Boulder Wealth Advisors LLC

ITEM 5 - FEES AND COMPENSATION

INVESTMENT MANAGEMENT FEES AND COMPENSATION

Our Firm charges a fee as compensation for providing Investment Management services on your account(s). These services include advisory
services, trade entry, investment supervision, and other account maintenance activities. Our recommended Custodian charges transaction
costs, custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for
details.

                                                             BOULDER WEALTH ADVISORS | JULY 2026 | PAGE 5

A calendar quarterly investment management fee is billed in advance based on the market value of the accounts on the last day of the
previous calendar quarter. The investment management fee will cover the period from the first day of the calendar quarter through the last
day of the calendar quarter. Our maximum annual advisory fee is 1.00%. The relevant fee and billing method is defined and agreed to by the
firm and the client in the executed Investment Advisory Agreement.This fee will be debited directly from your investment account. Fees are
assessed on all assets under management, including securities, cash, and money market balances. All of which are considered asset allocation
categories for the client’s investment strategy. We may exclude some assets from billing that are agreed upon by Boulder Wealth Advisors and
the client.The management fee is based on the size of the account at inception and is reviewed quarterly and reset if the accounts qualify for a
lower or higher fee.

In addition, some mutual fund assets transferred into the account may have been subject to deferred sales charges and 12(b)(1) fees and other
mutual fund annual expenses as described in the fund’s prospectus. Furthermore, some existing variable annuities may be subject to trailing
service fees, deferred sales charges, and mortality and expense fees. These fees are independent of our fees and should be disclosed by the
custodian or contained in each fund’s prospectus. You should also note that fees for comparable services vary and lower fees for comparable
services may be available from other sources.

Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account, or other reasons agreed upon by
our Firm and you as the client. In certain circumstances, our fees and the timing of the fee payments may be negotiated. Our employees and
their family related accounts are charged a reduced fee for our services.

Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of determining the account size and
annualized fee. The common practice is often referred to as “house-holding” portfolios for fee purposes and may result in lower fees than if fees
were calculated on portfolios separately. Our method of house-holding accounts for fee purposes looks at the overall family dynamic and
relationship. When applicable, and noted in Appendix of the Investment Management Agreement, legacy positions will also be excluded from
the fee calculation.

The independent and qualified custodian holding your funds and securities will debit your account directly for the advisory fee and pay that
fee to us. When establishing a relationship with Boulder Wealth Advisors, you provide written authorization permitting the fees to be paid
directly from your account held by the qualified custodian. Further, the qualified Custodian agrees to deliver an account statement to you on a
monthly basis indicating all the amounts deducted from the account including our advisory fees.

Either Boulder Wealth Advisors or you may terminate the management agreement, upon written notice to the other party. The management
fee will be pro-rated to the date of termination, for the quarter in which the cancellation notice was given, and any unearned fees will be
refunded to you. Upon termination, you are responsible for monitoring the securities in your account, and we will have no further obligation to
act or advise with respect to those assets.

In the event of client’s death or disability, Boulder Wealth Advisors will continue management of the account until we are notified of client’s
death or disability and given alternative instructions by an authorized party.

In no case are our fees based on, or related to, the performance of your funds or investments.

THIRD PARTY MONEY MANAGERS FEES (“TPMM”)

Clients pay Boulder Wealth Advisors an advisory fee that is typically charged as a percentage of assets under management, calculated and
billed in advance based on the market value of the accounts on the last day of the previous calendar quarter. The specific fee and billing
method for each client are stated in the advisory agreement.

When we allocate to AQR Flex or engage SpiderRock’s option overlay, clients also pay the applicable program or manager fee charged by that
provider. These third-party fees are separate from and in addition to our advisory fee and are deducted from client accounts pursuant to the
third-party agreement. Clients also bear applicable transaction costs, exchange and regulatory fees, custodial fees, and any expenses
associated with short sales, stock borrow, margin financing, and options transactions. For example, AQR Flex employs long and short equity
positions in a tax-aware framework, which can involve financing and borrow costs and may require margin; SpiderRock’s overlays involve
buying and selling listed options, which carry exchange fees, the possibility of early assignment, and collateral or cash-management
requirements. Provider fee schedules and other terms are available from AQR and SpiderRock upon request.
Clients could obtain similar services directly from these or other providers, possibly at lower or higher cost, and may choose to instruct us not
to use third-party managers or overlays. We do not accept performance-based compensation.
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ITEM 7 - TYPES OF CLIENTS
Boulder Wealth Advisors offers personalized, confidential financial planning and investment management to individuals, families, pension and
profit-sharing plans, trusts, estates, and charitable organizations.
                                                             BOULDER WEALTH ADVISORS | JULY 2026 | PAGE 7

Our firm requires a minimum account balance of $1,000,000 for our Investment Management services. In certain instances, at the discretion of
our Firm, our minimum requirements may be waived.

