DIVERSIFIED PORTFOLIOS INC

PART 2 OF FORM ADV – BROCHURE 39520 Woodward Avenue, Suite 200 Bloomfield Hills, Michigan 48304 (248) 644-3030 www.divport.com March 20, 2025 This Brochure provides you information about the qualifications and business practices of Diversified Portfolios, Inc. (“our,” or “us,” or “we”). If you have any questions about the contents of this Brochure, please contact us at (248) 644-3030. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. We are a registered investment adviser. Registration of an adviser does not imply any level of skill or training. Additional information about Diversified Portfolios, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. i Diversified Portfolios, Inc.  ITEM 2: MATERIAL CHANGES Pursuant to the amended SEC Rules, we will provide you with a summary of material changes detailing any material changes that we make to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We will further provide other ongoing disclosure information about material changes, as necessary. Our current Brochure and supplements may be obtained, free of charge, by contacting J. Brad Cox, Chief Compliance Officer, at 248-644-3030 or bcox@divport.com. Additional information about us is also available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered, or are required to be registered, as one of our investment adviser representatives of our firm. ii Diversified Portfolios, Inc.  ITEM 3: TABLE OF CONTENTS COVER PAGE................................................................................................................................. i ITEM 2: MATERIAL CHANGES ................................................................................................ ii ITEM 3: TABLE OF CONTENTS ................................................................................................ 1 ITEM 4: ADVISORY BUSINESS ................................................................................................ 2 ITEM 5: FEES AND COMPENSATION ...................................................................................... 4 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............... 7 ITEM 7: TYPES OF CLIENTS ..................................................................................................... 7 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .............................................................................................................................. 7 ITEM 9: DISCIPLINARY INFORMATION .............................................................................. 12 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................ 12 ITEM 11: CODE OF ETHICS ..................................................................................................... 12 ITEM 12: BROKERAGE PRACTICES ...................................................................................... 13 ITEM 13: REVIEW OF ACCOUNTS ......................................................................................... 17 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ....................................... 17 ITEM 15: CUSTODY .................................................................................................................. 18 ITEM 16: INVESTMENT DISCRETION ................................................................................... 19 ITEM 17: VOTING CLIENT SECURITIES ............................................................................... 19 ITEM 18: FINANCIAL INFORMATION .................................................................................. 19 EXHIBIT........................................................................................................................................20 Part 2 of Form ADV 1 Diversified Portfolios, Inc.  ITEM 4: ADVISORY BUSINESS Our Owners and Principals We are a Michigan corporation formed in 1993. We are required to disclose the persons owning twenty-five percent (25%) or more of our firm’s common stock. Ronald Yolles and Thomas Post, each a Partner of our firm owning more than twenty-five percent (25%) of our firm’s common stock. Our Advisory Services Investment Management We offer personalized discretionary investment management services to you based on your investment goals, financial objectives, and risk tolerance. We will rely upon the information you provide, however; we will not independently verify your information. If you engage us to provide you with investment management services, we will work with you to establish an investment planning summary, as part of our financial planning process, that is reasonable and documents your investment objectives and expectations. We use this information to build a portfolio of investments for you based on the principles of broad diversification and a long-term allocation of assets among equities, fixed income, and cash, consistent with your investment planning summary. We choose specific investments within your portfolio keeping minimization of transaction costs as a key goal. Once the portfolio is established, we monitor and reconcile your account held at your custodian on a regular basis. If your financial needs, circumstances, or objectives change or if any changes to the investment planning summary is necessary, please let us know promptly, in writing. We act under the fiduciary duty of care and loyalty applicable to a registered investment adviser. Our duty of care means we provide investment advice, based on the client’s objectives, in the best interest of our client. Under the duty of loyalty, we must eliminate or make full and fair disclosure of our conflicts of interests which might incline us — consciously or unconsciously — to render advice which is not disinterested. We perform our investment management service for you pursuant to the terms and conditions we establish in our written investment advisory agreement that we both sign at the beginning of our relationship. As described in further detail below in the “ITEM 16: INVESTMENT DISCRETION” section beginning on page 19, we manage your accounts on a discretionary basis, which means that we determine the securities to buy and sell for your account without obtaining your specific consent prior to each transaction. However, you may place reasonable restrictions on our discretionary authority or place limitations on the