Edmonds Duncan provides its services in an effort to improve clients’ overall financial wellbeing. To that end, the Firm will analyze client information to assess their current situation, define their goals and determine what should be done in order to meet those goals. Depending on what services the Firm is engaged to provide, this could entail analyzing client assets, liabilities and cash flow, current insurance coverage, investments, tax strategies and other less tangible concerns. The Firm believes an approach that carefully monitors client portfolios is integral in achieving client objectives. The Firm seeks to select efficient, liquid and low-cost investments while implementing a process that aims to adapt portfolio allocation to an ever-changing economic environment in order to manage portfolio risk. Edmonds Duncan has been in business since June 2013 and is wholly owned by Donald D. Duncan and Jason Stephen Edmonds. As of December 31, 2023, Edmonds Duncan had $440,511,126 in assets under management, $393,799,205 of which were managed on a discretionary basis and $46,711,920 of which were managed on a non-discretionary basis. With our discretionary relationship, we will change the portfolio as appropriate to help meet your financial objectives. We trade Client portfolios based on our Firm’s market views and the Client’s financial goals. With our non-discretionary relationship, we will provide recommendations to help meet your financial objectives, but we must obtain your approval before making any transactions in your account. While this brochure generally describes the business of Edmonds Duncan, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’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 Edmonds Duncan’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services Edmonds Duncan offers clients a range of financial planning and consulting services, which may include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Retirement Planning
• Estate Planning
• Financial Reporting
• Insurance Needs Analysis
• Charitable Giving
• Risk Management While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described below). In performing these services, Edmonds Duncan is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. Edmonds Duncan may recommend the services of itself, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Edmonds Duncan to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Edmonds Duncan under a financial planning or consulting engagement or to engage the services of any such recommended professionals, including Edmonds Duncan itself. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Edmonds Duncan’s previous recommendations and/or services. Retirement Plan Consulting Services Edmonds Duncan provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning and Benefits
• Investment Management and Review
• Plan Fee and Cost Analysis
• Retirement Plan Committee Consultation
• Fiduciary and Compliance
• Legacy Plan Services As disclosed in the Agreement, certain of the foregoing services are provided by Edmonds Duncan as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Edmonds Duncan’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Disclosure Regarding Rollover Recommendations We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We have to act in your best interest

and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. A client or prospect 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) rollover 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). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight. Investment Management and Wealth Management Services Edmonds Duncan manages client investment portfolios on a discretionary basis. In addition, Edmonds Duncan may provide clients with wealth management services which may include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. Edmonds Duncan primarily allocates client assets among index exchange-traded funds (“ETFs”), and may allocate client assets among various mutual funds, individual debt. equity securities and cash in accordance with the investment objectives of its individual clients. All of which are considered asset allocation categories for the client’s investment strategy. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may also engage Edmonds Duncan to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Edmonds Duncan directs or recommends the allocation of client assets among the various investment options available with the product. These assets are maintained at the underwriting insurance company or the custodian designated by the product’s provider. Edmonds Duncan tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. Edmonds Duncan consults with clients on an initial and ongoing basis to determine 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 Edmonds Duncan 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 Edmonds Duncan determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Sponsor / Manager of Wrap Program Edmonds Duncan is the sponsor and manager of the Edmonds Duncan Registered Investment Advisors Wrap Program (the “Program”), a wrap fee program (i.e., an arrangement where brokerage commissions and transaction costs are absorbed by the Firm). The fee covers transaction costs or commissions resulting from the management of your accounts, however, most investments trade without transaction fees today, so our payment of these and other incidental custodial related expenses should not be considered a significant factor in determining the relative value of our wrap program. Participants in the Program may pay a higher aggregate fee than if brokerage services are purchased separately. Additional information about the Program is available in Edmonds Duncan’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV. Legacy Management Services Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients can limit or restrict our trading in these positions.