OBERMEYER WOOD INVESTMENT COUNSEL, LLLP

Part 2A of Form ADV: Firm Brochure Item 1 C Obermeyer Wealth Partners Obermeyer Place 501 Rio Grande Place, Suite 107 Aspen, Colorado 81611 200 Columbine Street, Suite 600 Denver, CO 80206 Telephone: (970) 925-8747 Email: info@obermeyerwood.com Web Address: www.obermeyerwealth.com Last updated: 03/24/2025 This brochure provides information about the qualifications and business practices of Obermeyer Wealth Partners (Obermeyer Wealth). If you have any questions about the contents of this brochure, please contact us at (970) 925- 8747 or info@obermeyerwealth.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. Obermeyer Wealth Partners is a Registered Investment Adviser. Registration of an investment adviser does not imply any level of skill or training. In deciding whether to retain an adviser, you should consider its written materials and any conversations you have with the adviser. More information about Obermeyer Wealth is available on the SEC’s website at www.adviserinfo.sec.gov. You can use a unique identifying number, known as a CRD number, to find our firm there. Our firm’s CRD number is 110069. Item 2 Material Changes We have made the following material changes to our brochure. This section identifies only material changes since our last annual update, which we filed on March 28, 2024. • Effective December 17, 2024, Obermeyer Wood Investment Counsel, LLLP, updated its brand name to Obermeyer Wealth Partners and is now doing business under the new name. Please see Item 4 for more information. 1  Item 3 Table of Contents Item 1 Cover Page ........................................................................................................................................................... 1 Item 2 Material Changes ................................................................................................................................................. 1 Item 3 Table of Contents ................................................................................................................................................ 2 Item 4 Advisory Business ................................................................................................................................................ 3 Item 5 Fees and Compensation ...................................................................................................................................... 7 Item 6 Performance-Based Fees and Side-by-Side Management .................................................................................. 9 Item 7 Types of Clients ................................................................................................................................................... 9 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 ......................................................................................................................................... 14 Item 14 Client Referrals and Other Compensation ...................................................................................................... 14 Item 15 Custody ........................................................................................................................................................... 16 Item 16 Investment Discretion ..................................................................................................................................... 16 Item 17 Voting Client Securities ................................................................................................................................... 17 Item 18 Financial Information ...................................................................................................................................... 17 2  Item 4 Advisory Business Obermeyer Wealth Partners is an SEC-registered investment adviser with its principal place of business in Colorado. Obermeyer Wealth began conducting business on October 1, 2014, under the name Obermeyer Wood Investment Counsel, LLLP. In December 2024, the firm updated its name and began operating as Obermeyer Wealth Partners. All other aspects of the business, including ownership, corporate structure, and services offered, remain the same. The firm’s principal shareholders (i.e., those individuals or entities controlling 25% or more of this LLLP) are listed below: • Walter Raymond Obermeyer, Co-Founder and Chairman. A large portion of Mr. Obermeyer’s interest is held through Walter R. Obermeyer Holdings, Inc., of which he is the chief executive officer. Obermeyer Wealth was formed as Obermeyer Wood Investment Counsel in 2014 through the merger of the former firms Obermeyer Asset Management Company and Wood Investment Counsel, LLC. The firms operated with similar investment philosophies, types of clients, and geographic areas, and had a mutual respect for how each conducted business and served clients. The purpose of the merger was to leverage each other’s skills and to enhance the capability to serve the investment needs of both firms’ clients. The merger transaction closed on September 30, 2014, and the merged entity began operations on October 1, 2014, with an Aspen office located at 501 Rio Grande Place, Suite 107, Aspen, CO 81611, and a Denver office at 55 Madison Street, Suite 680, Denver, CO 80206. The Denver office moved to 200 Columbine Street, Suite 600, Denver, CO 80206 on August 24, 2015. On January 1, 2024, Obermeyer Wealth acquired Booth Creek Capital Management, LP, an independent investment advisor based in Vail, Colorado. Booth Creek’s founder and portfolio manager, Adam M. Savin, joined Obermeyer Wealth as Partner and Vice President, Investments. Booth Creek managed investments with a