SOUTH MADISON STREET, #210 | DENVER, CO 80209 6 Client Assets Managed by Peak Financial Advisors As of December 31, 2023, Peak Financial Advisors managed $230,298,334 in assets for 125 clients - $226,813,250 is managed on a discretionary basis and $3,485,084 is managed on a non-discretionary basis.