4a: Firm Description Ironwood Wealth Management, LLC was established in July 2009. On May 12, 2015, Ironwood Wealth Management, LLC changed its name to Ironwood Financial, LLC (“Ironwood”). Our main office is located in Tucson, Arizona. 4a1: Principal Owners Ironwood is owned and operated by the following individuals:
• Alex Parrs, PLLC; Alexander D. Parrs, CFA, Managing Member: alex.parrs@ironwoodfinancial.com| (520) 318-4600
• Dan Nentl, PLLC; Daniel S. Nentl, Managing Member: dan.nentl@ironwoodfinancial.com | (520) 318-4600
• Dolezal Wealth Management, LLC; Robin R. Dolezal, CFP, Managing Member: robin.dolezal@ironwoodfinancial.com | (520) 318-4600 4b: Types of Advisory Services INVESTMENT ADVISORY SERVICES Ironwood offers a variety of investment advisory services to its clients. Ironwood may be engaged to provide discretionary and/or non-discretionary investment advisory services. Before Ironwood provides investment advisory services, we work with our clients to identify their investment goals, objectives and risk tolerance in order to create an initial portfolio allocation consistent with the client’s designated investment objectives. Ironwood primarily allocates client investment assets among individual equities (stocks), individual fixed income products (bonds), mutual funds, and exchange-traded funds (“ETFs”) consistent with one or more of Ironwood's asset allocation strategies. Once the appropriate portfolio has been determined, we will review the portfolio and rebalance the account based upon our client’s individual needs, stated goals and objectives. Ironwood offers financial planning services for our clients. As requested, we will prepare a written financial plan for financial planning clients. The plan considers all of your assets, liabilities, goals and objectives, as communicated to Ironwood by you, and includes gathering all information necessary to provide you with appropriate and agreed upon services, which may include one or more of the following:
• Investment Strategies
• Investment supervisory services
• Consultations
• Financial planning
• Pension and profit sharing planning
• Endowments
• Foundations
• Business Accounts You are encouraged to review your plans on a regular basis. RETIREMENT PLAN CONSULTING SERVICES In limited instances, Ironwood also provides retirement plan consulting services, pursuant to which it assists sponsors of self-directed retirement plans organized under the Employee Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement shall be set forth in a Retirement Plan Services Agreement between Ironwood and the plan sponsor. To the extent that the plan sponsor engages Ironwood in an ERISA Section 3(21) capacity, Ironwood will assist with the non-discretionary selection and monitoring of investment options (generally open-end mutual funds and exchange traded funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. Ironwood can render the same services on a discretionary basis in its capacity as an ERISA 3(38) investment manager. If requested to do so, Ironwood can be engaged to provide investment advisory services relative to participant retirement plan assets. In such event, Ironwood shall allocate (or recommend that the participant allocate) the retirement account assets among the investment options available on the retirement plan platform. MISCELLANEOUS Limitations of Financial Planning and Consulting Services. As indicated above, to the extent requested by the client, Ironwood may provide financial planning and consulting services regarding topics such as estate planning, tax planning, and insurance matters. Ironwood does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Ironwood does not prepare estate planning documents or tax returns. To the extent requested by a client, Ironwood may recommend the services of other professionals (e.g., attorneys, accountants, insurance agents, etc.), including representatives of Ironwood in their separate individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all such decisions and is free to accept or reject any recommendation from Ironwood and/or its representatives. Clients are advised that if they engage any professional, recommended or otherwise, and a dispute arises thereafter relative to the engagement, the client must seek recourse exclusively from the engaged professional. At all times, the engaged professional(s), and not Ironwood, shall be responsible for the quality and competency of the services provided. Retirement Rollovers. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Ironwood recommends that a client roll over their retirement plan assets into an account to be managed by Ironwood, such a recommendation creates a conflict of interest if Ironwood will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Ironwood. ERISA / IRC Fiduciary Acknowledgment. When Ironwood provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, it does

so as a fiduciary 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 Ironwood makes money creates some conflicts with client interests, so Ironwood operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, Ironwood must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Ironwood gives advice that is in the client’s best interest;
• Charge no more than is reasonable for Ironwood’s services; and
• Give the client basic information about conflicts of interest. Account Aggregation Platforms. Ironwood may provide its clients with access to online platforms hosted by “eMoney Advisor” (“eMoney”) and/or Morningstar, Inc. (collectively, the “Platforms”). The Platforms allow clients to view their complete asset allocation, including those assets that Ironwood does not manage (the “Excluded Assets”). Ironwood does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, Ironwood shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not Ironwood, shall be exclusively responsible for such investment performance. The client may choose to engage Ironwood to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Ironwood and the client. The eMoney platform also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by Ironwood. Finally, Ironwood shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without Ironwood’s assistance or oversight. Cash Positions. Ironwood considers cash and cash equivalents to be a material aspect of a client’s investment allocation. Depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Ironwood may maintain cash and cash equivalent positions (such as money market funds, etc.) for defensive, liquidity, or other purposes. Unless otherwise agreed in writing, all such cash positions are included as part of assets under management for purposes of calculating Ironwood’s advisory fee. Clients are advised that, at any particular point in time, the yield earned on cash and cash equivalent positions may be lower than Ironwood’s annual asset-based fee. Periods of Portfolio Inactivity. Ironwood has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Ironwood will review client portfolios on a regular basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Ironwood determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Ironwood will be profitable or equal any specific performance level(s). Non-Discretionary Service Limitations. Clients that determine to engage Ironwood on a non-discretionary investment advisory basis must be willing to accept that Ironwood cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Ironwood would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Ironwood will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations. In performing its services, Ironwood shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Ironwood if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Ironwood’s previous recommendations and/or services. 4c: Client Tailored Relationships and Restrictions Your portfolio is customized based on your investment objectives. You may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination of our agreement. Similarly, you are under no obligation to act upon Ironwood’s or associated person’s recommendations. If you elect to act on any of the recommendations, you are under no obligation to effect the transaction through Ironwood or its associated persons. 4d: Wrap Fee Program Ironwood does not participate in a wrap fee program. 4e: Assets under Management (AUM) Ironwood, as of December 31, 2023, has $453,704,695 in discretionary Regulatory Assets Under Management and $2,774,465 in non-discretionary Regulatory Assets Under Management for a total of $456,479,160.