dividend-oriented strategy, and that will continue to be an available strategy for Obermeyer Wealth clients going forward. Obermeyer Wealth offers the following advisory services to our clients: Investment Management: Our firm provides continuous investment management to clients based on their individual needs. We work with each client to establish goals and objectives through discussions about that client’s particular circumstances. We then develop a client’s investment objective and create and manage a portfolio based on that objective. During our data-gathering process, we learn the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. We often collaborate with our clients’ other professional service providers as we work to understand their financial circumstances. We regularly encourage clients to promptly inform us of any changes in their financial situation or investment goals. We are long-term investors focused primarily on common stocks, both domestic and foreign, and, as appropriate, various types of bonds, mutual funds, ETFs and alternatives. Because some types of investments involve additional risks, we will only recommend and implement them when consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and suitability. Account supervision is guided by the client’s stated objectives (e.g., all-equity, growth, growth and income, or income). Financial Planning: As an integrated part of our investment management services, we offer financial planning. We offer the following financial planning services depending on the client’s situation: cash flow analysis, budgeting, retirement needs, asset allocation consulting, education funding, tax efficiency, charitable giving, estate 3  considerations, wealth transfer, and other goals or special needs. With respect to our limited financial planning services, clients are free to accept or reject any of our recommendations, and clients alone have the authority to implement any of our recommendations. With respect to estate and tax planning, our role is limited to consulting and facilitating with clients and their other professional advisors. We do not offer legal or tax advice. Tax Preparation Services: Obermeyer Wealth makes available to its clients the opportunity to obtain tax preparation and related accounting services from a CPA firm (“CPA”) selected by Obermeyer Wealth. Obermeyer Wealth and CPA are separate unaffiliated businesses. Clients who choose to use CPA’s services will generally incur a CPA fee (separate from and in addition to Obermeyer Wood’s investment advisory fee). Obermeyer Wood shall not receive any portion of the fee payable by the client to CPA. For clients with more than $5million of assets under our management, a credit toward CPA’s fee may be provided, the amount of which will depend upon the amount of the client’s assets under management. If the client chooses not to use CPA (the client is under no obligation to do so), no credit or discount will be provided against our investment advisory fee. Please Note: Obermeyer Wood is not a CPA, accounting, or tax preparation firm, and no portion of our services, including those provided in conjunction with CPA, should be considered as such, or the substitute for your engagement of your own CPA, accounting, or tax preparation professionals. Please Also Note: For clients whose situation and needs require an enhanced level of specific services or expertise, you should consider continuing with your current professionals or comparing other alternatives. No client is under any obligation to use CPA. Estate Planning Services: As part of the financial planning process, Obermeyer Wealth makes available to its clients the opportunity to consider or create various types of basic estate planning documents (such as simple wills and trusts) in conjunction with an estate planning software platform (“Planner”). Planner and Obermeyer Wealth are separate unaffiliated businesses. All documents are provided using Planner’s estate planning platform. The client will pay an additional fee to Planner for use of Planner’s service; the fee is usually $750–$1250. In certain circumstances, we may choose to provide a client with a credit to offset Planner’s fee. Please Note: Obermeyer Wealth is not a law firm, and no portion of its services, including those provided in conjunction with Planner, should be considered as legal advice, or as a substitute for the client’s engagement of legal counsel. Please Also Note: For clients whose situation and needs require more sophisticated and customized estate planning advice or documents, the engagement of legal counsel should be considered. No client is under any obligation to use Planner. Trustee Services: Although Obermeyer Wealth is not a registered trust company, on occasion and upon specific request our advisers will act individually as trustee for client accounts. This arrangement can present conflicts of interest and results in the firm having custody of clients assets (see Item 9, below, for more information). Trustee services are not included as part of our standard investment advisory agreement and will be subject to an additional agreement and an additional fee. Each request for us to perform trustee services will be considered on a case-by- case basis. Please note: No client is under any obligation to use an Obermeyer Wealth representative as trustee. Investment Research and Consulting: On occasion and upon specific request, Obermeyer Wealth will perform investment research and consulting services separate and apart from our normal investment process for clients. This service is intended to evaluate private investments to determine quality and suitability. This service is not included in our standard investment