types of investments for your account in writing. If we manage a joint account on your behalf (e.g., husband and wife, parent and child, etc.), our services will be based upon the identified financial needs and objectives that all or any one of the persons executing our agreement (collectively, the “Joint Clients”) communicate to Part 2 of Form ADV 2 Diversified Portfolios, Inc.  our Wealth Advisor. Joint Clients are collectively responsible for determining and advising us if only one or more of the Joint Clients is permitted to give us instructions, authorizations, or to otherwise control the account. Unless we are directed otherwise in writing, we are permitted to rely upon any authorization, instruction, or direction from any one of the Joint Clients until this authority is limited or revoked in a written notice delivered to us signed by all Joint Clients. Additional Services If clients request, we may provide additional discretionary investment advice for certain outside accounts these are primarily retirement accounts, for an additional fee see “ITEM 5: FEES AND COMPENSATION” for the specific fees for this service). We regularly review the available investment options in these accounts, monitor them, and rebalance in the same way we do other accounts, though using different tools, as necessary. We use a third party platform to facilitate the management of these “held-away accounts.” Clients using this service are provided with their own log-in credentials by the platform and will link their account to the platform. By linking the accounts on the platform, we are allowed to view the account allocation, and when deemed necessary by us, rebalance the outside accounts. We do not have access to clients’ credentials and therefore, do not have custody of the assets held in these accounts. We are not affiliated with the third-party platform in any way, and do not receive any compensation from the platform. If you would like us to provide this additional service, you will sign an addendum to your current agreement or, for new clients, a separate schedule of our investment advisory agreement which explains this service. Recommendation of Other Professionals In addition, when requested and in conjunction with our investment management services, we will advise you on issues related to wealth management. To implement our advice, we may recommend that you work with other professionals, such as attorneys or accountants, or utilize various financial products, such as insurance. If our services to you include the recommendation of other professionals, you will typically sign an agreement with them in addition to the advisory agreement you sign with us. You are under no obligation to act upon any of our recommendations. We do not receive any compensation from the professionals or from any financial products we recommend to you. Investment Management for Qualified Plans As part of our services to qualified ERISA plans, we may act as a fiduciary as defined in Sections 3(21)(A) and 3(38) of ERISA. If you engage us as a 3(21) advisor, we will make recommendations, but it is ultimately up to you, as the plan fiduciary, to decide whether and how to act. As a 3(21) advisor, we will not have discretion to invest and reinvest your assets without your prior consent. Thus, as a 3(21) advisor, we will share responsibility for the selection of Part 2 of Form ADV 3 Diversified Portfolios, Inc.  investments. If we act as a 3(38) investment manager, the plan fiduciary gives us discretionary authority to manage the plan’s assets. This means that the plan fiduciary shifts its fiduciary responsibility to us for the selection of the plan’s investments. For qualified plan clients, we assist you with creating and maintaining your investment planning summary, upon request. Your investment planning summary or other written investment objectives may place restrictions on the types of investments the plan assets may invest in. We adjust the asset allocation to ensure that the investment mix reflects the objectives of the chosen strategy. We continually monitor the performance of all investment options. Assets Under Management As of December 31, 2024, we had $1,660,883,638 in client assets managed on a discretionary basis. ITEM 5: FEES AND COMPENSATION Investment Management Fee Schedule Our standard fee schedule for all investment management services is as follows: Market Value of Assets Annual Fee For the first $2,000,000 0.90% For the next $4,000,000 0.65% For the next $9,000,000 0.45% Any amount over $15,000,000 0.25% We establish with you the specific manner in which we charge our fees in the written investment advisory agreement signed with us prior to beginning our relationship. Fees for the Additional Services provided to held-away accounts will be calculated using the same above fee schedule. Additional Information Unless otherwise stated in the written investment advisory agreement, we bill our fees in arrears on a quarterly basis based on the market value of your assets under our management, including cash and cash equivalents, on the last business day of the preceding quarter. Generally, the assets in client accounts are valued in our reporting system using prices obtained from their custodian including the value of any held-away assets managed through the third party platform. We prorate our fee for accounts initiated or terminated during a calendar quarter, in the event that our engagement does not begin or end at the end of a calendar quarter. We also prorate our management fees for each capital contribution and withdrawal greater than $30,000 made Part 2 of Form ADV 4 Diversified Portfolios, Inc.  during the applicable calendar quarter. Each quarterly report contains a detailed description of how the fee is calculated. Please note that the values utilized to calculate fees may differ from those reported by the account custodian as further described in “ITEM 15: CUSTODY” beginning on page 18. At our sole discretion, fees may be negotiated. In certain circumstances, fees may be negotiated based upon considerations such as complexity of the client’s situation, amount of assets to be placed under our management, anticipated future additional assets, other related accounts, historical relationship, among other factors. Negotiated fees may be higher or lower than those described in this Brochure. In these