INTRACK INVESTMENT MANAGEMENT, INC.

1 1233 Shelburne Road, Suite D6-B South Burlington, Vermont (802) 658-0625 www.intrackinvest.com March 7, 2025 This brochure provides information about the qualifications and business practices of InTrack Investment Management, Inc. If you have any questions about the contents of this brochure, please contact us at (802) 658-0625 or e-mail Brandon D. Tieso at btieso@intrackinvest.com 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. InTrack Investment Management, Inc. is a registered investment adviser. Use of the term “registered investment adviser” does not imply any level of skill or training. Additional information about InTrack Investment Management, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as an SEC file number. Our firm’s SEC file number is 801-79488. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  2 Item 2: Material Changes Below are the material changes that occurred since InTrack Investment Management’s last SEC annual filing on March 01, 2024: Item 4 has been updated to reflect that InTrack has incorporated financial planning services into its investment management offering but retains the option to charge a negotiable hourly rate for complex or standalone financial planning engagements. Item 5 has been updated to reflect certain disclosures related to advisor compensation and conflicts of interest. Item 7 has been updated to reflect that InTrack’s recommended minimum account size is $500,000. Item 14 has been updated to reflect certain disclosures related to advisor compensation and conflicts of interest. Part 2B has been updated with addendums for Matthew Sopher and Brandon Tieso. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  3 Item 3: Table of Contents Item 1. Cover Page.........................................................................................................................................1 Item 2. Material Changes...............................................................................................................................2 Item 3. Table of Contents...............................................................................................................................3 Item 4. Advisory Business.............................................................................................................................3 Item 5. Fees and Compensation.....................................................................................................................6 Item 6. Performance-Based Fees and Side-By-Side Management……………………..…………………..8 Item 7. Types of Clients.................................................................................................................................8 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss…………………………………….9 Item 9. Disciplinary Information.................................................................................................................11 Item 10. Other Financial Industry Activities and Affiliations.....................................................................11 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading………....11 Item 12. Brokerage Practices.......................................................................................................................12 Item 13. Review of Accounts.......................................................................................................................13 Item 14. Client Referrals and Other Compensation……………………………….……………................13 Item 15. Custody..........................................................................................................................................14 Item 16. Investment Discretion....................................................................................................................14 Item 17. Voting Client Securities.................................................................................................................14 Item 18. Financial Information....................................................................................................................15 Item 19. Requirements for State-Registered Advisers.................................................................................15 Part 2B Brochure Supplement – Myron R. Sopher......................................................................................16 Part 2B Brochure Supplement – Matthew D. Johnson................................................................................18 Part 2B Brochure Supplement – Brett C. Peltzer.........................................................................................21 Part 2B Brochure Supplement – Matthew S. Sopher...................................................................................24 Part 2B Brochure Supplement – Brandon D. Tieso.....................................................................................27 Item 4: Advisory Business Corporate History InTrack Investment Management, Inc., previously Sopher Investment Management, has been in business providing advisory services since 1992. In 2016, Peltzer Capital Management joined InTrack Investment Management. The advisory firm has offices in South Burlington and Norwich, Vermont. The company’s Managing Partner and principal owner is Myron R. Sopher. Partners and owners in the firm include Myron R. Sopher, Brett C. Peltzer, CFA® and MBA, Matthew D. Johnson, CFA®. Matthew S. Sopher, MBA and Brandon D. Tieso, CFP® are employees of the firm. Advisory Services Investment Management Services InTrack Investment Management (InTrack) clients and their families know our advisers are there to help them navigate change and stay on course to achieve their long-term financial goals by managing their investments. InTrack’s advisers integrate their understanding of a client’s individual circumstances and values with their expertise in finance, global economics, entrepreneurial ventures, and customized portfolio construction. Using the information collected, the adviser determines asset allocation, then constructs and manages the client’s portfolio based on the stated objective. While InTrack’s goal is to help clients manage their assets and financial lives, plus assist them in building and sustaining wealth, our advisers’ greatest pleasure is being an ever-present, trusted resource. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  4 InTrack’s advisers use their expertise to manage complex trust situations, provide solutions to concentrated investment positions, oversee clients’ retirement funds and help clients balance risk with other non-retirement accounts. Advisers assist clients with planned goals (saving for college, medical expenses) or unplanned events (death of a loved one and the transition of assets from one generation to the next). If a client requests that their adviser examine retirement planning and other investments related to retirement, the adviser may provide suggestions. Advisers educate clients so they understand their investments and the factors that affect their investments. InTrack’s investment advisory services are fee- only. Our investment strategies utilize publicly traded equities, fixed income and cash securities as described below. • Stocks. • Bonds including municipal, treasury, corporate, and foreign bonds that are investment grade. InTrack cannot control bond holdings in mutual funds and informs clients of this fact. Certain mutual funds may include lower than investment grade fixed income bonds. • Exchange traded funds (ETFs) • Mutual funds. • Cash, cash equivalents, and certificates of deposit. • Structured notes, private placements The majority of clients that work with InTrack advisers do so on a discretionary basis. If a client engages InTrack