advisory agreement and will be subject to an additional fee. Each request for investment consulting services will be considered on a case-by-case basis. Please note: No client is under any obligation to use Obermeyer Wealth investment consulting services. Private Investments: For certain eligible clients, we will offer private investment vehicles. These vehicles have management fees additional to what you pay us. You will receive additional disclosure documents on the access fund or private fund if we purchase these for you. 4  Secured Lending: On occasion, clients request a margin loan or other loan secured by their portfolio. Margin loans and secured loans typically incur additional expenses such as interest costs. When a client intends to carry a margin loan balance for an extended period of time, our policy is to open a separate account to house the margin loan separate from the managed securities portfolio. Both private investments and margin or secured loans are sophisticated investment strategies and carry additional costs. Obermeyer Wealth’s Chief Compliance Officer, Charlton Rugg, is available to address any questions that a client or prospective client has about private investments, margin loans, or secured loans. As of December 31, 2024, we were actively managing approximately $2,605,000,000 of clients’ assets on a discretionary basis. Limitations of Financial Planning and Non-Investment Consulting or Referral Services: To the extent requested by the client, Obermeyer Wealth will generally provide limited financial planning and related consulting services regarding non-investment-related matters, such as tax and estate planning, insurance, etc. Please Also Note: Obermeyer Wealth does not serve as an attorney, accountant, or insurance agent, and you should not construe any part of our services as such. Accordingly, Obermeyer Wealth does not prepare legal documents, prepare tax returns, or sell insurance products. Upon request, we can refer a client to other professionals such as attorneys, accountants, or insurance agents. The client retains absolute discretion to make any engagement decisions and has no obligation to engage any professional to whom we make a referral. The client is free to accept or reject any recommendation from Obermeyer Wealth or its representatives. If the client engages any professional (i.e., attorney, accountant, insurance agent, etc.), whether or not referred by Obermeyer Wealth, and a dispute later arises related to that engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not Obermeyer Wealth, is responsible for the quality and competency of the services provided. Please Note—Retirement Rollovers and Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan and may choose a combination of these options: (I) leave the money in the former employer’s plan, if permitted, (ii) roll the assets into a new employer’s plan, if one is available and rollovers are permitted, (iii) roll the assets i n to an Individual Retirement Account (IRA), or (iv) cash out the account value (which could result in adverse tax consequences). If Obermeyer Wealth recommends that a client roll over retirement plan assets into an account to be managed by Obermeyer Wealth, that recommendation creates a conflict of interest when Obermeyer Wealth will earn new or increased compensation from the rollover. When acting in such capacity, Obermeyer Wealth serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by Obermeyer Wealth. Obermeyer Wealth’s Chief Compliance Officer, Charlton Rugg, is available to address any questions that a client or prospective client has about the potential for conflict of interest presented by such rollover recommendations. Client Obligations: In performing our services, Obermeyer Wealth shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is responsible for promptly notifying Obermeyer Wealth of changes in the client’s financial situation or investment objectives so that we can review, evaluate, and potentially revise our recommendations or services. Please Note—Investment Risk: Different types of investments involve different degrees of risk. Clients should not assume that future performance of any specific investment or investment strategy (including the investments and 5  investment strategies recommended or undertaken by Obermeyer Wealth) will be profitable or achieve any specific performance level. Portfolio Activity: Obermeyer Wealth has a fiduciary duty to provide services consistent with the client’s best interest. Obermeyer Wealth will review client portfolios on an ongoing basis to determine whether any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions or withdrawals, or a change in the client’s investment objective. Based upon these factors, there can be extended periods of time when Obermeyer Wealth determines that changes to a client’s portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note—Cash Positions: Obermeyer Wealth continues to treat cash as an asset class. As such, all cash positions (money markets, etc.) are included as assets under management for purposes of calculating Obermeyer Wealth’s advisory fee, unless specifically agreed otherwise by Obermeyer Wealth. At any specific point in time, depending upon perceived or anticipated market conditions or events, Obermeyer Wealth may keep cash positions for defensive purposes. While assets are kept in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Obermeyer Wealth’s advisory fee could exceed the interest paid by the client’s money market fund. Obermeyer Wealth’s Chief Compliance Officer, Charlton Rugg, remains available to address any questions that a client or prospective client has about the above fee billing practice. Unaffiliated Private Investment Funds: Obermeyer Wealth also provides investment advice regarding private investment funds. Obermeyer Wealth, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts, and fees, including incentive compensation) is in the fund’s offering documents. Obermeyer Wealth’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client decides to invest in an unaffiliated private fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Obermeyer Wealth calculating its investment advisory fee. Obermeyer Wealth’s fee shall be in addition to the fund’s fees. Obermeyer Wealth’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including but not limited to potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client owns, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he or she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note, Valuation: If Obermeyer Wealth displays private investment funds owned by the client on any supplemental account reports prepared by Obermeyer Wealth, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if the fund has not provided an updated valuation after purchase, the valuation shall reflect the initial purchase price until the fund provides an updated valuation. Please Also Note: As a result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, Obermeyer Wealth shall calculate its fee based upon the most recent value provided by the fund sponsor. 6  Item 5 Fees and Compensation Obermeyer Wealth’s annual investment management fee is prorated and paid quarterly in arrears, based on the average daily value of the portfolio and the fee schedule noted below. Unless otherwise directed by the client, Obermeyer Wealth’s management fee shall be debited from the client’s account on a quarterly basis in accordance with required SEC procedures. Obermeyer Wealth prefers a $1 million per client minimum for investment management services. Obermeyer Wealth occasionally charges a lesser management fee or waives the $1 million client minimum based on certain criteria (e.g., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, historical relationship, related accounts, account composition, negotiations with client, accounts referred to us by another professional). The investment management fee will be charged as a percentage of the market value of assets under management, according to the following schedule: Assets Under Management Annual Fee First $10 million Next $10 million Additional amounts above $20 million 1.0% 0.75% 0.5% Obermeyer Wealth’s accounting and billing systems use pricing information provided by approved custodians of Obermeyer Wealth’s client assets, or by an independent third-party pricing service. This information is used to assess management fees. Obermeyer Wealth will send you a client statement quarterly. Your custodian will send you a client statement quarterly or monthly. On occasion, the statement from your custodian will reflect slightly different prices for certain securities than the statement from Obermeyer Wealth. We encourage you to compare your account statements sent directly to you from your custodian with those that we provide. Clients will incur brokerage commission charges when certain buy or sell transactions are executed. Some transactions have no fee. Some of the custodians we work with also charge custodial fees for recordkeeping and safekeeping of client assets; some do not. For more information on brokerage practices, please see Item 12. Because Obermeyer Wealth was created as a merger of predecessor firms, certain clients have different fee schedules or calculation methods than described above. GENERAL INFORMATION Termination of the Advisory Relationship: A client can cancel an investment advisory agreement at any time for any reason by delivering written notice. Obermeyer Wealth can cancel at any time according to the terms specified in the investment advisory agreement. Mutual Fund and ETF Fees: Most mutual funds and exchange-traded funds are available directly to the public. Thus, a client could invest in a mutual fund directly, without engaging Obermeyer Wealth. In that case, the client would not receive our investment advisory services. In addition to Obermeyer Wealth’s investment management fee described above, and transaction and custodial fees discussed below in Item 15, clients will also incur, relative to all mutual fund and ETF purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Private Investment Fees: A client who chooses to invest in a private investment vehicle through Obermeyer Wealth will pay additional fees. Typically, in addition to Obermeyer Wealth’s fee, the client will pay fees to the fund manager 7  that include administration and management fees, incentive fees or carried interest, and an additional administration or management fee to the access fund provider. We will provide additional more specific disclosures and engage in additional discussions before investing any client funds in private investments. Tradeaway Fees: Relative to its discretionary management services, when beneficial to the client, individual equity or fixed-income transactions may be effected through broker-dealers with whom Obermeyer Wealth or the client have entered into arrangements for prime brokerage clearing services. In this event, the client generally will incur both the transaction fee charged by the executing broker-dealer and a “tradeaway” fee charged by the custodian of the client account. Bank custodians do not charge tradeaway fees. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians or broker-dealers, including but not limited to any transaction charges such as trading costs. Clients will also be responsible for any interest charges or other costs associated with margin loans or other secured loans. We have contracted with a service provider to provide securities class-action services to our clients with accounts at certain custodians. The service provider will conduct research and file claims on behalf of those clients in securities class actions in which they might be entitled to recovery. The service provider will keep 15% of any recovery as its fee for services. Clients can opt out of this service. If clients opt out, they will be solely responsible for filing claims in any class action in which they may be eligible for recovery. ERISA Accounts: Obermeyer Wealth is a fiduciary to advisory clients that are employee benefit plans or have individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (ERISA). As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Obermeyer Wealth charges fees only for investment advice about products for which our firm and related persons do not receive any commissions or 12b-1 fees. As a matter of practice, we do not accept 12b-1 fee compensation. Fee Dispersion: Obermeyer Wealth, in its discretion, will sometimes reduce its investment advisory fee, charge a flat fee, waive its fee entirely, or charge fees on a different interval based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please Note: As a result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. Margin Accounts—Risks and Conflict of Interest: Obermeyer Wealth does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities or for other non-investment borrowing purposes. The broker or custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. Should a client specifically request to use margin, Obermeyer Wealth will consider the entire market value of the margined assets as managed; that is, Obermeyer Wealth will not deduct the margin loan value from the managed asset value when computing its advisory fee. As a result, a conflict of interest arises since Obermeyer Wealth may have an economic disincentive to recommend that the client terminate the use of margin. Please Note: The use of margin can cause significant adverse financial consequences in the event of a market correction. 8  ANY QUESTIONS: Obermeyer Wealth’s Chief Compliance Officer, Charlton Rugg, is available to address any questions that a client or prospective client has about advisory fees, fee dispersion, or margin loans. Item 6 Performance-Based Fees and Side-by-Side Management Obermeyer Wealth does not charge any performance-based fees (fees based on a share of capital gains or on capital appreciation of the assets of a client). Item 7 Types of Clients Obermeyer Wealth provides advisory services to the following types of clients: Individuals (other than high-net-worth individuals) • High-net-worth individuals • • Trusts • Pension and profit-sharing plans • Charitable organizations and endowments • Corporations or other businesses • Government entities Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our investment strategy is based on the well-documented observation that long-term investments in carefully selected equity investments have provided attractive long-term returns that have exceeded general inflation and fixed income returns. In addition, we will suggest a ratio of equity investments, fixed income (bonds), and cash that seems appropriate to the client’s individual circumstances and the relative long-term attractiveness of the various asset classes. We monitor a wide variety of variables including broad economic trends and financial markets worldwide in order to identify both risks and long-term opportunities. However, economic outcomes and financial market prices are notoriously unpredictable. Thus, our equity investment decisions are based primarily on long-term, fundamental, company-specific considerations, not market timing or economic forecasts. Our investment team meets regularly to review existing holdings and evaluate new investments. Our core investment philosophy integrates the identification of companies that have attractive fundamental prospects with a discipline of investing in them only when the company’s stock appears undervalued. We believe this approach can provide attractive long-term returns while helping to mitigate risk. Investing in securities can involve a high degree of risk or loss of investment. Many factors can create a loss, including company-specific adverse developments, inaccurate or incomplete financial statements, or broad economic or financial issues. Financial markets can be volatile and unpredictable. In its investment selection process, Obermeyer Wealth conducts extensive independent research on companies for potential investment. In addition, we use a variety of other sources including industry data, economic information, and research from various brokerage firms as well as independent sources. We regularly review the operations and long-term strategies of the companies in which we invest and, in many cases, conduct interviews with management. 