Denali Wealth Management, Inc. (“DWM”) is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). It is also notice-filed in various states. The firm provides counseling and financial planning, asset management and investment counseling services to its clients. DWM became registered as an investment adviser with the SEC in March 2010. DWM is owned by Carl A. Valimont. DWM does not engage in any other business, or control any other firm. The advisory services of DWM are described in detail below. COUNSELING AND FINANCIAL PLANNING SERVICES In designing a project or comprehensive financial plan, regardless of the complexity, DWM Representatives will:
• Interview the client, analyze the client’s financial needs, and assist the client in developing realistic goals and objectives based on information provided by the client. The Representative may also clarify planning problems and outline strategies designed to meet the client’s goals. A client may retain DWM to perform a single non-recurring project, such as investment research or specific investment advice, retirement planning or insurance analysis, or a comprehensive plan covering these and other subjects. A client may also engage a Representative for projects that may require annual or more frequent reviews if more complex long-term planning is needed.
• Prepare an initial written project or comprehensive plan in the scope requested by a client based on the information gathered during the client interview and needs evaluation. This plan may include establishing a clear set of objectives, an outline of resources, a written investment policy statement, an asset allocation model, strategy recommendations, retirement, estate, education, or insurance planning, product recommendations, and steps to take for implementing advice provided.
• Help the client implement the plan, including purchasing and/or selling securities and/or insurance products.
• Review the plan periodically in the scope and frequency agreed upon with the client. The Representative may also, as needed, recommend changes to the client’s investment portfolio or plan, either in writing or verbally. Changes in the client’s financial condition, personal circumstances, goals, or general economic conditions may trigger changes in the plan. To the extent material changes have occurred to a client’s circumstances or goals, or to the extent a client requests a new project, the client will be asked to sign a new services agreement. The client may initiate contact and meet with the client’s Representative as often as needed and the Representative will schedule conferences as needed, usually no less than annually. All planning is based on information provided by the client. It is the client’s responsibility to be certain DWM has current and accurate information for the initial plan, and it is the client’s responsibility to inform the Representative of material changes affecting the investments and planning strategies implemented. ASSET MANAGEMENT SERVICES DWM provides clients with portfolio management and reporting services by means of its Asset Management Services program. Through the program, clients receive investment analysis, allocation recommendations, monthly or quarterly statements reflecting holdings and transactions, quarterly statements, and ongoing account monitoring services for a portfolio which may include stocks, bonds, mutual funds, exchange-traded funds, private placements, and convertible securities. DWM will exercise discretionary trading authority while providing services. This means that DWM Representatives will have authority to purchase and sell securities of their choice in the amounts and at the times they believe it is suitable for a client’s account to do so. DWM may also recommend the use of third-party investment managers to manage all, or a portion of the assets. Such managers will also have limited discretionary trading authority to place orders. The initial asset allocation recommendations are based on the financial information gathered from each client including net worth, risk tolerance, financial goals and objectives, investment restrictions and overall financial conditions. Based on this information, the client is provided with investment recommendations designed to provide an appropriate asset mix consistent with the client’s objectives. The client’s portfolio and its performance are monitored by the client’s Representative in light of the client’s stated goals and objectives. The frequency of these reviews and transactions made for a client’s account are determined by the Representative. DWM Representatives meet with the client on an as-needed basis, or at the request of the client, to discuss the portfolio and other aspects of the service. As a general rule, DWM believes that investing is best suited to those who believe in a long-term buy-and- hold policy. Therefore, clients should not expect frequent investment changes in the portfolio. However, as a

result of monitoring the account, portfolio modifications will be made. DWM does not guarantee the results of its management services, thus losses can occur from receiving services. Although they generally do not exercise discretion to select brokerage firms, DWM Representatives typically recommend the custodial services of Charles Schwab & Co., Inc. (“Schwab”). As of December 31, 2023, DWM has $256,543,000 in total assets under management and provides investment advisory services with respect to $401,865,000 of employee benefit fund assets. INVESTMENT CONSULTING SERVICES DWM also offers Investment Consulting Services. This service may include analysis of client's existing assets, investment objectives, investments, asset allocation recommendations, selection and monitoring of other managers or other investment-related matters. For clients having a large or highly-diversified securities portfolio, DWM prepares written recommendations which assist a client in arriving at an asset mix designed to achieve the client's investment objective. Clients decide which recommendations to accept and implement and which recommendations to reject. This service can also be used by retirement plan sponsors who need advice about preparing their investment policy statement, evaluating plan investments, recommendations about alternative investments and participant education. The scope of all retirement plan services are determined in advance and set forth in the written contract between DWM and the plan's sponsor. Like Asset Management Services, DWM does not guarantee results and losses can occur from receiving Consulting Services RETIREMENT PLAN ADVISORY SERVICES DWM may enter into agreements with employers that provide qualified retirement plans (“Plan”) with various advisory services. DWM typically provides the following services: Investment advice to the Employer at a Plan Level -
• review of the Plan’s Investment Policy Statement annually, including assessing the following: (a) the criteria for selecting money managers and the due diligence procedures that the Plan followed in selecting its money managers and/or mutual funds; (b) the basis for asset mix and rebalancing limits: (c) the performance measurement criteria; (d) monitoring procedures of money managers and other investment-related venders; (e) composition and relevancy of quarterly performance reports; (f) composition of custodial reports; and (g) termination procedures for money managers;
• advise Client about mutual funds and other investment alternatives that are consistent with the investment categories allowable under the Plan;
• meet with representatives of Client, at intervals mutually acceptable to Client and DWM, to discuss the Plan's investment performance and investment selections;
• monitor investments in the Plan’s accounts with account custodians (each, an "Account”) and change investment selections as DWM deems appropriate. Client grants DWM limited discretionary authority and appoints DWM as agent and attorney-in-fact with respect to each Account. Pursuant to such authorization, DWM may, in its sole discretion and at Client’s risk, open brokerage and custodial accounts and accounts with third-party investment managers, purchase, sell, exchange, convert and otherwise trade in the securities and other investments in an Account on such markets, at such prices and at such commission as DWM believes to be in the best interest of the Account. DWM shall also have authority to arrange for delivery and payment in connection with transactions for each Account, and act on behalf of Client and in all other matters necessary or incidental to the handling of the Account. This authorization does not grant DWM permission to take delivery or possession of Client’s funds or securities except for fees due DWM;
• prepare written performance and other reports in the scope and at the times mutually agreed upon between Client and DWM;
• conduct informational/educational group meetings with Plan participants at initial installation of the Plan, and periodically thereafter in the scope and frequency mutually agreed upon between Client and DWM regarding: o general investment concepts; o investment objectives and performance of selected investments; and o investment allocations and strategies available to meet various investment objectives. All advice provided by DWM and its Representatives is based upon the reliability of the information provided to DWM by the Plan and its participants. It is the client’s responsibility to be certain DWM has current and accurate information, and it is the client’s responsibility to inform the Representative of material changes affecting the investments and planning strategies implemented so the Representative has them for future reference. Either the client or DWM may at any time request an audit of the Plan by an independent certified public accountant, the fee for such audit will be paid by the party making the audit request.