on a non-discretionary investment advisory basis, the client must accept that InTrack Investment Management cannot affect any account transactions without obtaining prior verbal consent from the client. This applies even in the event of a market correction. Without consent from the client, an adviser does not have the authority to execute trades. Financial Planning Services InTrack’s financial planning services are integrated with its investment management offering. Clients may engage InTrack for standalone financial planning on a negotiable hourly basis for complex or unique cases. Financial planning services typically involve a comprehensive review of personal and financial information, which may include interviews, financial statements, tax considerations, and estate planning documents. InTrack utilizes eMoney software in the preparation of the financial plan. eMoney software allows the client to view a consolidated asset allocation of their financial assets which can include assets InTrack does not manage. The plan may include an income, spending, and savings analysis while incorporating the client’s goals such as retirement and education savings. If requested, advisers analyze the client’s current investments and make recommendations based on the plan’s results. It is entirely the client’s decision to implement the plan, parts of the plan, or disregard the recommendations. Although InTrack may make recommendations, the firm is not responsible for the investment performance of any assets not managed by InTrack. If the client chooses to implement any of the plan’s recommendations, InTrack advises the client to consult closely with their attorney, accountant, insurance agent and financial adviser when implementing the plan. Consulting and Participant Directed Retirement Plan Consulting InTrack provides consulting services for some clients. Depending on the nature of the agreement, Advisers review individual securities and overall aggregate allocation then offer recommendations to align the portfolio with the client’s objectives, risk tolerance and current and future financial needs. It is the client’s responsibility to choose the recommendations that meet their objectives and execute those March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  5 recommendations. Consulting services also include participant directed retirement plans. In these cases, advisers review and select mutual funds offered to the plan’s participants which are consistent with the plan’s objectives, provide general information on the benefits of investing in 401k plans, show historic return information on various asset classes, and offer general guidance on allocation of participant’s portfolios. Miscellaneous Retirement Plan Rollovers and Potential for Conflicts of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan and may engage in a combination of the following options. If permitted, leave the money in the former employer’s plan. • • Rollover the assets to the new employer’s plan, if one is available and rollovers are permitted. • Rollover to an Individual Retirement Account (IRA). • Cash out the account value which could, depending upon the client’s age, result in adverse tax consequences. If an adviser of InTrack recommends that a client rollover their retirement plan assets into an account to be managed by InTrack, such a recommendation creates a conflict of interest if InTrack will earn an advisory fee on the assets. To address this, InTrack requires all rollover clients to sign and understand our Rollover Disclosure document. No client is under any obligation to rollover retirement plan assets to an account managed by InTrack. If a client has any questions regarding the potential for a conflict of interest on a retirement plan rollover, please contact Brandon D. Tieso, CCO. If a client requests information regarding retaining an attorney, accountant, insurance agent or any professional, advisers of InTrack Investment Management may recommend an individual or firm to assist the client. However, if a dispute arises between the client and the professional, InTrack is not held accountable for recommending the professional. The client shall seek recourse from the individual or firm they engaged to provide the professional service. InTrack is not responsible for the services rendered by the professional. Held-Away Management with Pontera InTrack Investment Management uses the Pontera platform made available by Pontera Solutions, Inc. (“Pontera”), a third party online platform, to assist with management of clients’ “held away” accounts, including 401(k)s, 403(b)s, annuities, and 529 education savings plans, and as an order management system for such accounts where InTrack implements tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. The specific fee schedule charged by InTrack for account management of held away assets is established in the client’s written agreement with InTrack. To facilitate use of the Pontera platform, the client securely logs into the Pontera site and entitles InTrack to manage the assets. Clients do not pay any additional fee to Pontera or to InTrack in connection with platform participation. InTrack is not affiliated with the Pontera platform in any way and receives no compensation from them for using their platform. Investment management fees are generally directly debited on a pro rata basis from client accounts. The exception for this is directly managed held-away accounts, such as 401(k)s on Pontera. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account, those fees will be billed directly to the client. Customizing Advisory Services InTrack Investment Management tailors each advisory relationship to the client’s needs by maintaining March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  6 contact with each client through meetings, phone calls, and e-mails and determines if the individual’s circumstances or perspectives have changed which may result in a change to their investment objective. Upon a client’s request, and if the adviser believes the request can be honored, InTrack Investment Management is able to customize a client’s investments. Typically, a client might restrict the adviser from purchasing or holding certain securities, industries, or sectors. If the portfolio currently includes these holdings, the adviser will act upon the client’s decision to either sell or work to reduce the holding over time. These requests are documented. Each client is advised that it remains their responsibility to promptly notify InTrack Investment Management of any changes in their financial situation or investment objectives so the adviser can review, recommend, and incorporate the change into the client’s accounts. Wrap Fee Programs This item is not applicable. InTrack Investment Management does not participate in wrap fee programs. Client Assets Assets under management as of December 31, 2024: Discretionary: $286,242,959.51 Non-discretionary: $0 Item 5: Fees and Compensation Fee Schedule During the onboarding process for portfolio management services and before any documents are signed, InTrack’s advisers review, discuss, and answer any questions with the potential client on all aspects of the business relationship including fees. InTrack’s annual investment management fee is usually a graduated scale. The following is a sample fee schedule provided for illustrative purposes, however actual fee schedules will vary by client and are negotiable. • 1.0% of the value of the account plus accrued interest up to $3,000,000.00. • 0.85% of the value of the account plus accrued interest between $3,000,000.01 up to $5,000,000.00. • 0.75% of the value of the account plus accrued interest between $5,000,000.01 up to $7,500,000.00. • 0.50% of the value of the account plus accrued