A. The Firm. Tiemann Investment Advisors, LLC (TIA) is a privately held investment advisory business, founded in 2002 and organized as a California Limited Liability Company (LLC). TIA’s owners are Dr. Jonathan Tiemann and Valerie Gardner. Dr. Tiemann commenced with managing a small number of portfolios and within a few months, opened an office on University Avenue in Palo Alto to serve the needs of individual investors and families. TIA relocated to larger offices in Menlo Park in 2004 and remains closely held by Dr. Tiemann and Ms. Gardner. TIA has no subsidiaries or indirect owners. B. Types of Advisory Services. TIA offers two types of investment advisory services to individuals and institutional clients: Portfolio Management and Portfolio Consulting. As discussed below, these advisory services involve components similar to financial planning to facilitate individualized tailoring; however, TIA does not consider itself or hold itself out as a financial planner. In addition, TIA provides various investment services to other investment professionals. PORTFOLIO MANAGEMENT TIA provides continuous investment advice, designing and managing securities portfolios seeking to address the circumstances of each client. The process begins with a profile, which includes the usual considerations of investment horizon and risk tolerance, but goes beyond these to include the client’s individual circumstances and holdings. These circumstances include the client’s occupation, geography, and portfolio restrictions stemming from social preferences, historical loyalties, or restricted holdings. TIA’s approach aims to achieve a portfolio design that complements, rather than redoubles, the risks already inherent in the client’s life and circumstances. In many instances, these considerations lead to individualized choices of sector allocations for client portfolios. TIA manages portfolios that include an array of investments across a variety of asset classes. In general, TIA uses instruments readily traded in US securities markets. For asset classes with sufficiently large allocations, TIA will generally create portfolios of individual securities. This approach applies most commonly to US large-capitalization equities, US Treasuries, and municipal bonds. For asset classes with smaller allocations that do not permit sufficient diversification at reasonable cost through individual securities, TIA may invest through exchange-traded funds (ETFs), and through other pooled vehicles such as mutual funds. Clients will ordinarily give TIA a limited power of attorney to act on a discretionary basis with their funds. TIA will not take or maintain possession or custody of funds or securities for any client. The client funds and securities will typically be deposited in a brokerage firm account, with the broker acting as custodian. With client consent, TIA may cause fees to be paid out of Portfolio Management accounts by the client’s custodian. Prior to doing so, TIA will send the client an invoice showing the amount of the fees, the value of the assets on which they are based, and the fee computation. TIA fees are paid in arrears. PORTFOLIO CONSULTING TIA’s Portfolio Consulting service comprises a series of portfolio planning and design services. These include developing and stating an asset allocation plan, designing a strategy for building a diversified portfolio, and articulating an overall portfolio management strategy. TIA may summarize these plans in a formal Investment Policy Statement designed to govern the implementation of the portfolio plan. Clients engaging TIA for Portfolio Consultation services may also from time to time request that TIA evaluate investment opportunities or managers to which they are contemplating committing funds. TIA will evaluate such opportunities and express a view reflecting the firm’s professional judgment, subject to the understanding that such judgment does not in any way diminish the risks inherent in all investment decisions. In the event that a client has presented TIA with an investment that the client has made which, in TIA’s view, reflects an improper risk, TIA will indicate its view to the client and may recommend an exit strategy. TIA may also perform an ongoing portfolio monitoring and reporting function, creating periodic written reports, if desired. These reports cover the portfolio's value, performance, and effective asset allocation, along with relevant comparisons to market indices and to portfolio plans. These reports will be intended to supplement and interpret clients’ custodial statements, which remain the definitive record of client holdings. TIA may also arrange in-person meetings with clients for some or all of these reviews. While TIA has performed this service for various clients at various times, TIA currently has no Portfolio Consulting clients. SERVICES FOR INVESTMENT PROFESSIONALS. TIA offers to investment professionals the capability of bringing high-level expertise directly to bear on the management of their clients’ portfolios. TIA may provide generic models and presentation materials, individual portfolio analysis, portfolio design services, and, where appropriate, individual portfolio monitoring and custom reporting. Under this arrangement, TIA can be available to meet with clients individually.