circumstances, our negotiated fee schedule will be set forth in your investment advisory agreement. We provide employees and immediate family members the same services at no charge or for a fee lower than those charged to clients that are not related to the firm. These fees are not available to our general clients. As set forth in the “ITEM 7: TYPES OF CLIENTS” section beginning on page 7, we generally require you to have a minimum of $1,000,000 in assets to open an account for investment advisory services. Additional Fees and Expenses Our fee does not include brokerage commissions, transaction fees, and other related costs and expenses incurred in connection with providing investment advisory services to you. When we select mutual funds and exchange traded funds (“ETFs”) for client accounts, the client is subject to various fees and charges, including, but not limited to, the annual fund operating expenses (including management fees, administrative fees, and other expenses) expressed as a percentage of assets deducted each fiscal year for fund expenses, (i.e., the expense ratio). The particular fees and charges a client will pay are generally determined by the share class that the client purchases. You should be aware that there are limitations on the availability of share classes to clients based on service providers and the funds themselves. These limitations may be imposed by the custodian if, for example, the custodian’s platform only makes certain share classes available. The funds themselves impose certain limitations, such as minimum investment requirements. We recommend and invest in mutual funds that are “no load” funds, which, as the name implies, means that the fund does not charge a sales load. When selecting a fund, we will consider a variety of factors including its expense ratio. We seek to use the lowest cost share class available while considering the client’s investment time horizon and preference. In some instances, the fund investment that we select might be more expensive than another share class with lower expense ratios when considering all the relevant factors. Mutual funds are subject to “ticket charges” which is paid by the client directly to the broker-dealer. ETFs do not Part 2 of Form ADV 5 Diversified Portfolios, Inc.  charge a load, are traded directly on an exchange and unless waived by the broker-dealer, are subject to brokerage commissions. Such fees are in addition to our fee and are disclosed in the fund’s prospectus and are not paid to our Wealth Advisors or to us. Our share class selections are based upon then available information and circumstances, which may later turn out differently for many reasons beyond our control, including your changing investment objectives, financial needs, or time horizon. On a periodic basis, we will review mutual fund holdings to evaluate for share class exchange. A copy of the prospectus is available from the fund. Generally speaking, you may purchase many funds directly, without using our services and without incurring our advisory fees. However, we recommend a number of funds and have access to institutional shares that are not available to the general public. Consequently, for any type of fund investment, it is important for you to understand that you are directly and indirectly paying two levels of advisory fees and expenses: one layer of fees and expenses at the fund level and one layer of advisory fees to us. For information that we consider when recommending a broker-dealer for client transactions and determining the reasonableness of their compensation (e.g., commissions and ticket charges) please see the “ITEM 12: BROKERAGE PRACTICES” section beginning on page 13. Termination of Services Either of us may terminate the investment advisory agreement at any time by providing the other party with written notice. Upon termination, you will remain obligated for the payment of any services performed for your account prior to termination. Also, upon termination of any account, we will charge any earned fees or refund any prepaid, unearned fees as appropriate based on your billing method chosen. You are responsible for any cost incurred in transferring assets from your account to a different account. After termination, we will have no further duties or obligations to you. Direct Billing to Your Custodian Generally, you will authorize us, in the investment advisory agreement, to bill our fees to the custodian of your account and grant the custodian permission to directly debit our fees from your accounts. If you provide us such authorization, you will receive periodic statements from your custodian showing each fee deduction from your account. You may withdraw this authorization for direct billing of these fees at any time by notifying us or your custodian in writing. We will not directly debit our fee from an outside account that holds held-away assets. Instead, our fee will be paid from the client’s taxable accounts. If the client does not have a taxable account from which we can bill, our fee will be billed directly to the client. Payment is due within 20 days of receipt of the invoice. Part 2 of Form ADV 6 Diversified Portfolios, Inc.  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of your assets). ITEM 7: TYPES OF CLIENTS We provide investment management services to individuals, high net-worth individuals, pension and profit-sharing plans, charitable organizations, corporations, and trusts. We impose certain conditions for opening or maintaining an account. Generally, we require a minimum of $1,000,000 of cash and/or securities to open an account for investment management services. We will waive this requirement if, for example, you anticipate future additional assets, have other related accounts, or we have a historical relationship. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis We base our investment approach on the following core principles:  The most important investment decision and the primary driver of returns is the asset allocation decision among various asset classes (i.e., cash, bonds, stocks and alternatives).  Diversification among and within investment categories or “asset classes” is the best way to limit risk, drawdowns (i.e., the decline in an investment's value from peak to trough over a specific period) and improve outcomes.  