interest in excess of $7,500,000.01. A 5% reduction in fees is granted to non-profit organizations. Depending on the client relationship, we sometimes agree to “household” certain client account for the purposes of fee calculation. In certain situations, InTrack retains the right to negotiate fees based on circumstances including but not limited to the complexity of managing the portfolio, related accounts and balances of those accounts, the future addition of assets, and the level of service required. InTrack does not charge investment management fees for employee accounts or their children’s accounts. Reduced fees may be offered to the parents of our employees. At our sole discretion, we sometimes charge a lesser investment advisory fee or waive fees entirely March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  7 depending on client circumstances. Due to business acquisitions and legacy agreements, fee schedules will vary among clients and fees can be calculated in a different manner. Financial Planning Financial planning services are now incorporated into our investment management offering. However, for complex or unusual cases requiring extensive analysis beyond standard financial planning, InTrack reserves the right to charge an hourly rate, which is negotiable based on the scope and complexity of the engagement. InTrack may also charge on an hourly basis for standalone financial planning services not tied to investment management. An ongoing, flat annual fee is charged for clients who elect to retain access to the eMoney software. At the advisor’s discretion, financial planning fees may be waived when provided as part of the onboarding process. Consulting Each consulting arrangement is unique and therefore, there is no set fee schedule. Fees are determined after considering the anticipated time to service the relationship and agreed upon in the consulting agreement. In the case of fees for consulting on participant directed retirement plans, the following factors are considered but not limited to the size of the plan, number of investment options, and the type and frequency of the requested reports. These fees are disclosed and agreed upon in the consulting agreement. Billing Investment management client fees are debited from the client’s investment account; however, a few investment management clients elect to be invoiced. The billing method is determined during the onboarding process. Investment fees are billed on a quarterly basis and based upon the ending market value of the assets on the last business day of the previous quarter. If a market value is not available for a particular client security, historical cost will be used as the quarter ending value for fee calculation purposes. In the case of an investment relationship beginning within a quarter, the fees will be prorated. Financial planning clients and consulting clients are usually invoiced at the rate determined in the agreement, and those fees are due upon receipt of the invoice. Other Types of Fees or Expenses InTrack Investment Management’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment entities and other third parties. Other fees that may be incurred are deferred sales charges, odd-lot differentials, transfer taxes, wire transfers, electronic fund fees, fees and taxes on brokerage accounts, and security transactions. Trade away and/or prime brokerage fees will be charged in situations where, for the benefit of the client, InTrack advisers purchase investment instruments through broker dealers other than the client’s account custodian. Mutual funds and exchange-traded funds also charge internal management fees and other fees which are disclosed in a fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to InTrack’s fee and the firm shall not receive any portion of these commissions, fees, and costs. For additional information, please refer to Item 12, Brokerage Practices. Certain Investment Adviser Representatives ("IARs") of the firm may participate in arrangements where they receive a percentage of the advisory fees generated by client accounts. These arrangements create a conflict of interest as the IAR may have an incentive to devote more time and attention to these accounts or to make different investment decisions for these accounts compared to other client accounts. The firm addresses these conflicts through disclosure, supervision, and our Code of Ethics to ensure all clients receive appropriate attention and are treated fairly. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  8 Fees Paid in Advance or in Arrears Investment advisory clients are billed in advance each calendar quarter; however, clients managed by the Norwich office at the time of the merger (January 1, 2016) and a few South Burlington clients are billed in arrears as specified in the client’s fee agreement. If a client or adviser terminates an agreement, the unearned fees paid in advance will be refunded to the client promptly. In the case of fees paid in arrears, the client will be liable for the accrued fees. An agreement may be terminated by either party upon ten day’s written notice to the other. The calculation method for unearned fees takes the number of days in the quarter then subtracts the actual days the account was managed. This provides the number of days the account was not managed. By dividing this number by the number of days in the quarter, the ratio used to multiply the total fee charged is calculated. This sum determines the amount InTrack Investment Management owes the client. Please see below for an example. Fee charged $750.00 91 days in the quarter 5 days the account was managed 91 – 5 = 86 days the account was not managed 86/91 = .945 $750 fee charged x .945 = $708.75, the amount the client is reimbursed Consulting clients are charged in accordance with their consulting agreement. Financial planning and money coaching are invoiced before receiving services. Compensation for Sales of Investment Products This item is not applicable. Employees of InTrack Investment Management do not receive compensation for the sale of investment products including securities. Item 6: Performance-Based Fees and Side-By-Side Management InTrack Investment Management’s current fee schedule does not include performance- based fees. InTrack has one agreement with a long-time client that rewards the firm on an annual basis if the adviser exceeds predetermined performance benchmarks. There is a risk that an adviser will spend more time managing this account and provide preferential treatment because of the incentive. To mitigate this risk, InTrack utilizes policies and procedures which monitor asset allocation decisions and trade turnover to ensure this type of portfolio is not influenced by the fee arrangement. All our advisers sign our Code of Ethics which addresses conflicts of interest. The adviser on this account is a Certified Financial Analyst and is held to that organization’s Code of Ethics. Item 7: Types of Clients Our clients include individuals, high-net-worth individuals, families, trusts, non-profit organizations, foundations, municipal organizations, limited liability organizations, corporations, and participant directed retirement plans. To utilize our full-service capabilities efficiently, InTrack recommends a minimum account size of $500,000. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  9 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis and Investment Strategies To formulate investment advice and manage assets, advisers utilize research, sector analysis, economic factors, and business cycles. InTrack Investment Management has a team-based approach which allows advisers to evaluate, through discussion, aspects of an investment recommendation. Each adviser researches and monitors certain sectors of the market and is responsible for disseminating the information to the other advisers. Advisers utilize independent research sources to assist in compiling information on individual securities. InTrack’s advisers have considerable experience in evaluating assets and portfolios and have created systems (discussed below) to assist them in managing assets. The Investment Committee meets on a regular basis to discuss investment selection and monitor existing investments in clients’ portfolios. InTrack Investment Management constructs each client portfolio to reflect that client’s unique circumstances. Advisers evaluate the client’s tolerance to risk, their return requirements, cash flow needs, and tax implications. As the client’s circumstances change, their portfolio could be adjusted to reflect their new objective. These objectives are defined in their Investment Management Agreement and will be discussed in “Investment Strategies and Material Risks.” Below are other systems, in addition to the ones mentioned above, that assist advisers in the selection of stocks. • Strategic approach refers to the asset allocation decision and is based on a long-term macroeconomic view and market valuation. InTrack Investment Management considers many variables when constructing a portfolio’s asset allocation including, but not limited to, market segment valuations, inflation expectations, corporate earnings and interest rate outlooks, geopolitical concerns, and currency fluctuations. • Market psychology is also important to the asset allocation process. InTrack Investment Management believes the market is efficient in the long term; however, it can prove to be irrational or incorrectly priced in the short term. The short-term fluctuations usually occur during periods of extreme optimism or pessimism. • An individual’s tax situation is taken into consideration by advisers in the portfolio management process. InTrack constructs portfolios to minimize the impact of taxes by considering the client’s various accounts, for example taxable, tax- deferred, tax advantaged charitable trusts and generation skipping trusts. The assets within the accounts have different tax considerations and could make a significant impact in long-term wealth accumulation. • A client’s investing choices are incorporated when building and managing their portfolio. Material risks to an individual investment security purchased in a portfolio include, but are not limited to, unexpected natural disasters, damage as the result of war and armed conflicts, loss of key corporate personnel, product recalls, quality concerns, loss of a major client, introduction of new products that render existing product lines obsolete, patent suits, penalties from those suits, a data breach of secure information, federal, state or local laws that adversely impact a company, inaccurate, misleading or fraudulent information distributed to the public and relied upon to make an investment decision. Non- public information within a company may exist and, if disclosed, could significantly alter the company’s standing. Analysis of securities utilizes rating agencies and public sources of information which the March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  10 advisers presume are providing accurate and unbiased information. Investment advisers, including InTrack’s advisers, rely on digital and network technologies to conduct business. Digital technologies can be vulnerable to cyber- attacks where unauthorized access is attained to digital systems and a client’s personal information can be illegally removed and misappropriated. The intent of other cyber- attacks is to cause disruption to operations or corrupt data. Although companies and InTrack institute policies, procedures, and safeguards to prevent the misappropriation of data or interruptions to operations, cyber-attacks could occur, and these attacks could result in access to the personal information of a client and adviser. Investing in the financial markets involves risk and there is no guarantee that any investment strategy will meet the objective over a short period of time. Clients should be aware of the possibility and prepared for potential losses in their investment portfolios. InTrack’s advisers never promise clients that the firm’s past investment performance will be the future investment performance. Investment Strategies and Material Risks Our investment strategies are designed to align with clients’ financial goals and risk tolerance. We emphasize the importance of asset allocation in driving long-term portfolio performance. Our strategies range from conservative income-focused portfolios to growth-oriented portfolios, with the level of investment risk generally correlating to the proportion of equities within the portfolio. We typically recommend a longer time horizon for portfolios with significant equity exposure. Portfolios may include cash, fixed-income securities, and equities, both domestic and international. Fixed- income investments provide income and help mitigate volatility, while equities offer growth potential. We employ a disciplined approach focused on high-quality investments, seeking to balance income generation, capital preservation, and long-term growth. Clients should be aware that investments are subject to market risk, including the potential loss of principal, and that there are no guarantees of achieving investment objectives or outperforming inflation. An investment objective can be customized when agreed upon by both the client and adviser. Risk factors for these portfolio types are the same as those mentioned in Item 8, A, as well as the risks discussed below. Portfolios including fixed income securities (see above for percentages of fixed income securities in each portfolio strategy) are subject to risks including changing interest rate levels, credit, and economic risks. The value of fixed income securities generally decreases in periods when interest rates are rising. Interest rate changes typically impact the prices of long-term fixed income securities more than short-term fixed income securities. Credit risk involves the probability that a company will not make interest and principal payments or the perceived notion of this occurring. Change in the issuing entity’s situation, industry, or events in the financial markets are also risk factors. Market risks include inflation, currency movement, and sociopolitical risk. Equities are influenced by many of the same factors as fixed income securities. Other risks include business risks or anything that causes a drop in the value of the company, economic growth or a recession, disruption in the company itself, performance of the company and financial strength of the company. The risks involved in investing in emerging markets include the possibility of highly volatile markets and less regulation than those of developed countries. Countries with emerging markets may have immature economic structures and financial markets, different legal systems, and could have laws or enact laws that prove unbeneficial to foreign investors. Investing in foreign stocks through American Depositary Receipts March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  11 (ADR’s) can run the risk of not being denominated in U.S dollars. With an unsponsored ADR, it may be difficult to receive shareholder communications. Risks Regarding a Recommended Type of Security This item is not applicable. Employees of InTrack Investment Management do not primarily recommend specific securities that have unusual risk factors. Item 9: Disciplinary Information The Advisor has not been subject to any disciplinary actions. Neither have any of its partners, affiliates, or their employees. This includes any criminal cases involving fraud, civil actions