GENERAL INFORMATION Copper Financial (also referred to as “we” or “us”) is a broker-dealer registered with the SEC and a member of FINRA and a federally registered investment adviser. We offer financial planning and investment advisory services to you through our registered Investment Advisor Representatives ("Advisor"). Copper Financial is a Missouri limited liability company and is a wholly owned subsidiary of CommunityAmerica CUSO One, LLC (“CUSO One”). CUSO One is wholly owned by CommunityAmerica Credit Union (“CommunityAmerica”), a privately held organization. Our Advisors primarily work with members of credit unions. This includes members of CommunityAmerica, our parent company, as well as members of credit unions with which we have entered into a bank networking agreement to provide investment services to their members (“Program Credit Union”). See Item10 for additional information. The following advisory services are discussed in this Brochure: Financial Planning and our Third-Party Manager Accounts (“TPMA”) program, which involves Copper Financial referring clients to approved third- party managers. In addition to the advisory services discussed in this Firm Brochure, Copper Financial offers additional advisory programs. We offer the Asset Allocation Managed Portfolio (“AAMP”) program, a wrap fee program whereby our Advisors make recommendations of model portfolios designed by third-party managers and managed by us. We also offer an online-only digital investing wrap fee program, Guided Investing. Through our Guided Investing program we make recommendations of model portfolios solely through an online platform and without the assistance of an Advisor. You can obtain information related to our wrap fee programs and other advisory services not discussed in this Brochure in the Advisory Brochures section of Copper Financial’s website at https://cu.financial/disclosures/ or by asking your Advisor. As of December 31, 2023, we have regulatory assets under management in the amount of $306,448,486 which we manage on a discretionary basis. We currently do not manage any client assets on a non- discretionary basis. Additionally, we have $249,875,853 in assets under administration. While we provide administrative services regarding these assets under administration, we are not currently providing continuous investment management services to these assets as this is done by the manager. Accordingly, we have total platform assets of $556,324,339. WORKING WITH YOUR ADVISOR Your Advisor can offer both investment advisory services and products and brokerage services and products. There are important considerations when selecting the services and products best suited to your investment needs and goals, including, but not limited to your unique financial situation, investment objective, risk tolerance and investment time frame. Advisory Relationship – As a federally registered investment adviser, we and our Advisors are fiduciaries to you. This means that we and your Advisor must act solely in your best interest when offering you investment advisory services and products. Generally, fees we charge for investment advisory services and products are either hourly or asset based as described in this Brochure. Brokerage Relationship – As a broker-dealer, we and our financial professionals must ensure that the brokerage products and services we recommend are in your best interest based on your stated investment objective, risk tolerance, tax status and other personal financial information you provide. Generally, you will pay commissions to purchase and sell brokerage products. See the Regulation Best Interest Disclosure at https://cu.financial/disclosures/ for additional information on fees charged on brokerage accounts. For brokerage accounts held at our clearing firm, Apex Clearing, you will also be subject to account maintenance and servicing fees as outlined in the Brokerage Fee Schedule maintained at https://cu.financial/disclosures/. Factors to Consider When Deciding Between Investment Advisory and Brokerage Relationship: Advisory Relationship
• Seek ongoing advice and monitoring on your account.
• Prefer to pay ongoing fees based on assets under management rather than based on the number of transactions.
• Seek a fiduciary relationship with an Advisor who must act in your best interest.
• Periodic portfolio rebalancing. Brokerage Relationship
• Seek advice only on individual transactions with no ongoing monitoring of your investments.
• Prefer commission-based compensation paid on a per transaction basis.
• Seek a relationship with a financial professional who must make recommendations in your best interest. FINANCIAL PLANNING SERVICES We, through our Advisors, offer financial plans and investment advice consistent with your financial status, investment objective, risk tolerance, investment time frame and tax status. We have contracted with various unaffiliated third-party vendors to offer financial planning software that allows you, in collaboration with your Advisor, to create a comprehensive view of your financial accounts, assets, liabilities, income, and expenses. The software uses assumptions and calculations to determine the likely success of your goals based on your current situation or suggested modifications. The suggested success or failure of a financial goal is not a guarantee of any future event or balance of an account, security, or asset. Neither we nor your Advisor provide any implicit or explicit guarantee of a future value of a security, account, asset, or holding. Together, you and your Advisor will work through some or all of the financial planning process elements described below to develop a financial plan specific to your needs and goals:
• Initial Engagement: Discuss your specific financial and personal goals and concerns
• Gather Data: Discuss your current financial situation in more detail. This will entail the collection from you of various documents such as bank and brokerage account statements, tax returns, estate planning documents and insurance policies. We will rely on you to provide accurate and complete information.