Establishing and then committing to a long term, disciplined investment approach is the most reliable way to achieve your objectives.  Risk and return are related. The higher return an investor seeks, the greater the potential exists to experience loss. Financial markets provide returns to investors for placing their capital at risk.  Low cost, passively managed and enhanced (i.e., actively managed) index funds, are the most effective vehicles for accessing market returns. Historical data indicates that active fixed income managers can outperform certain fixed income indices after the fund’s fees. We may use low-cost active fixed income Part 2 of Form ADV 7 Diversified Portfolios, Inc.  funds. Reasonable fund management fees are now available with the proliferation of ETF’s and other investment vehicles.  The high cost of many investment products and services contributes to the failure of investors to achieve market returns. We receive data and analysis from economists and other investment professionals. We believe these resources for information are reliable and regularly depend on these resources for making our investment decisions; however, we do not independently verify for the accuracy or completeness of this information. We also receive proprietary software from Dimensional Fund Advisors (“DFA”), an unaffiliated registered investment adviser. We utilize the software in the formation of asset allocation strategies, to analyze investments for your account and production of hypothetical performance reports. Investment Strategies We use a variety of investment strategies depending on your circumstances, financial objectives, and needs. Investments made in portfolios are predominantly long term, and the frequency of trading is limited in order to keep costs low and taxable gains to a minimum. We believe that your portfolio should involve a long-term strategy instead of short-term. We use software programs, to help us analyze and rebalance client portfolios. All accounts are reviewed by our Wealth Advisors and periodically trades are needed to rebalance portfolios or to generate cash for client spending requirements. A list of required trades is prepared and entered into the trading platform, which allows for electronic submission of trades. Before we submit trades, we review the trades again for accuracy. We then place the trade file electronically and keep all required records. The following day, our trading records are reconciled with the custodian and any discrepancy is corrected immediately. We maintain an electronic record of all trades both by date and on a per client basis. Types of Investments and Risk of Loss We develop a long-term asset allocation strategy consistent with your investment goals, objectives and risk tolerance outlined in your investment planning summary. In implementing this long-term strategy, we predominantly use low cost, passively managed and enhanced index funds. Equity funds follow a passive investment philosophy with low turnover and low-cost funds will sometimes follow an active investment philosophy. Occasionally, and only if appropriate for the client’s objectives, we will use individual securities to implement a strategy. While a long-term strategy assumes that the financial market values will increase over the long term, history shows that some asset classes may experience losses over a lengthy period of Part 2 of Form ADV 8 Diversified Portfolios, Inc.  time. Economic, market, political, and issuer-specific conditions and events will cause the value of securities, and the portfolio that owns them, to rise or fall. Markets tend to move in cycles, with periods of rising prices and periods of falling prices. There is also the short-term risk that the segment of the market you are invested in (or perhaps just your particular investment) will decrease over time even if overall markets values increase. We offer advice about a wide variety of investment types, including mutual funds, passive and enhanced index funds, and ETFs, each having different types and levels of risk. We will discuss these risks with you in determining the investment objectives that will guide our investment advice for your account. We will explain and answer any questions you have about these kinds of investments, which present special considerations such as the following.  Market Risk: The price of a security (e.g., mutual funds and ETFs) may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, changes in political, economic, and social conditions have the ability to trigger market events.  Interest-rate Risk: Fluctuations in interest rates cause investment prices to fluctuate. For example, when interest rates rise, the value of fixed-income securities generally declines, and the value of certain equity securities may be adversely affected. Similarly, portfolios that hold fixed-income securities are subject to the risk that the portfolio’s income will decline when interest rates fall.  Reinvestment Risk: This is the risk that future proceeds from investments will have to be reinvested at a potentially lower rate of return. This primarily relates to fixed income securities.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Capitalization Risk: Small-cap and mid-cap companies have historically been more volatile than the stocks of larger, more established companies. Common Part 2 of Form ADV 9 Diversified Portfolios, Inc.  challenges include limited resources or less diverse products or services than larger companies.  Enhanced Index Funds: Using active management, enhanced index funds modify the weights of holdings to enhance the returns of an index. In some cases, the fund may also use derivatives (such as future contracts, and options) and leverage to enhance its returns or the fund may lend its portfolio securities to generate additional income. The use of derivatives and leverage can add additional costs and increase the potential for losses. o Derivatives derived their value from that of other assets, rates or indices. The use of derivatives for non-hedging purposes may be considered to carry more risk than other types of investments. When a fund uses derivatives, the fund will be directly exposed to the risks of those derivatives. Derivative instruments are subject to a number of risks including counterparty, liquidity, interest rate, market, credit and management risks, as well as the risk of improper valuation. Changes in the value of a derivative may not correlate perfectly with the underlying asset, rate or index, and a fund could lose more than the principal amount invested. o Securities lending involves the risk that the borrower may fail to return the securities in a timely manner or at all. As a result, a fund may lose money and there may be a delay in recovering the loaned securities. A fund could also lose money if it does not recover the securities and/or the value of the collateral falls, including the value of investments made with cash collateral. Securities lending also may have certain adverse tax consequences.  