related to investments, administrative proceedings before the United States Securities and Exchange Commission or other regulatory agencies, and any self-regulatory organizations. Item 10: Other Financial Industry Activities and Affiliations These items are not applicable. InTrack Investment Management advisers are not registered (or have pending registrations) for broker dealers, future commission merchants, etc. and do not have related persons that present a conflict of interest nor does InTrack recommend investment advisers and receive compensation. Sometimes securities held in client portfolios may be the subject of class action lawsuits. Our firm has engaged a third-party service provider, Chicago Clearing Corporation (“CCC”), to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of the InTrack’s clients. When a claim is settled and payments are awarded to our clients, it may be necessary to share client information, such as name and account number, with CCC in connection with this service. CCC earns a fee based on a flat percentage of all claims it collects on behalf of our clients. This fee is collected and retained by CCC out of the claims paid by the claim administrator. We do not receive any fees or remuneration in connection with this service. Clients may opt out of this service at any time. If a client opts out, we do not have an obligation to advise or take any action on behalf of a client with regard to class action litigation involving investments held in or formerly held in a client’s account. Clients may call us to discuss anything relative to their investments including any questions they have regarding Chicago Clearing Corporation. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics InTrack Investment Management has adopted a Code of Ethics for all employees of the company that describes our standard of business conduct and fiduciary duty to our clients. Advisers in the firm also adhere to the CFA Code of Ethics. InTrack Investment Management’s employees owe a duty of loyalty, fairness, and good faith to our clients. The Code of Ethics includes provisions relating to the confidentiality of client information, prohibits insider trading, describes personal securities trading procedures, discusses restrictions on the acceptance of significant gifts, and the reporting of certain gifts and business entertainment items. All employees of InTrack Investment Management must acknowledge the terms of the Code of Ethics annually or when amended. Any violation of the code may result in disciplinary action that a designated person or March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  12 committee deems appropriate, including but not limited to a warning, fines, disgorgement, suspension, demotion, or termination of employment. Clients or prospective clients may request a copy of InTrack Investment Management’s Code of Ethics by contacting Myron R. Sopher or Brandon D. Tieso, CFP®. Clients are notified of our Code of Ethics policy prior to or on the day an investment management agreement is signed. Clients are informed annually that InTrack’s Code of Ethics is available to them upon request. Securities and Material Financial Interest This item is not applicable. InTrack Investment Management’s advisers do not buy or sell securities in which the advisers, or any person related to the adviser, hold a material financial interest. Securities Held by Clients and Advisers Advisers may elect to buy or sell an investment that is the same investment held in a client portfolio or that was recommended to a client. A conflict of interest may arise from these transactions; however, as stated in our Code of Ethics, employees of InTrack Investment Management are prohibited from using knowledge about client pending or considered security transactions to profit in their personal accounts. InTrack’s Code of Ethics is designed to assure that personal security transactions, activities, and interests of the employees will not interfere with making decisions in the best interest of advisory clients. To mitigate a conflict of interest, employee accounts trade the same securities with client accounts on an aggregated basis that is consistent with InTrack’s best execution policy. In such circumstances, the accounts will share commission costs associated with their custodial relationship and receive securities at a total average price. InTrack will retain records of the trade order (specifying each participating account) and its allocation. Partially filled orders will be allocated on a pro-rata basis. The Managing Partner reviews trades on a daily basis and would contact the adviser and notify the Chief Compliance Officer with any concerns. Our employees have a fiduciary responsibility to act in the best interest of our clients and to put our clients’ interests in front of their own. Securities Recommended to Clients and Held by Advisers Please see Item 11, C. Item 12: Brokerage Practices Factors in Selecting or Recommending Broker Dealers InTrack Investment Management is a fee-only business. InTrack does not derive income from brokerage equity trades, mutual funds, exchange traded funds, or fixed income securities. Clients do pay trading fees in addition to our investment management fees for some specific investments which have additional fees associated with them, for example, mutual funds and exchange traded funds. The majority of InTrack’s clients use Fidelity as their custodian; however, some clients opt to use a different brokerage firm and may incur higher fees which is explained to them by their adviser. To deem if commissions and best execution policies are reasonable for brokerage firms selected by clients, advisers consider a firm’s commission rates, availability, response time, expertise, relationship with the firm, and other factors covered in our best execution policy. InTrack Investment Management takes advantage of trading platforms, data feeds, mutual funds, software, third-party research, and services of brokerage firms which custody our clients’ assets. Their trading systems enable us to administer client accounts. The brokerage firms’ research is used for the March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  13 benefit of all clients. Education is available to assist with regulatory recommendations or perspectives on best practices. Advisers are invited to seminars to educate themselves on trends or investment ideas. When attending these seminars and depending on the circumstances, InTrack may pay for accommodations and travel; in the past, InTrack has also received compensated travel and accommodations. There is no incentive for advisers to direct trades to any brokerage firm based upon the research or quality of their trading platforms. InTrack might select a brokerage firm based upon their ability to provide research, services, or other technical resources. This is not a conflict of interest since the attributes of a brokerage firm are available to all clients. When choosing a custodian, the entire relationship is considered. Research and Other Soft Dollar Benefits InTrack does not have soft dollar relationships. Brokerage for Client Referrals This item is not applicable. InTrack advisers do not select or recommend broker dealers based on the chance they might provide InTrack Investment Management with a client referral. InTrack’s interest is to make available the best fit for the client in terms of services and value the brokerage firm provides. Directed Brokerage This item is not applicable. InTrack does not routinely accept directed brokerage arrangements. If a client wants to direct a brokerage transaction, advisers allow it but only with the understanding that they may incur additional fees and that the client understands they may not be able to see the transactions on the InTrack Investment Management reports. Item 13: Review of Accounts Periodic Review of Client Accounts For investment advisory clients, we monitor our investment strategies as part of an ongoing process while regular client account reviews are conducted on at least an annual basis. For those clients to whom we provide financial planning and/or consulting services, reviews are conducted on an “as needed” basis or as agreed to within the terms of the agreement. Such reviews are conducted by one of our wealth advisors. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with us and to keep us informed of any changes thereto. We shall contact ongoing investment advisory clients at least annually to review our previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Reporting on a Regular Schedule InTrack produces and sends quarterly reports to each client. The reports are generated using our portfolio management system. Each adviser reviews their client’s report before they are sent. The reports break down investments into asset categories. Equity holdings are reported by industry sector. These reports may include asset performance calculations – net of fees. Item 14: Client Referrals and Other Compensation Economic Benefits As referenced in Item 12 A, 1, above, InTrack Investment Management may receive an indirect economic benefit from service providers. InTrack without cost and/or a discount, may receive support services and/or products from these firms. Conflicts of interest and mitigating those conflicts are also discussed March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  14 above. InTrack Investment Management’s clients do not pay more for investment transactions made and/or assets maintained at service providers as a result of this arrangement. There is no corresponding commitment made by InTrack Investment Management to service providers or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as a result of the above arrangement. Advisers do not receive economic benefits which are defined as sales awards and other prizes. The firm has entered into an arrangement with certain IARs where they receive a percentage of advisory fees from client relationships. This arrangement does not result in higher fees to clients but creates a conflict of interest as described in Item 5 Compensation for Client Referrals This item is not applicable. InTrack Investment Management has received client referrals from current clients, personal friends, and professionals, such as accountants and lawyers. However, InTrack Investment Management does not pay for client referrals and does not receive compensation from any outside entity for referrals. Item 15: Custody This item is not applicable. InTrack Investment Management does not maintain physical custody of client assets. The information in InTrack’s quarterly reports may vary from the custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. InTrack includes a note on the quarterly statements encouraging clients to review the statement with those of their custodian and call with any questions. Item 16: Investment Discretion InTrack Investment Management accepts discretionary accounts. Some clients may choose not to invest in certain assets. In the past, clients have restricted advisers from purchasing stocks from companies that manufacture guns, tobacco, and fossil fuels. If a client chooses to have a discretionary account, InTrack receives discretionary authority from the client and limited powers at the onset of the relationship through the Investment Management Agreement. A discretionary account gives advisers authorization to select the identity and number of securities to be bought or sold. In all cases such discretion is to be exercised in a manner consistent with the client’s Investment Policy Statement. If a client chooses not to invest in certain assets, this is also noted in the Investment Policy Statement. Item 17: Voting Client Securities Voting Client Securities This item is not applicable. InTrack Investment Management does not vote proxies for clients. Authority to Vote Client Securities InTrack Investment Management does not vote proxies on behalf of our clients. Every client has unique views on the conduct of corporate management and shareholder initiatives; therefore, InTrack Investment March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  15 Management does not vote proxies on their behalf. A client’s custodian, a firm acting for the custodian, and in some cases a transfer agent, sends clients solicitations and proxies. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in their portfolios. Clients may call us to discuss anything relative to their investments including any questions they have regarding proxy voting. Item 18: Financial Information InTrack has not been subject to a bankruptcy petition and has no outstanding legal judgments or adverse financial conditions that would be material to any of its clients. InTrack does not require the prepayment of more than $1,200 in fees per client, six months or more in advance. Item 19: Requirements for State-Registered Advisers; Biographies of Executive Officers See Part 2B of Form ADV: Brochure Supplement March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  16 Part 2B of Form ADV: Brochure Supplement Item 1: Cover Page Myron R. Sopher InTrack Investment Management Inc. 1233 Shelburne Road, Suite D6B South Burlington, Vermont 05403 Phone Number: South Burlington (802) 658-0625 March 7, 2025 This brochure supplement provides information about Myron R. Sopher that supplements the InTrack Investment Management brochure. You should have been offered a copy of that brochure. Please contact Brandon D. Tieso, CFP®, if you would like to receive an InTrack Investment Management brochure or if you have any questions about the contents of this supplement. Additional information about Myron R. Sopher is available on the SEC’s website at www.adviserinfo.sec.gov March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  17 Item 2: Educational Background and Business Experience Myron R. Sopher Date of Birth: May 6, 1950 Formal Education: University of Vermont, BA 1973 Psychology/Business Background: • Sopher Investment Management/InTrack Investment Management Inc., Burlington, Vermont, Founder of the firm in 1992, President and now Managing Partner Business Background Prior to 1992: • Burlington Industries, New York City, National Accounts Manager • American Hospital Supply Corporation, Inc., Evanston, Illinois, National Accounts Manager for the American Convertors Division • Herman Miller, Inc., Zeeland, Michigan, Health Science Division National Accounts Manager • Computer Aided Planning, Vice President of Sales Item 3: Disciplinary Information This item is not applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. There is no disciplinary information to disclose for Myron R. Sopher. Item 4: Other Business Activities This item is not applicable. Myron R. Sopher is not actively engaged in any investment related business, occupation, or pending activity for compensation as described in this section. Item 5: Additional Compensation This item is not applicable. Myron R. Sopher does not receive economic benefit from providing advisory service to someone who is not a client. Item 6: Supervision The employees and advisers of InTrack Investment Management utilize supervision consistent with InTrack Investment Management’s policies and procedures manual. InTrack Investment Management’s policies and procedures comply with the supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act. InTrack Investment Management’s Chief Compliance Officer is primarily responsible for implementation of InTrack Investment Management’s policies and procedures. Matthew D. Johnson, Partner and Portfolio Manager [phone number (802) 658- 0625], supervises Myron R. Sopher. Item 7: Financial Events Myron R. Sopher has not been found liable in an arbitration claim, civil or administrative proceeding for any of the wrongdoing listed in this item including but not limited to fraud, theft, or embezzlement. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  18 Part 2B of Form ADV: Brochure Supplement, continued Item 1: Cover Page Matthew D. Johnson InTrack Investment Management Inc. 1233 Shelburne Road, Suite D6B South Burlington, Vermont 05403 Phone Number: South Burlington (802) 658-0625 March 7, 2025 This brochure supplement provides information about Matthew D. Johnson that supplements the InTrack Investment Management brochure. You should have been offered a copy of that brochure. Please contact Brandon D. Tieso, CFP®, if you would like to receive an InTrack Investment Management brochure or if you have any questions about the contents of this supplement. Additional information about Matthew D. Johnson is available on the SEC’s website at www.adviserinfo.sec.gov March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  19 Item 2: Educational Background and Business Experience Matthew D. Johnson Date of Birth: September 15, 1974 Formal Education: St. Lawrence University, BA Economics, Environmental Sciences Background: • Sopher Investment Management/InTrack Investment Management Inc., Burlington, Vermont, Portfolio Manager, now Portfolio Manager and Partner Business Background since 2005: • Bombardier Aerospace, Colchester, Vermont, Senior Credit Analyst • Stratevest Group, Burlington, Vermont • State Street Bank, Quincy, Massachusetts, Portfolio Accountant • Putnam Investments, Braintree, Massachusetts, Mutual Fund Accountant Professional Designations: Chartered Financial Analyst (CFA), September 5, 2003 The Chartered Financial Analyst (CFA) designation is a globally respected, graduate- level investment credential established in 1952 and awarded by the CFA Institute. The CFA Institute is the largest global association of investment professionals. There are currently more than 160,000 CFA charter holders working in 160 markets. Regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements. To earn the designation candidates must pass three sequential, six-hour examinations, which is difficult and requires extensive study (successful candidates report spending an average of 300 hours of study per level), have at least four years of qualified professional investment experience, and join the CFA Institute as members. The exams test proficiency in a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed income and equity analysis, alternative and derivative investment, economics, financial reporting standards, portfolio management, and wealth planning. The curriculum is constantly being updated by experts. A member of the CFA Institute must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. This code of conduct, which is enforced through an active professional conduct program, requires CFA Charter holders to: • Place their clients’ interests ahead of their own. • Maintain independence and objectivity. • Act with integrity. • Maintain and improve their professional competence. • Disclose conflicts of interest and legal matters. To learn more about the CFA charter, visit www.cfainstitute.org Item 3: Disciplinary Information This item is not applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  20 supervised person providing investment advice. There is no disciplinary information to disclose for Matthew D. Johnson. Item 4: Other Business Activities This item is not applicable. Matthew D. Johnson is not actively engaged in any investment related business, occupation, or pending activity for compensation as described in this section. Item 5: Additional Compensation Matthew D. Johnson may receive additional compensation related to overall performance factors stated in his job description, which includes investment knowledge, leadership, and client and prospect interaction. Matthew does not receive economic benefit from providing advisory service to someone who is not a client. Item 6: Supervision The employees and advisers of InTrack Investment Management utilize supervision consistent with InTrack Investment Management’s policies and procedures manual. InTrack Investment Management’s policies and procedures comply with the supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act. InTrack Investment Management’s Chief Compliance Officer is primarily responsible for implementation of InTrack Investment Management’s policies and procedures. Brett C. Peltzer, Partner and Portfolio Manager [phone number (802) 236-1403], supervises Matthew D. Johnson. Item 7: Financial Events A. This item is not applicable. B. This item is not applicable. Matthew D. Johnson has not been found liable in an arbitration claim, civil or administrative proceeding for any of the wrongdoing listed in this item including but not limited to fraud, theft or embezzlement. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  21 Part 2B of Form ADV: Brochure Supplement, continued Item 1: Cover Page Brett C. Peltzer InTrack Investment Management Inc. P.O. Box 1563, 289 Main Street Norwich, Vermont 05055 Phone Number: Norwich (802) 649-1666 March 7, 2025 This brochure supplement provides information about Brett C. Peltzer that supplements the InTrack Investment Management brochure. You should have been offered a copy of that brochure. Please contact Brandon D. Tieso, CFP®, if you would like to receive an InTrack Investment Management brochure or if you have any questions about the contents of this supplement. Additional information about Brett C. Peltzer is available on the SEC’s website at www.adviserinfo.sec.gov March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  22 Item 2: Educational Background and Business Experience Brett C. Peltzer Date of Birth: January 14, 1960 Formal Education: University of Vermont, BS and MBA Business Background: • Peltzer Capital Management/InTrack Investment Management Inc., Norwich, Vermont, President, now Portfolio Manager and Partner Business Background Prior to 2005: • Ledyard National Bank, Hanover, New Hampshire, Senior Investment Adviser • Chittenden Bank, Burlington, Vermont, Trust Investment Officer • First Vermont Bank, Brattleboro, Vermont, Trust Investment Officer • Merchants Bank and Trust Company, Burlington, Vermont, Consumer Loan Officer Professional Designations: Chartered Financial Analyst (CFA), September 5, 1990 Certified Money Coach, June 1, 2020, Money Coaching Institute, LLC The Chartered Financial Analyst (CFA) designation is a globally respected, graduate- level investment credential established in 1952 and awarded by the CFA Institute. The CFA Institute is the largest global association of investment professionals. There are currently more than 160,000 CFA charter holders working in 160 markets. Regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements. To earn the designation candidates must pass three sequential, six-hour examinations, which is difficult and requires extensive study (successful candidates report spending an average of 300 hours of study per level), at least four years of qualified professional investment experience, and join the CFA Institute as members. The exams test proficiency in a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed income and equity analysis, alternative and derivative investment, economics, financial reporting standards, portfolio management, and wealth planning. The curriculum is constantly being updated by experts. A member of the CFA Institute must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. This code of conduct, which is enforced through an active professional conduct program, requires