• Analyze Data: We will evaluate and analyze your current financial needs and goals based on the data and documents you provide, and we will use this analysis to develop a set of recommendations intended to lead to assist you in attaining your financial and personal goals.
• Recommendations: We will deliver a written financial plan that will provide recommendations based on our analysis of the data and documents you provide to us. Your financial plan will address one or more of the following goals:
• Retirement: Analyze projected retirement income and expenses based on defined retirement goals you provide. The analysis may suggest potential retirement shortfalls or surpluses which we will address with strategies to meet your retirement capital and income needs.
• Education Funding: Analyze educational planning goals for specific periods. This analysis may outline potential gaps in your current education funding and provide strategies to eliminate the gaps.
• Goal Funding: Analyze your specific personal goals and provide strategies to fund those goals.
• Survivor Income Needs: Analyze the potential financial impact of an untimely death of a spouse based on defined financial goals. This analysis will provide strategies to help meet survivor income goals.
• Disability Income: Analyze the potential impact of an unplanned disability on financial needs. This analysis will provide strategies to help meet necessary income requirements.
• Long-Term Care: Analyze the potential impact of long-term care expenses on your overall financial goals. This analysis will provide risk strategies for ensuring sufficient benefits to cover long-term care financial obligations.
• Estate Planning: Analyze your current estate and the benefits of implementing various estate planning techniques and strategies such as wills, revocable trusts, irrevocable trusts, and gifting programs.
• Asset Allocation: Analyze basic asset allocation strategies for specific

financial goals based on individual time horizons, investment objectives, and risk tolerance levels
• Business Planning: Analyze the issues related to business planning and the potential impacts it may have on business and personal financial goals.
• Income Tax Planning: Analyze the estimated impact taxes may have on your income, assets, and financial goal, including the tax implications of various investment products and strategies. The consolidated view and reporting available in the financial planning software is provided for informational purposes only and as a courtesy to you. These reports may include assets disclosed to us by you that we do not service or are not held on our books and records. Copper Financial believes the consolidated view and reports provided to be reliable; however, the accuracy and completeness of the information is not guaranteed and has not been verified by us. We are not responsible for any inaccurate reporting of assets we do not custody. You should compare the financial planning software reports and the information reflected on the reports to the official account statements provided by the custodians of your account to ensure that the information listed on these reports match the securities, insurance, cash, bank deposit and other holdings reflected on the official account statements provided by the custodians of your assets. If there are any discrepancies between the information in the reports we provide and the official account statements, the official account statements will prevail. The reports created through our financial planning software are not a replacement for the official account statement issued by the custodian of your account. We and our Advisors do not offer legal, tax or accounting advice when preparing the personal financial plan, business planning, or providing investment recommendations. None of the fees for services under this program relate to legal, tax or accounting services. If you need legal, tax or accounting services, it shall be your responsibility to obtain them from independent qualified professionals. We have a conflict of interest when recommending our financial planning services as there is an incentive for us to recommend products or services for which we or your Advisor may receive compensation. However, you are under no obligation to act upon any financial planning recommendations or to implement any financial planning recommendations through us or your Advisor. THIRD PARTY MANAGED ACCOUNTS (TPMA) Our TPMA program provides access to various unaffiliated third-party managers (“Manager” or “Managers”). We decide which Managers to include in TPMA (“approved Managers”) and whether to remove and replace a manager based on several factors, including client needs, investment styles available in the marketplace, platform capacity, client demand and composite performance. Copper Financial will add or remove approved Managers at our sole discretion. As part of its ongoing Manager due diligence process, Copper Financial will, among other things, ensure that every Manager is properly licensed and registered as an investment adviser. NOTE: Our due diligence review of Managers