Exchange-Traded Funds: ETFs are types of securities that derive their value from a basket of securities such as stocks, bonds, or indices and trade on exchanges during the day like individual stocks, while traditional mutual funds are priced once a day at the close. The value of the ETF will fluctuate with the value of the underlying securities. While ETFs generally track their underlying index fairly well, technical issues can create discrepancies referred to as a “tracking error.” ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of the ETF. Any of these factors may lead to liquidity risk and/or the fund’s shares trading at either a premium or a discount to its “net asset value.” Part 2 of Form ADV 10 Diversified Portfolios, Inc.   Foreign Securities and Currency Risk: Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability.  Performance of Underlying Managers: We select the mutual funds and ETFs in the client’s portfolios. However, we depend on the Underlying Manager of such funds to select individual investments in accordance with their stated investment strategy and on their decisions regarding the allocation of the fund’s assets.  Real Estate Industry: The value of securities in the real estate industry can be affected by changes in real estate values and rental income, property taxes, and tax and regulatory requirements. Also, the value of securities in the real estate industry may decline with changes in interest rates. Investing in REITs and REIT- like entities, including investing in funds that hold these types of entities, involves certain unique risks in addition to those risks associated with investing in the real estate industry in general. REITs and REIT-like entities are dependent upon management skill, may not be diversified, and are subject to heavy cash flow dependency and self-liquidation. Also, because REITs and REIT-like entities typically are invested in a limited number of projects or in a particular market segment, these entities are more susceptible to adverse developments affecting a single project or market segment than more broadly diversified investments.  Cybersecurity - The computer systems, networks and devices used by Diversified Portfolios, Inc. and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent Part 2 of Form ADV 11 Diversified Portfolios, Inc.  release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. Investing in securities involves risk of loss that you should be prepared to bear. Obtaining higher rates of return on investments typically entails accepting higher levels of risk. We work with you to attempt to identify the balance of risks and rewards that is appropriate and comfortable for you. However, it is still your responsibility to ask questions if you do not fully understand the risks associated with any investment or investment strategy. Also, while we strive to render our best judgment on your behalf, many economic and market variables beyond our control can affect the performance of your investments and we cannot assure you that your investments will be profitable or assure you that no losses will occur in your investment portfolio. Past performance is one relatively important consideration with respect to any investment or investment advisor, but it is not a predictor of future performance. ITEM 9: DISCIPLINARY INFORMATION As a registered investment adviser, we must inform you of all material facts regarding any legal or disciplinary events that would be material to your evaluation of our firm or the integrity of our management. We have no legal or disciplinary events to disclose. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS As a registered investment adviser, we must disclose information regarding our business activities, other than giving investment advice, our other activities in the financial industry, and any arrangements with related persons that are material to you or our advisory business. We are also required to disclose if we receive cash or other economic benefits when recommending or selecting third-party investment advisers in connection with advising you. We do not utilize or select other investment advisers to manage your assets and have no applicable information to disclose. ITEM 11: CODE OF ETHICS We have adopted a Code of Ethics for the officers and employees (collectively, “supervised persons”) of our firm describing the high standard of business conduct and fiduciary duty owed to our clients. Our Code includes provisions relating to the confidentiality of client Part 2 of Form ADV 12 Diversified Portfolios, Inc.  information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All of our supervised persons are required to follow our Code and must acknowledge the terms of our Code annually, or as amended. From time to time, our supervised persons will purchase investments that we also recommend to clients. Subject to our Code and applicable laws, all of our supervised persons are permitted to trade for their own accounts in securities which we recommend to or purchase for our clients. Generally, these securities will be shares of open-ended mutual funds priced at its portfolio's net asset value (NAV) at the end of each day or ETFs actively traded on a national securities exchange or market where the time and size of their purchases or sales will not affect transactions for you or our other clients. If we do recommend the purchase or sale of a thinly traded security to you, we will ensure that our supervised persons’ transactions do not adversely affect you nor improperly benefit them. The Chief Compliance Officer (“CCO”) monitors our supervised persons’ trading under our Code to prevent conflicts of interest between our clients and us. All