ITEM 8 - INVESTMENT STRATEGIES AND RISK OF LOSS
The basic tenets under which this Policy will be managed include the following:

INVESTMENT STRATEGIES & METHODS OF ANALYSIS

We invest our client accounts in one of our five basic portfolio models: Ultra Aggressive, Aggressive, Growth, Growth & Income, and Bond only.
Clients may have different models for different accounts. With some exceptions, our client assets are invested into one of these portfolio
models. All of our portfolios consist of a diversified mix of stock and bond funds.The stock portion may include asset classes such as: large and
small capitalization companies, value, and growth-oriented companies, developed and emerging market companies, and other market
sectors. In addition, the bond portion of our portfolios may contain a variety of bonds such as: U.S. government, municipals, corporate, foreign
corporate, emerging markets, sovereign, and high yield bonds. Our model portfolios may vary in stock and bond mix, depending on market
conditions. The Ultra-Aggressive Portfolio will contain the highest amount of stocks and the Growth and Income Portfolio will contain the least
amount of stocks.The Bond Only portfolio will contain bond funds, including but not limited to: U.S. government, municipals, corporate, foreign
corporate, emerging markets, sovereign, and high yield bonds. At times this portfolio may contain money market funds, cash or cash like
instruments. If we are utilizing a third party separately managed account provider, they may own individual bonds at their discretion.

On occasion, we will employ charting techniques.We rely on many sources of information, including financial newsletters and magazines,
subscription services, research material prepared by others, annual reports and prospectuses, and company releases. Our allocation analysis
could be described as top-down. This analysis begins with looking at economic indicators, both national and international, such as; GDP
growth rates, inflation, interest rates, exchange rates, productivity, and energy prices. We then narrow our focus to market sectors or industries
that we believe will perform well in the given economic environment. We then employ proprietary metrics to select mutual funds that we
determine should outperform their benchmarks. This process includes examining the funds price to earnings ratios, price to book, turnover
rates, management tenure, bond duration, and other metrics.

We purchase securities with the intent to hold them for the long term. Occasionally, we purchase securities for a shorter time period,
depending on market conditions. We exercise the right to buy and sell options, perform margin transactions, and do frequent trading;
however, we have rarely performed any of these transactions since we have been in business.

Client’s assets are held at Charles Schwab & Co.They have trading minimums that require us to treat accounts valued at less than $10,000
differently than larger account sizes. These smaller accounts will be allocated to our model portfolio percentages in stock and bond funds and
may contain different mutual funds than larger accounts, due to certain fund’s minimum initial purchase constraints.

We assess our clients’ risk-return level to determine which portfolio model best fits their objectives. We do not build tailored models for
individual clients.However, if they have an existing position that they transfer in or if the client requests to buy a specific security, we will hold
that in addition to our model portfolio holdings. These exceptions are documented in our Investment Policy Statement. Special situations may
require that the client hold additional cash in their account.A description of our four portfolio models are as follows:

   ULTRA AGGRESSIVE – Typically 97% or more in equities, primarily investing in mutual funds, Exchange Traded Funds (ETFS). Individual
   stocks may be used as well. The portfolio has a range of 70% to 100% of the portfolio invested in equities. The range of equity exposure
   depends on market conditions. The primary objective of this portfolio is to maximize growth and capital appreciation, with no emphasis on
   income generation. Designed for investors with a high-risk tolerance and a long-term investment horizon, this portfolio carries the highest
   level of risk and includes significant allocations to volatile asset classes such as stocks. To mitigate risk, Boulder Wealth Advisors may
   incorporate bonds, cash, alternative investments, trend-following strategies, or real asset strategies, utilizing ETFs and mutual funds.

   AGGRESSIVE – Typically 80% stock funds, primarily investing in mutual funds and Exchange Traded Funds (ETFs), with a range of 45% to
   90% invested in stocks depending on market conditions. The goal of this portfolio is to maximize growth and capital appreciation. There is
   no focus on generating income. This portfolio has the highest risk level and is for investors with a long-time horizon. This portfolio has a
   large allocation to volatile asset classes, such as stocks, and has some defensive asset classes such as bonds and cash.

   ·GROWTH – Typically 65% stock funds, primarily investing in mutual funds and Exchange Traded Funds (ETFs) with a range of 35% to 80%
   invested in stocks depending on market conditions. The goal of this portfolio is to maximize long-term growth and capital appreciation,
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