Allodium is an independent fee-only registered investment adviser providing investment management, financial planning, and fiduciary consulting services. To best serve clients, Allodium is committed to minimizing potential conflicts of interest, providing transparent pricing, and receiving financial compensation only from its clients. Allodium strives to simplify and improve the financial lives of its clients. Where appropriate, Allodium’s advisors will work with a client’s other professional advisors to ensure effective execution of suggested strategies. Allodium has been in business since August 2005 and is owned by David Bromelkamp, Eric Hutchens, Saul Baumann, Derek Van Calligan and Tyler Chapman. This disclosure brochure describes the business of Allodium. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Allodium’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or any other person who provides investment advice on Allodium’s behalf and is subject to Allodium’s supervision or control. Prior to engaging Allodium to provide investment advisory services, the client is required to enter into one or more written agreements with Allodium setting forth the terms and conditions under which Allodium renders its services (collectively the “Agreement”). The specific investment advisory services Allodium provides to each client—as described in detail later in this section—vary based on the client’s needs and are determined by which of the following types of Agreements the client enters with Allodium:
• Wealth Management – discretionary investment management + financial planning services
• Fiduciary Management – discretionary investment management + fiduciary consulting services
• Financial Planning – financial planning services only
• Fiduciary Consulting – fiduciary consulting services only
• Allodium Portfolios – investment management via the Betterment for Advisors platform + limited financial planning services
• Investment Management Consulting – investment management services only on a consulting basis Neither Allodium nor the client may assign the Agreement without the consent of the other party. A transaction that does not result in a change of actual control or management of Allodium is not considered an assignment. Allodium has $396,432,633 of Assets Under Management (AUM) as of December 31, 2023, all of which are managed on a discretionary basis. Separate from its AUM, Allodium has $300,165,013 of Assets Under Advisement (AUA) as of December 31, 2023. Clients with AUA sign the Investment Management Consulting Agreement described above and their assets are managed on a consulting basis as described in the following section.
Page | 5 © 2024 Allodium Investment Consultants Investment Management Services Clients may engage Allodium to manage all or a portion of their investment portfolios on a discretionary, non-discretionary, or consulting basis. When assets are managed on a discretionary basis, Allodium has written authority to implement investment decisions on behalf of the client without first seeking the client's consent. When assets are managed on a non-discretionary basis, Allodium has written authority to implement investment decisions on behalf of the client after first obtaining the client’s consent. When assets are managed on a consulting basis, Allodium provides advice regarding client’s assets without performing continuous supervision of the assets or implementing investment decisions on a client’s behalf, including the hiring, and firing of independent investment managers ("Independent Managers"). Clients may additionally (but are not required to) engage Allodium to perform financial planning and/or fiduciary consulting services as a part of its investment management services, which Allodium refers to as “Wealth Management” and "Fiduciary Management" respectively. Allodium also offers a service called "Allodium Portfolios" for clients with smaller investment portfolios and/or less complex financial situations who require primarily investment management services. Apart from Allodium Portfolios clients, Allodium typically will assist clients in initially determining their investment objectives, risk tolerance, and cash flow needs. Portfolios are customized for each investor. The determination of an appropriate portfolio for each client is a function of current and future cash flow needs, risk tolerance, time horizon, goals, and modeled return. Allodium primarily directs or recommends the allocation of client assets among various asset classes, with a bias for implementing investment strategies with low-fee, tax advantaged investments typically embodied through a passive approach to the markets. However, where certain inefficiencies present themselves or Allodium believes that a manager has an unusual advantage in a marketplace, Allodium may suggest or employ other strategies. These strategies may include Independent Managers, mutual funds, exchange- traded funds (“ETFs”), or other listed securities, in accordance with the investment objectives of its individual clients. Where appropriate, the Firm may also provide advice about client-selected securities, legacy positions, or other investments held in client portfolios. Allodium also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, Allodium either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Allodium tailors its advisory services to meet the individual needs of its clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. Page | 6 © 2024 Allodium Investment Consultants Allodium consults with clients on an ongoing basis to determine changes to their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to

promptly notify Allodium if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Allodium determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to Allodium’s management efforts. With its Allodium Portfolios service, Allodium utilizes the Betterment for Advisors platform to manage client assets in a manner that incorporates broad diversification, periodic rebalancing and investment portfolios that are designed to align with client goals and time horizon. This investment management service is supplemented with an assigned investment consultant who reviews investments relative to financial goals and is available for ad hoc financial planning and investment-related questions depending on the client’s specific needs. Use of Independent Managers As mentioned above, Allodium may recommend that clients authorize the active discretionary management of a portion of their assets by and/or among Independent Managers, based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between Allodium or the client and the designated Independent Managers. Allodium renders services to the client relative to the discretionary and non-discretionary selection of Independent Managers. Allodium also monitors and reviews the account performance and the client’s investment objectives. With respect to any assets placed with Independent Managers, Allodium’s annual advisory fee is typically based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When selecting an Independent Manager for a client, Allodium reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that Allodium considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, will be exclusive of, and in addition to, Allodium’s investment advisory fee as described in Item 5 below. In addition to Allodium’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers impose more restrictive Page | 7 © 2024 Allodium Investment Consultants account requirements and varying billing practices than Allodium. In such instances, Allodium may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Financial Planning and Fiduciary Consulting Services Allodium believes that financial planning and fiduciary consulting services can be as important as investment management depending on the client’s investment needs. Accordingly, financial planning and fiduciary consulting services are offered by Allodium on a one-time basis via standalone Agreements or ongoing as a part of its Wealth Management and Fiduciary Management Agreements, respectively. Financial planning services may include general oversight and guidance for individuals and families on any or all of the following services, among others:
• Financial Goal Setting & Prioritization
• Financial Position Analysis
• Investment Planning
• Retirement Planning
• Asset & Income Protection Planning
• Income Tax Planning
• Philanthropic Planning
• Wealth Transfer & Estate Planning
• Socially Responsible Investing (SRI)
• Concentrated Wealth Strategies As part of Allodium’s Wealth Management Agreement, Allodium performs a comprehensive initial and annual review of each client’s financial situation to provide recommendations in some or all of the above areas. Fiduciary consulting services may include general oversight and guidance for individuals and institutions who serve in a fiduciary role on any or all of the following services, among others:
• Financial Goal Setting & Prioritization
• Financial Position Analysis
• Investment Planning
• Spending Policy Development
• Investment Policy Development
• Financial Analyses
• Investment Governance
• Fiduciary Education
• Socially Responsible Investing (SRI)
• Fiduciary Reviews & Assessments As part of Allodium’s Fiduciary Management Agreement, Allodium performs a comprehensive initial and annual review of each client’s financial situation to provide recommendations in some or all of the above areas. Page | 8 © 2024 Allodium Investment Consultants In performing its services, Allodium is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Allodium recommends the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Allodium recommends its own services. The client is under no obligation to act upon any of the recommendations made by Allodium under a financial planning or fiduciary consulting engagement or to engage the services of any recommended professional, including Allodium itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Allodium’s recommendations. Clients are advised that it remains their responsibility to promptly notify Allodium if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Allodium’s previous recommendations and/or services.