Unrelated investment advisors may from time to time choose to recommend that clients allocate all or a portion of their assets to TIA for portfolio management as described above. In all such cases, TIA’s services are distinct from those of the advisor, and provided under a separate contract and for a separate fee, using a schedule negotiated on behalf of the client by the investment advisor. In addition, TIA may perform transition or overlay portfolio management in individual cases. Fees for these services are individually negotiated. Fees for investment professionals depend on the scope of services, and are negotiated and typically paid in arrears. With the exception of portfolio management and construction of model portfolios, TIA is typically compensated for these services on an hourly or fixed fee basis; fees are generally negotiated. Lower fees for comparable services may be available from other sources. From time to time TIA will assist clients in evaluating securities or transactions in which they express an interest. TIA does not propose such transactions or securities, but ordinarily only evaluates them at client request. TIA may negotiate an hourly or flat fee for such an evaluation, and may waive such a fee for Portfolio Management clients. This service may also be part of a Portfolio Consulting service. TIA’s President, Dr. Jonathan Tiemann, may act as an expert witness for various organizations or entities, including governmental agencies. TIA has in the past been engaged to provide expert witness service to the US Department of Labor, but the matter for which Dr. Tiemann performed that function has been resolved. Dr. Tiemann may also consult with commercial entities wishing to become investment advisers or otherwise become involved in or provide services to the US or international investment industry. C. Tailoring of advisory services. PORTFOLIO MANAGEMENT. Tiemann Investment Advisors, LLC (TIA) offers comprehensive, individualized portfolio planning and execution services for high net worth individuals and other investors with significant assets. TIA uses the quantitative tools of Modern Portfolio Theory to design and create portfolios to address the unique risk profile of each client. This profile begins with the usual considerations of investment horizon and risk tolerance, but goes much further, examining the client’s individual circumstances and holdings. These circumstances include the client’s occupation, earnings, asset holdings, geography, and portfolio restrictions stemming from social preferences, historical loyalties, or restricted holdings. TIA’s approach aims to achieve a portfolio design that complements, rather than redoubles, the risks already inherent in the client’s life. In many instances, these considerations lead to individualized choices of sector allocations for client portfolios. Central to TIA’s investment approach is the conviction that, unlike institutions, individual investors each have unique needs and circumstances that should influence their investment choices. Accordingly, while TIA applies a uniform process to the design and management of client portfolios, this process uses inputs that are unique to each client. As a result, each client’s portfolio is unique, and TIA manages each portfolio individually. Because TIA makes no effort to “time” the market, on any given day the focus of portfolio management and trading activity is likely to be the rebalancing or initialization of one or a small number of client portfolios. Due to the nature of the rebalancing and portfolio management discipline, it is not at all unusual for TIA’s activity one day to consist largely of buying stocks for one portfolio on one day, but selling stocks for another portfolio the next. The same is true at the level of individual stocks — it is not uncommon for TIA to buy a particular security in one client’s portfolio on one day, and sell it from another client’s portfolio the next. TIA also seeks to design client portfolios to be advantageous from the client’s particular tax point of view. Tax considerations inform both initial portfolio construction and ongoing portfolio management. When new clients bring existing portfolios, the tax position of the existing holdings can have an important impact on the resulting portfolio. Many times TIA’s structured approach can preserve existing portfolio holdings carried at a capital gain, avoiding the need to create taxable events in restructuring the portfolio. On an ongoing basis, a judicious program of tax management can also defer taxation, often for significant periods. PORTFOLIO CONSULTING. By its nature, TIA’s Portfolio Consulting service includes significant elements that vary according to the particular client’s circumstances. The principles TIA applies in tailoring Portfolio Consulting services are similar to those we apply in Portfolio Management. SERVICES FOR INVESTMENT PROFESSIONALS. These services involve the direct application of Dr. Tiemann’s expertise to the specific problem at hand. D. Wrap fee programs. TIA does not participate in wrap fee programs. E. Client assets. As of February 29, 2024, TIA had discretionary management authority over $302.89 million in client assets in 121 portfolios holding assets in a total of 312 accounts.