does not substitute for your ongoing monitoring of your TPMA account(s) and performance. We will act as a promoter for the Managers we include in TPMA. When acting as a promoter for the Managers we introduce clients to the Manager and recommend the client obtain advisory services from the Manager. Each promoter arrangement with Managers will be conducted pursuant to a written agreement between us and the Manager that is consistent with SEC Rule 206(4)-1. Your Advisor will refer Managers from our list of approved Managers that they believe best meet your stated investment objectives, goals, investment time frame, and risk tolerance. If the assets in your TPMA account(s) constitute only a portion of your total assets, we will not be responsible for the proper diversification of those other assets. You grant the Manager(s) you select discretionary authority to manage the individual securities in your TPMA account(s) (“Funds and securities”). As such, all buy and sell decisions will be made by the Manager without consulting you in advance. The Manager also has authority to select broker-dealers or other qualified custodians to custody your account and to execute transactions. Managers may use our Clearing Firms (as discussed in Item 15 below) to custody the funds and securities in your TPMA account(s) and execute transactions for your account(s) or may choose another broker-dealer or qualified custodian in their sole discretion. You should contact the Manager(s) you select to determine what types of investment restrictions you may impose on your TPMA account. Please consult each Manager's ADV Part 2A brochure for more information about their investment strategies/styles, fees, trading costs, best execution, investment risks, disciplinary information, error correction, trade aggregation and bunching, step out trading practices, program, and account costs, etc. The Manager will provide their brochure at the time of, or prior to, TPMA account opening, which should be in a similar format to this Copper Financial Brochure. List of Managers The following is a list of approved Managers currently available through TPMA:
• Brinker Capital Investments, Inc.
• Asset Mark, Inc.
• Morningstar Investment Services, Inc.
• United Asset Strategies, Inc.
• SEI Investment Management Corporation (existing accounts only) Below is a list of important features of TPMA that you should consider before selecting a Manager:
• You will receive a disclosure from your Advisor or the Manager for each Manager. The disclosure provides certain information about the Manager and the fees we will receive from the Manager for your referral;
• You will receive a brochure similar to this Brochure from your Manager(s) at the time or prior to the time you establish a TPMA account with the Manager(s);
• You will enter into a client agreement with the Manager(s) you select which, among other things, grants discretionary authority to the Manager to execute securities transactions without consulting you in advance and describes the Manager's fees and costs;
• Your Manager(s) will select one or more broker-dealers to custody your assets and execute your securities transactions;
• Your Manager(s) will charge a fee for their services which will be deducted from your TPMA account
• Your Manager(s) is responsible for selecting investment styles and individual securities;
• You must contact your Manager(s) to ascertain what types of restrictions you may request for your account;
• We will, upon request from your Manager(s), provide certain information about you to your Manager(s); and
• Your Advisor will answer general questions about your Manager(s). You will have a contractual relationship with your Manager(s) and should contact your Manager(s) directly to:
• Discuss your account(s) and investment performance;
• Review your Manager's investment philosophy and investment style to determine the ongoing compatibility of your Manager(s) to your investment objectives, financial goals, tax considerations and risk tolerance;
• Request information regarding conflicts of interest between you and your Manager(s);
• Discuss questions about your Manager’s Form ADV and Brochure;
• Discuss any reasonable restrictions you may decide to place on your account;
• Discuss your Manager’s fees and costs;
• Discuss your Manager’s proxy voting policies; and
• Discuss the nature and frequency of reports your Manager will provide to you. You assume responsibility for monitoring your Manager's investment practices and performance. We will not:
• Make any representation concerning your manager's qualifications or investment acumen;
• Bear responsibility for the services rendered, information provided by, or for any recommendations made by your Manager(s);
• Endorse, recommend, or otherwise suggest that your Manager(s) will make suitable investment decisions; or
• Undertake to investigate or monitor the appropriateness of your Manager's investment style, investment decisions, best execution, or selection of broker-dealers. NOTE: The ultimate decision to participate in TPMA and the selection of your Manager(s) is your responsibility.