trades and holdings of the CCO are reviewed by Katie P. Wagner, co-owner. You may request a copy of our Code by contacting J. Brad Cox, Chief Compliance Officer, at 248-644-3030 or bcox@divport.com. ITEM 12: BROKERAGE PRACTICES Directed Brokerage & Soft Dollars We require that our clients use Charles Schwab & Co., Inc., (“Schwab”) a registered broker-dealer for custodial and brokerage services. We are independently owned and operated and are not affiliated with Schwab. While we require that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Not all independent investment advisers require that their clients use a particular broker/custodian. If you open your account at Schwab, Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. We do not open the account for you, although we may assist you in doing so. Generally, if you choose Schwab as your custodian, they do not charge your account a separate custodial fee, but instead charge commissions and other transaction-related fees for securities trades that are executed through them or that settle into your account custodied with them. Clients may pay ticket charges or commissions to Schwab that are higher than another qualified broker-dealer might charge to effect the same transaction. We will in good faith determine that any transaction fee is reasonable in relation to the value of the brokerage and research services received. Certain trades (for example, many mutual funds, and U.S. exchange-listed equities, and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on cash in Schwab’s Cash Features Part 2 of Form ADV 13 Diversified Portfolios, Inc.  Program (“Cash Features”). The Cash Features is a service that automatically invests, or “sweeps,” the client’s eligible uninvested cash from their brokerage account into a liquid investment. The Cash Features is not intended for long-term investments and yields on any of the Cash Features can be lower than reasonable alternatives. If your account utilizes a Cash Features Program, your cash will earn income while we decide how best to invest those funds for the longer term. We have evaluated Schwab and have determined they offer our clients a variety of services, financial stability, and competitive commission rates. We do not receive remuneration from any broker including Schwab. In recommending this broker, we considered our confidence in the firm, competitive rates for transactions, trade execution, availability of no-load, no transaction fee mutual funds, and other investments that are otherwise generally available only to institutional investors or to accounts with a significantly higher minimum initial investment, website features, and their custodial services. We have not and do not intend to enter into any contractual third-party soft-dollar arrangements, such as committing to place a specific level of brokerage with a specific firm in return for which the brokerage firm will pay for various research related products or services for us that are generally available for cash purchase. However, Schwab does offer us other products and services that assist us in managing and administering clients’ accounts but will not necessarily directly benefit your account. We do use many of these products and services to service all or some substantial number of our client accounts. These products and services include software and other technology that (1) provide us access to client account data, such as trade confirmations and account statements; (2) facilitate trade execution; (3) provide research, pricing and other market data; (4) facilitate payment of our fees from our clients’ accounts; and (5) assist with back-office functions, recordkeeping and client reporting. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Nevertheless, as part of our fiduciary duty to clients, we endeavor at all times to put the interests of our clients first. You should be aware that the receipt of economic benefits by us or our supervised persons in and of itself creates a conflict of interest and could indirectly influence our choice to recommend brokers for custody and brokerage services. However, we have determined that having Schwab execute trades is consistent with our duty to see “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer you may pay lower transaction costs. If your assets are subject to ERISA, you may direct us to utilize a specified broker-dealer of your choice to effect transactions for or with your account. You should understand that, in the case of such a directed brokerage arrangement: Part 2 of Form ADV 14 Diversified Portfolios, Inc.   you will be solely responsible for negotiating the terms and arrangements on which those brokers and dealers are engaged, and we will have no responsibility for re- viewing the fairness of those terms and arrangements;  we will not seek better execution services or prices from other brokers and dealers in connection with transactions for your account;  we will not be able to “batch” or “aggregate” transactions for your account with trans- actions for our other clients not subject to a similar such arrangement;  we will not monitor the performance of or the services provided by the brokers and dealers so designated; and  you may pay higher commissions or other transaction costs or greater spreads, or re- ceive less favorable net prices on transactions for the account than would otherwise be the case. Schwab Advisor Services™ Schwab offers independent investment advisory firms like us support products and services, such as institutional trading and custodial services, through their program Schwab Advisor Services™. These services are generally available to independent investment advisers on an unsolicited basis, at no charge, so long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab. As a result, these services are contingent upon us committing a specific amount of business, assets in custody, to Schwab. Schwab also offers other services intended to help us manage and further develop our business enterprise. These service offerings include compliance, legal and business consulting, publications and conferences on practice management and business succession and access to employee benefits providers, human capital consultants and insurance providers. Schwab also offers other benefits to us, such as educational events or occasional business entertainment of our personnel. Schwab’s support services are generally available at no charge to us. The fact that we receive benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such decisions based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not the services that benefit only us. Dimensional Fund Advisors and Vanguard Group, Inc. Part 2 of Form ADV 15 Diversified Portfolios, Inc.  