ACP provides financial planning, investment management services and investment advisory consulting as a fiduciary to private clients as well as retirement plans. Prior to engaging ACP to provide any of the foregoing financial planning or investment advisory services, the client is required to enter into one or more written agreements with ACP setting forth the terms and conditions under which ACP renders its services (collectively the “Agreement”). ACP has been in business since 2011. Aveo Capital Holdings, LLC, owned by Keys Tinney, is the managing member of ACP. ACA Holdings, LLC, owned by Brian Rorick and Michael Beermann and RIA Holdings, LLC, owned by Sean Henderson, are members. Andrew Armstrong is ACP’s Chief Compliance Officer. As of this filing, ACP had $1,513,251,107 in regulatory assets under management, of which $1,324,178,772 was discretionary, and $189,072,335 was non-discretionary. This Disclosure Brochure describes the business of ACP. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of ACP’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on ACP’s behalf and is subject to ACP’s supervision or control. Financial Planning Services ACP may provide formal financial planning services or financial plans to clients for a fee. ACP clients sign a separate financial planning agreement. In addition, some ACP investment adviser representatives provide clients with a broad range of comprehensive services including insurance, tax and estate planning, college education savings and charitable planning, etc., without charging a separate financial planning fee (see our description of Management Fees below). In performing its services, ACP is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, agent, etc.) and is expressly authorized to rely on such information. ACP may recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if ACP recommends its own services or services of an affiliate or related party. The client is under no obligation to act upon any of the recommendations made by ACP under a financial planning engagement or to engage the services of any such recommended professional, including ACP itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of ACP’s recommendations. Clients are advised that it remains their responsibility to promptly notify ACP if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising ACP’s previous recommendations and/or services. If the client chooses to use ACP to provide investment management services, the client will sign a separate discretionary investment advisory agreement.. As part of its client services, ACP IAR’s may elect to enter a non-exclusive relationship to provide insurance products to ACP clients. Such affiliated licensed agents may earn commission on the sale of such insurance products. Investment Management Services Clients can engage ACP to manage all or a portion of their assets on a discretionary or non-discretionary basis. ACP investment adviser representatives (“IAR”) primarily allocate clients’ investment management assets among Affiliated Managers and Unaffiliated Managers (collectively “Managers” as defined below), mutual funds, exchange- traded funds (“ETFs”), individual debt and equity securities, option contracts as well as the securities components of variable annuities in accordance with the investment objectives of the client. In addition, ACP may provide due diligence, ongoing monitoring and/or recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include, without limitation, pooled investment vehicles and hedge funds, private equity and venture capital investments, real estate, or other vehicles (”Private Funds”), when consistent with the clients’ investment objectives. A client’s decision to invest in a Private Fund is done on a non-discretionary basis unless specifically stated in the investment advisory agreement. ACP may also provide advice about other types of investment held in clients' portfolios. Unless agreed otherwise, assets designated as Private Funds may be subject to the investment advisory fee charged by ACP. However, if ACP clients are invested in Private Funds managed by an affiliate or related person of ACP, no ACP advisory fees are charged on such assets. Each ACP investment adviser representative (“IAR”) has discretion to manage his or her clients’ investment management assets using customized portfolio management strategies as well. IAR’s can trade individual stocks and bonds, option or other securities, and manage their own portfolio strategies for clients consistent with each clients’ investment objectives and risk tolerance goals. ACP also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, individual employer-sponsored retirement plans, Private Funds, or other products that may not be held by the client’s primary custodian. In so doing, ACP may direct or recommend the allocation of client assets among the various investment options that are available with the plan or product. Client assets are maintained at

the specific insurance company or custodian designated by the plan or product. ACP tailors its advisory services to the individual needs of clients. ACP consults with clients initially and on an ongoing basis to develop an investment goals and objectives which determines risk tolerance, time horizon and other factors that may impact the clients’ investment needs. ACP ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. In performing its services, ACP is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, agent, etc.) and is expressly authorized to rely on such information. Clients are advised to promptly notify ACP if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon ACP’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in ACP’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. ACP IAR’s may be registered representatives of an unaffiliated broker/dealer through which they may sell registered securities where they may earn a commission. Such commissions are not earned or charged by ACP and are not included in any fees charged by ACP or its Affiliates. Use of Managers As mentioned above, ACP may recommend the discretionary management of a portion of a client’s assets by and/or among certain Affiliated and Independent Managers (“Managers”), based upon the stated investment objectives of the client. The client authorizes ACP to delegate discretionary or non-discretionary management of all or part of their assets to one or more Managers and/or investment management programs, based upon such client’s stated investment objectives. Managers will generally charge a separate investment management fee in addition to ACP’s Management. Clients will generally not be required to execute a separate agreement with the Managers; however, if the Manager requires a separate agreement (including agreements with separately managed account advisers or platforms), the terms and conditions under which the client engages them will be set forth in a separate written agreement between the client and the designated Managers. ACP will generally execute a subadvisory and/or independent management agreement with Managers setting forth the terms of their agreement. When recommending or selecting Managers for a client, ACP reviews information about the Manager such as its disclosure brochure and/or material supplied by the Manager or independent third parties for a description of the Manager’s investment strategies, past performance and risk results to the extent available. Factors that ACP IARs generally consider in recommending a Manager include the client’s stated investment objectives, as well as the Manager’s management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are generally exclusive of, and in addition to, ACP’s investment advisory fee set forth below. As discussed above, the client may incur additional fees than those charged by ACP, the designated Managers, and corresponding custodian. In addition to ACP’s written disclosure brochure, the client may receive the written disclosure brochure of Managers upon request. Certain Managers may impose more restrictive account requirements and varying billing practices than ACP. In such instances, ACP may alter its corresponding account requirements and/or billing practices to accommodate those of the Managers. When Adviser provides investment advice to you regarding your retirement plan account or individual retirement account, Adviser is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Adviser makes money creates some conflicts with your interests, so Adviser operates under a special rule that requires Adviser to act in your best interest and not put our interest ahead of yours. Participant Account Management (Discretionary) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary.