ABOUT OUR FIRM This Disclosure document is being offered to you by Denver PWM, LLC (“Denver PWM, “us,” “we,” “our firm”) in connection with the investment advisory services we provide. Denver PWM, LLC does business as:
• Denver Private Wealth Management
• Harmony Private Client Advisers
• Flourish Financial Partners This disclosure document discloses information about the services that we provide and the manner in which those services are made available to you, the client. We provide advisory services through Advisory teams, each with their own advisory focus and strategies driven by the types of clients they have. We are an investment management firm located in Colorado. Our main headquarters is located at 2000 South Colorado Boulevard Tower One, Suite 3700 Denver, Colorado 80222. We specialize in investment advisory services for high-net-worth individuals, families, trusts, estates, institutions (including ERISA and other retirement accounts) and profit-sharing plans. The Firm was established by Robert Spicer in March 2014. In January 2019, Darin Snow and Mark Levine became the owners of Denver PWM. Darin Snow is the Managing Partner and Mark Levine is an Investment Advisor Representative and no longer an owner as of January 2023. Matthew Lengel became an owner in 2023 and also serves as Chief Compliance Officer of the Firm. We are committed to helping clients build, manage, and preserve their wealth, and to providing assistance that helps clients to achieve their stated financial goals. We may offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and Denver PWM execute an engagement letter or client agreement. INVESTMENT MANAGEMENT AND SUPERVISION SERVICES We offer discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. These services include investment analysis, allocation of investments, quarterly portfolio statements, financial commentaries, financial plans, and ongoing monitoring of client portfolios. We determine your portfolio composition based on your needs, your portfolio restrictions, if any, your financial goals and your risk tolerances. We will work with you to obtain necessary information regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This information enables us to determine the portfolio best suited for your investment objective and needs. In performing our services, we shall not be required to verify any information received from you or from other professionals. If you request, we may recommend and/or engage the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. Once we have determined the types of investments to be included in your portfolio and allocated 6 them, we will provide ongoing portfolio review and management services. This approach requires us to review your portfolio at least quarterly. We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives. We will trade these portfolios and rebalance them on a discretionary basis based on our market views and on your objectives, using our investment process. Our advisory services are tailored to meet your individual needs. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. However, when using mutual funds or Exchange Traded Funds (“ETFs”), this multi-fund manager approach makes it difficult for us to ensure that your portfolio will not invest in a particular industry or security. However, we are happy to discuss your preferences regarding socially conscious or other investment concerns and, we will try wherever possible, to accommodate them. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate authorization from you. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect an account’s performance. This could result in capital losses in your account. EMPLOYER SPONSORED RETIREMENT PLAN SERVICES Employer Sponsored Retirement Plan Advisory Services consist of helping employer plan sponsors establish, monitor and review their company’s retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment selection and monitoring, plan structure, and participant education. Pursuant to Section 402(c)(3) of ERISA, the client may appoint us as the Plan’s “investment manager” with respect to the Plan’s portfolio of investment options. We acknowledge that we are registered as an investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”) and act as a “fiduciary” within the meaning of Section 3(21) and 3(38) of ERISA with respect to the Plan. As a result of the 3(38) appointment, we are granted full trading authority over the Plan and have the sole responsibility for the selection and monitoring of all investment options offered under the Plan in accordance with the investment policy statement and its underlying investment objectives and strategies for the Plan. As a result of the 3(21) appointment, plan sponsors are responsible for making the fund changes within the account. Plan participants have the ability to exercise control over the assets in their account, and we have no authority or discretion to direct the investment of assets of any participant’s account under the Plan, unless a separate Investment Advisory Agreement is executed between the Participant and Denver PWM providing discretionary authority over the account. We offer management of 401(k), 457, and 403(b) accounts both on a plan level and on the individual participant level. PLAN LEVEL We will establish the Plan’s needs and objectives through an initial meeting to collect data, review Plan information, and assist in developing or updating the Plan’s provisions. Ongoing services may include recommendations regarding the selection and review of unaffiliated mutual funds that, in our judgment, DBA DENVER PRIVATE WEALTH MANAGEMENT 7 are suitable for Plan assets to be invested. We periodically review the investment options selected and make recommendations to keep or replace Plans investment options as appropriate. We perform a comprehensive review of Investment options and will assist with converting from incumbent service providers to a new service provider if appropriate. We will provide quarterly recommendations for the Plan’s investment allocation. Upon receipt we will review the investment options and provide positions for accounts in accordance with the management style chosen by the client. Plan Sponsors are responsible for making the fund changes within the account. PARTICIPANT LEVEL We can also be engaged to provide financial education to Plan participants. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA. Participant education will relate to general principles for investing and information about the investment options currently in the Plan.

We may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for new participants. PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY) Financial Planning services may be offered on a comprehensive or a la carte (limited focus) basis. Financial plans may encompass all or some of the following areas of financial concern to the client: 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. FINANCIAL PLANNING Financial Planning services may be offered on a comprehensive or a la carte (limited focus) basis. Financial plans may encompass all or some of the following areas of financial concern to the client:
• Estate Planning Goals
• Retirement Planning
• Education Planning
• Insurance Planning/Risk Management
• Investments 8
• Asset Allocation Review and Recommendations
• Cash management and certain treasury services Information is obtained through personal interviews (including discussion of current financial status, future goals and attitude towards risk), and the review of related documents and data supplied by the client. A written financial plan may be prepared and provided. The implementation of financial plan recommendations is entirely at the discretion of the client. Financial plans are not limited in any way to products or services provided by any particular company. However, in general, only products and services that Denver PWM is able to provide will be offered. CONSULTING SERVICES We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we may provide advice on non-securities matters in connection with the rendering of estate planning, insurance, real estate, and/or annuity advice. In these cases, you may be required to select your own investment managers, Custodian and/or insurance companies for the implementation of consulting recommendations. If your needs include brokerage and/or other financial services, we may recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals (“Firms”). You must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm you choose. You are under no obligation to follow the consulting advice that we provide. 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 - DBA DENVER PRIVATE WEALTH MANAGEMENT 9 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. ADVISORY TEAM FOCUS DBA We offer our advisory services through our network of investment advisor representatives (“Advisor Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Client should understand that the businesses are legal entities of the IAR and not of our Firm. The IARs are under the supervision of our Firm, Denver PWM and the advisory services of the IAR are provided through our Firm. EACH OF OUR TEAMS HAS ITS OWN FOCUS DESCRIBED IN THE CHART BELOW ADVISORY TEAM NAME IARS ADVISOR’S AREA OF TEAM FOCUS INVESTMENT CONSULTING/ WEALTH MANAGEMENT DISCRETIONARY ADVISORY SERVICES FINANCIAL PLANNING RETIREMENT PLANNING Denver Private Wealth Management Darin Snow, Drew Kelleher Harold Classick, Brian Rettig Matthew Lengel Customized Wealth Management YES YES YES YES Harmony Private Client Advisers Scott Sanford, Roger Pierce Sherri Gilligan Customized Wealth Management YES YES YES YES Flourish Financial Partners Craig Austad Customized Wealth Management YES YES YES YES WRAP FEE PROGRAMS We do not offer a Wrap Fee Program. ASSETS As of December 31, 2023, we managed a total of $585,750,770 in regulatory assets under management. Discretionary assets under management totaled $582,955,185 and non-discretionary assets totaled $2,795,585.