As stated under ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS, beginning on page 7, we utilize resources made available to us through DFA, to analyze investments for your account such as historical market analysis, and risk/return analysis. DFA also provides us, and other advisers in its network, with education and analytics tools, practice management support, and other resources. These tools are made available to us because we are considered an approved advisor on the DFA platform. DFA’s approval process includes meeting with the advisor’s representatives, discussing investing philosophy to determine whether it matches that of DFA, and requesting that the financial advisor attend DFA’s seminar. In addition, Vanguard Group, Inc. (“Vanguard”) makes available to us tools to evaluate client portfolios and holdings. Vanguard also makes available general educational material that if relevant, we will send to our clients. While there is no direct link between our participation with Vanguard and the investment advice, we give to you and our other clients, as stated above, we do receive some benefits through our association with Vanguard that are typically not available to the general public. While receiving tools and research materials from DFA and Vanguard causes a conflict of interest, we mitigate this risk by evaluating and treating the available resources in the same way as the resources received from Schwab and other sources. Aggregation of Orders Investment advisers may aggregate the purchase or sale of securities for various client accounts for their administrative convenience and, in some transactions, to obtain better execution for the aggregated order than might be achieved by processing each of the transactions separately. We offer personalized investment management services and do not aggregate trades. Trade Error Policy We have the responsibility to process trade orders correctly, promptly and ensure the best interests of our clients are served. From time to time, we may make an error when submitting a trade such as, the purchase or sale of the wrong security (e.g., use the wrong ticker symbol);  the purchase or sale of an incorrect amount of shares of a security;  the purchase or sale of a security at a price not in accordance with instructions; or  a purchase of a security when the intent was to sell, or vice versa.  Our policy is to seek to identify and correct any errors as promptly as possible without disadvantaging the client or benefiting us. If we are responsible for a trade error that results in a loss in the client’s account, we would normally make a trade to reverse the error immediately upon discovery of the error. However, if this is not allowed, e.g., where the “wash sale” rules of the Internal Revenue Code prevent immediate reversal of an error, then we place a corrective Part 2 of Form ADV 16 Diversified Portfolios, Inc.  trade as soon as allowable. Generally, if related trade errors result in both gains and losses in the client’s account, they will be netted. Trade Error Losses - If a trade error occurs and it results in a loss in the client’s account, the client’s account is reimbursed for the entire amount of the loss as soon as practical after the discovery of the error. If the loss is greater than $100, we are invoiced by Schwab and will pay for the loss. If the loss is under $100, Schwab will absorb it to minimize its administrative time and expense. Trade Error Gains - If a trade error at Schwab results in a gain less than $100, Schwab will retain the gain to reduce its administrative time and expense. If a trade error results in a gain of more than $100, the gain will remain in the client’s account, unless the same error involved other client account(s) that should have received the gain, it is not permissible for the client to retain the gain, or we confer with the client and the client decides to forego the gain (e.g., due to tax reasons). If the gain does not remain in the client’s account, Schwab will donate the amount of any gain of $100 or over to charity. In all cases, where a trading error results in a gain, we will not be given the benefit of the net profit. We do maintain appropriate records for all trade errors. Regardless of the nature of the error, if we are responsible for a trade error that occurs in your account, you will be reimbursed any and all costs that result from the errant trade. ITEM 13: REVIEW OF ACCOUNTS We review each account at least quarterly to evaluate and ensure the conformity of the portfolio with your investment objectives. Other factors may trigger additional reviews, such as substantial changes in the market price of stocks and bonds, changes in your objectives or portfolio changes that would impact all accounts. Our Wealth Advisors conduct reviews and review trades when reviewing accounts. We provide you a report on a quarterly basis. Quarterly reports provide the quarter-end market value and the time-weighted returns for all the relevant time periods covering the relationship. You will receive periodic reports, at least quarterly, from the custodian for your account, detailing the transactions within your account for that period. We urge you to review your statements carefully and compare such official custodial records to your statements that we provide to you as described in “ITEM 15: CUSTODY,” beginning on page 18. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION As described in “ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS and ITEM 12: BROKERAGE PRACTICES,” we receive research and other benefits from our relationships with Schwab, DFA, and Vanguard. In addition to the Part 2 of Form ADV 17 Diversified Portfolios, Inc.  services named above, DFA, through a web-based service, provides referrals based on the prospective client’s geographic location. DFA makes such referrals to many investment advisers that manage at least $20 million in total assets and have used Dimensional Funds for at least one year and invest at least 40% of client assets in Dimensional funds based on data known to DFA. We do not compensate DFA for including our name on their web-based service. Other Third Party Promoters Prior to joining our firm, Mr. Post arranged to pay a third party promoter (formerly referred to as a solicitor) for referring clients to his former employer, Independence Advisors, Inc. Many of those referred clients became our clients, and under the arrangement, the third party promoter continues to receive a portion of the standard management fee for a period of time on such clients, which may vary on a case-by-case basis. The payment for a referral or solicitation does not influence the fee paid by our clients. Employees We have entered into written agreements with our registered employees in which we pay those employees a percentage of revenue billed and received for referring certain business to us. ITEM 15: CUSTODY We do not maintain custody of client assets. Rather, each client appoints a qualified custodian to take possession of all client funds and securities. We do not accept cash or securities. We have procedures in place to direct employees regarding the inadvertent receipt of any client funds or securities. Nevertheless, we are deemed to have custody when we are authorized, by the client, to directly debit our advisory fees from the client’s custodian account. We are also deemed to have custody when a client establishes a letter of instruction or other asset transfer authorization arrangement with their qualified custodian, authorizing us to disburse funds to one or more third parties specifically designated by the client. You will receive statements from the broker-dealer, bank or other qualified custodian that holds and maintains your investment assets at least quarterly. Our statements may vary from custodial statements due to items such as the timing of posting and settlement of transactions, securities pricing, the treatment of corporate reorganizations or other corporate actions, reporting dates, cost basis adjustments, valuation methodologies of certain securities and other differences. You should notify us promptly if you do not receive statements from all your account custodian(s) on at least a quarterly basis. We urge you to carefully compare the account balances and positions contained in the official custodial records to the balances reflected on your statement received directly from us, as described in the “ITEM 13: REVIEW OF ACCOUNTS” beginning on page 17. If you have any questions or believe there are inconsistencies with these statements, please contact us or the account custodian. Part 2 of Form ADV 18 Diversified Portfolios, Inc.  ITEM 16: INVESTMENT DISCRETION We generally receive discretionary authority from you at the outset of an advisory relationship. Discretionary authority grants us the ability to determine, without obtaining your specific consent, the securities to be bought or sold for your portfolio, and the amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with your investment planning summary, as described in more detail in “ITEM 4: ADVISORY BUSINESS” beginning on page 2. When selecting securities and determining amounts, we observe your investment planning summary or any other investment policies, limitations, and restrictions you provide to us in writing. Also, you will sign an agreement with your custodian which generally includes a limited power of attorney granting us authority to direct and implement the investment and reinvestment of your assets within the account. ITEM 17: VOTING CLIENT SECURITIES On rare occasion, we may elect to accept a client’s authorization to receive issuer and issuer-related communications regarding corporate reorganizations and other corporate actions, excluding proxies, regarding investments held in a client’s account. Unless we agree otherwise, we will have no obligation or authority to take any action or render any advice with respect to the voting of proxies solicited by or with respect to issuers of securities held in client accounts. You will arrange with your custodian to have proxy solicitation materials forwarded to you for response and voting. You will be solely responsible for voting proxies. ITEM 18: FINANCIAL INFORMATION As a registered investment adviser, we are required to provide you with certain financial information or disclosures about our financial condition if we have financial commitments that impair our ability to meet contractual and fiduciary commitments to you. We have not been the subject of a bankruptcy proceeding and do not have any financial commitments that would impair our ability to meet any contractual or fiduciary commitments to you. Part 2 of Form ADV 19 Diversified Portfolios, Inc.  EXHIBIT ITEM 2: MATERIAL CHANGES Under the Amendments to the Form ADV, Diversified Portfolios, Inc. may provide you with this summary of Material Changes detailing any material changes that we made to our Brochure dated March 20, 2025 since the last annual update March 18, 2024, in lieu of sending a full copy of our Brochure to all our clients. On December 17, 2024, Connor Hughes obtained his CFP® certification and has been promoted to the position of Wealth Advisor. Additional information regarding Mr. Hughes is available in his Brochure Supplement. In addition to the changes identified below, we have made certain other grammatical and non-material changes throughout the Brochure. Item 5: Fees and Compensation Our standard fee schedule for new clients has been updated. Item 8: Investment Strategies and Risk of Loss We have added additional disclosures to explain our use of passive and actively managed index funds as well as the risks associated with such investment vehicles. Item 12: Brokerage Services We provided additional disclosures regarding the Cash Features Program available through Charles Schwab & Co., Inc. Additional Information You may request a copy of our current Brochure and supplements, free of charge, by contacting J. Brad Cox, Chief Compliance Officer, at 248-644-3030 or bcox@divport.com. Additional information about us is also available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered, or are required to be registered, as one of our investment adviser representatives of our firm. Material Changes Part 2 of Form ADV Diversified Portfolios, Inc.