CFA Charter holders to: • Place their clients’ interests ahead of their own. • Maintain independence and objectivity. • Act with integrity. • Maintain and improve their professional competence. • Disclose conflicts of interest and legal matters. To learn more about the CFA charter, visit www.cfainstitute.org. Item 3: Disciplinary Information March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  23 This item is not applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. There is no disciplinary information to disclose for Brett C. Peltzer. Item 4: Other Business Activities This item is not applicable. Brett C. Peltzer is not actively engaged in any investment related business, occupation or pending activity for compensation as described in this section. Item 5: Additional Compensation Brett C. Peltzer may receive additional compensation related to overall performance factors stated in his job description, which includes investment knowledge, leadership, and client and prospect interaction. Brett does not receive economic benefit from providing advisory service to someone who is not a client. Item 6: Supervision The employees and advisers of InTrack Investment Management utilize supervision consistent with InTrack Investment Management’s policies and procedures manual. InTrack Investment Management’s policies and procedures comply with the supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act. InTrack Investment Management’s Chief Compliance Officer is primarily responsible for implementation of InTrack Investment Management’s policies and procedures. Myron R. Sopher, Managing Partner [phone number (802) 658-0625], supervises Brett C. Peltzer. Item 7: Financial Events Brett C. Peltzer has not been found liable in an arbitration claim, civil or administrative proceeding for any of the wrongdoing listed in this item including but not limited to fraud, theft, or embezzlement. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  24 Part 2B of Form ADV: Brochure Supplement, continued Item 1: Cover Page Matthew S. Sopher InTrack Investment Management 1233 Shelburne Road, Suite D6B South Burlington, Vermont (802) 658-0625 March 7, 2025 This brochure supplement provides information about Matthew S. Sopher that supplements the InTrack Investment Management brochure. You should have been offered a copy of that brochure. Please contact Brandon D. Tieso, CFP®,, if you would like to receive an InTrack Investment Management brochure or if you have any questions about the contents of this supplement. Additional information about Matthew S. Sopher is available on the SEC’s website at www.adviserinfo.sec.gov March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  25 Item 2: Educational Background and Business Experience Matthew S. Sopher Date of Birth: October 4, 1985 Formal Education: Lehigh University, Finance BA; Duke University, M.B.A. • InTrack Investment Management Inc., Burlington, Vermont, Portfolio Manager, now Portfolio Manager and Partner Business Background: • Principal, US Strategic Initiatives Leader, Mercer • Senior Manager, Strategic Initiatives, Guardian Life • Analyst, Sopher Investment Management • Senior Underwriter, American Insurance Group Item 3: Disciplinary Information This item is not applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. There is no disciplinary information to disclose for Matthew S. Sopher. Item 4: Other Business Activities This item is not applicable. Matthew S. Sopher is not actively engaged in any investment related business, occupation, or pending activity for compensation as described in this section. Item 5: Additional Compensation Matthew S. Sopher may receive additional compensation related to overall performance factors stated in his job description, which includes investment knowledge, leadership, and client and prospect interaction. Matthew does not receive economic benefit from providing advisory service to someone who is not a client. Item 6: Supervision The employees and advisers of InTrack Investment Management utilize supervision consistent with InTrack Investment Management’s policies and procedures manual. InTrack Investment Management’s policies and procedures comply with the supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act. InTrack Investment Management’s Chief Compliance Officer is primarily responsible for implementation of InTrack Investment Management’s policies and procedures. Matthew D. Johnson, Partner and Portfolio Manager supervises Matthew S. Sopher. Item 7: Financial Events A. This item is not applicable. B. This item is not applicable. Matthew S. Sopher has not been found liable in an arbitration claim, civil or administrative proceeding for any of the wrongdoing listed in this item including but not limited to fraud, March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  26 theft or embezzlement. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  27 Part 2B of Form ADV: Brochure Supplement, continued Item 1: Cover Page Brandon D. Tieso, CFP® InTrack Investment Management 1233 Shelburne Road, Suite D6B South Burlington, Vermont (802) 658-0625 March 7, 2025 This brochure supplement provides information about Brandon D. Tieso, CFP®, that supplements the InTrack Investment Management brochure. You should have been offered a copy of that brochure. Please contact Brandon D. Tieso, CFP®, if you would like to receive an InTrack Investment Management brochure or if you have any questions about the contents of this supplement. Additional information about Brandon D. Tieso, CFP®, is available on the SEC’s website at www.adviserinfo.sec.gov March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure  28 Item 2: Educational Background and Business Experience Brandon D. Tieso, CFP® Date of Birth: June 27, 1997 Formal Education: College of the Holy Cross, BA Political Science; University of Oxford (VSP) • InTrack Investment Management Inc., Burlington, Vermont, Financial Advisor and Chief Compliance Officer Business Background: • Licensed Private Investigator, VTPrivateye • Account Executive and Producer, Howie Carr Network Item 3: Disciplinary Information This item is not applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. There is no disciplinary information to disclose for Brandon D. Tieso, CFP® Item 4: Other Business Activities This item is not applicable. Brandon D. Tieso, CFP®, is not actively engaged in any investment related business, occupation, or pending activity for compensation as described in this section. Item 5: Additional Compensation Brandon D. Tieso, CFP® may receive additional compensation related to overall performance factors stated in his job description, which includes investment knowledge, leadership, and client and prospect interaction. Matthew does not receive economic benefit from providing advisory service to someone who is not a client. Item 6: Supervision The employees and advisers of InTrack Investment Management utilize supervision consistent with InTrack Investment Management’s policies and procedures manual. InTrack Investment Management’s policies and procedures comply with the supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act. InTrack Investment Management’s Chief Compliance Officer is primarily responsible for implementation of InTrack Investment Management’s policies and procedures. Matthew S. Sopher, Partner and Portfolio Manager supervises Brandon D. Tieso, CFP®. Item 7: Financial Events A. This item is not applicable. B. This item is not applicable. Brandon D. Tieso, CFP® has not been found liable in an arbitration claim, civil or administrative proceeding for any of the wrongdoing listed in this item including but not limited to fraud, theft or embezzlement. March 7, 2025 InTrack Investment Management, Inc. Form ADV Part 2A – Disclosure Brochure