Business Background Peak Capital Management, LLC (“PCM”) was formed in June 2007 as a Limited Liability Company (LLC) and is registered as an investment advisor with the Securities and Exchange Commission. Effective April 2013, the principal owners were Brian Lockhart and Geoff Eliason. In February 2020 PCM was acquired by Shepherd Kaplan Krochuk, LLC (“SKK”), a Boston-based investment adviser registered with the SEC, which is now PCM’s sole Managing Member. Brian Lockhart remains as Chief Investment Officer and also became Chief Executive Officer of PCM following the acquisition, and he also holds an indirect minority membership interest in SKK, a direct membership interest in SKK Group, LLC, which serves as the managing member of the general partners or managers of a number of SKK-affiliated funds and is a member of SKK’s Management Board. Although service enhancements have been implemented, the PCM team remains in place and the acquisition has not resulted in material changes to the services being provided by PCM to its clients. More information can be obtained about SKK in its Form ADV Part 2A brochure available at www.adviserinfo.sec.gov. Also, see Items 10 and 11 of this brochure for additional information regarding our relationship with SKK. PCM develops investment strategies designed to manage risk utilizing an absolute return philosophy. The basis of these strategies is to seek an investment return less dependent on the returns in the stock and fixed income markets, while seeking to reduce volatility. Effective in March 2023, Bayard Dodge has replaced Peter J. DiLorenzo as Chief Compliance Officer of PCM. Advisory Services Investment Management Advisory services are tailored to meet the individual needs of clients with the use of Risk Profile Questionnaire (“RPQ”), which is a tool that PCM uses to classify each client into risk tolerance levels including: growth, balanced, and income. Client funds are invested into models or other investments that are appropriate to their specific risk tolerance. In limited circumstances, PCM may recommend allocations to models and/or investments with a different risk profile than the one identified in the client’s RPQ, such as when the client holds other assets not managed by PCM, which PCM’s recommended allocation seeks to counterbalance, e.g., PCM might recommend conservative investments to a client which expressed a moderate risk tolerance, to balance a client’s holding of aggressive assets held outside PCM managed accounts. PCM’s models are diversified, multi-strategy equity and fixed income portfolios that are tactical in nature and hold combinations of individual stocks, exchange-traded funds (“ETFs”), mutual funds, U.S. treasury obligations, and/or short funds. Sub-Advisory and Research Services PCM’s management of diversified portfolios primarily utilizing exchange-traded funds, individual stocks, and mutual

funds enables other registered investment advisors to engage PCM in a sub-advisory and/or signal provider capacity, which permits them to allocate their clients’ assets into model investment portfolios designed and managed by PCM. These models incorporate ETFs, individual stocks, mutual funds, U.S. treasury obligations, and/or short funds. Such advisors retain fiduciary responsibility for their clients, and PCM’s services are provided pursuant to agreements with such advisors and not with their clients. In these circumstances, PCM typically charges a sub-advisory or signal provider fee to the advisor that is a percentage of the assets allocated to PCM models, but its fee may include minimum fees and/or fixed amounts. These sub-advisory arrangements may be negotiated directly with advisors, or in other circumstances PCM may allow advisors to allocate client funds into PCM models through third-party platforms facilitating such allocation. Financial Planning As part of its service offerings, PCM offers financial planning with respect to estate, retirement, and tax plans. Clients are under no obligation to contract for a financial plan service in order to receive investment management and may contract for financial planning without utilizing investment management services. The initial financial planning engagement will include the following services:
• Review of the Client’s personal and financial goals
• Net worth calculations and cash flow analysis
• Projection and estimation of federal and state income taxes
• Estate planning review
• Retirement income planning
• Investment portfolio evaluation and recommendations
• Education and succession planning, where appropriate Tailored Services We offer investment advice to every client based upon their specific circumstances, including investment objectives, financial goals, and risk tolerance. Clients may impose restrictions on investing in certain securities or types of securities by providing in writing, and within 30 calendar days of advance notice, specific restrictions they wish to impose. Participation in Wrap Fee Program We do not participate in a wrap fee program. Regulatory Assets Under Management As of December 31, 2023, PCM managed client assets totaling approximately $155,703,109. Approximately $109,089,276 are managed on a discretionary basis and approximately $46,613,833 are managed on a non- discretionary basis. Assets Under Advisement Assets under advisement refer to assets on which our firm provides advice or consultation but for which we either do not provide regular and continuous supervisory or management services or do not arrange or effectuate the transaction. There is no requirement to disclose the assets under advisement figure, but we have opted to include the figure to give prospective clients a more complete picture of the firm’s responsibilities. The Firm had approximately $58,625,654 in assets under advisement for 20 accounts.