9  We seek to identify companies that possess some or all of the following characteristics: • Access to a growing market • A unique product, service, or asset that is difficult to duplicate • Above-average profitability that can internally finance the growth of the business • Able management who are themselves significant shareholders and have demonstrated that they act in the best interests of all shareholders • Attractive return of capital through dividends or share repurchase Portfolios are constructed primarily from a combination of stocks and bonds that have been thoroughly researched and meet the criteria for quality, growth, and valuation. In addition to stocks and bonds, we use mutual funds and ETFs to augment or construct some client portfolios. In our search for attractive long-term investment opportunities, we are guided by the quality of the company and the valuation of the stock but are not confined by arbitrary definitions of investment style or company size. We believe this flexible approach is in the best interest of our clients as it considerably expands the universe of potential investments. We pursue a long-term investment philosophy. Therefore, investments are made with a several-year time horizon, and turnover tends to be low. As a result, trading expenses and current-period tax payments, where relevant, may be lowered. Valuation plays a critical role in our investment process. We consider a variety of parameters including the earnings, cash flow, dividends, growth, and financial strength of a company, and we consistently apply this valuation discipline when making an investment decision. In addition, we consider comparable company valuations, market transactions between industry participants, and long- term net-asset-value calculations. In addition to common stocks and bonds, we invest as appropriate in mutual funds and ETFs to augment our investments. One example of this is that we may select one or more funds that track particular indices or sectors in order to give clients exposure to the desired investment opportunities. We examine the long-term experience and investment record of the mutual fund or ETF to evaluate the fund’s ability to successfully invest over the long term and in different economic conditions. We also review the underlying assets in a mutual fund or ETF to determine whether there is significant overlap in the underlying investments held in other funds or as individual securities in the client’s portfolio. We also monitor the mutual funds and ETFs to determine whether they are continuing to follow their stated investment strategy. A risk of mutual-fund and ETF analysis is that, as in all securities investments, past performance does not predict future results. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding less suitable for the client’s portfolio. 10  In summary, Obermeyer Wealth believes our value-oriented philosophy, combined with extensive independent research, serves well the objectives of clients, which include both the preservation of their capital and growth of income and principal. Nevertheless, losses can and do occur. Private Investments. We use private investments as part of our investment strategy only when specifically discussed with an eligible client in advance. Private investments generally have higher costs than publicly available mutual funds or ETFs. Margin Transactions. We do not use margin purchases as part of our investment strategy unless specifically requested by and discussed with a client in advance. If a client intends to carry a margin balance as a secured loan, we recommend the client open a separate account to hold the margin balance. Risks for All Forms of Analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that inaccurate or misleading information will compromise our analysis. Moreover, securities are often priced on factors that cannot be predicted, such as emotional and behavioral factors of other market participants. Risk of Loss. Securities investments are not guaranteed, and you may lose some or all of your money on any of your investments. We ask that you communicate with us to help us understand your tolerance for risk. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Obermeyer Wealth and our management personnel have no reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations Our firm and our related persons are not engaged in other financial industry activities and have no other industry affiliations that create any conflicts of interest or are material to our advisory business. Item 11 Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Obermeyer Wealth requires its employees to comply with applicable federal securities laws as well as its Code of Ethics, which sets forth high ethical standards of business conduct. Obermeyer Wealth and our personnel owe a duty of loyalty, fairness, and good faith toward our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the code. It is our policy that all employees must receive prior approval before making a purchase or sale of certain types of securities. In addition, employees are not allowed to purchase or sell any security immediately before a transaction in that security is implemented for an advisory account, thereby preventing employees from benefiting from transactions placed on behalf of advisory accounts. 11  Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s employees. Among other things, our Code of Ethics also requires prior approval for acquisition of securities in a limited offering (e.g., private placement) or an IPO (Initial Public Offering). Our code also provides for oversight, enforcement, and recordkeeping provisions. Obermeyer Wealth’s Code of Ethics further includes the firm’s policy prohibiting the use of material, non-public information. While we do not believe that we have any special access to non-public information, we remind all employees that such information may not be used in a personal or professional capacity. Obermeyer Wealth and individuals associated with our firm are prohibited from engaging in principal transactions and agency cross transactions. Principal transactions are those in which Obermeyer Wealth would directly purchase securities from or sell securities to our clients; this practice could leave our clients in an unfair position as we would determine the security pricing. Agency cross transactions are those in which Obermeyer Wealth would arrange the purchase or sale of securities between two or more clients; this practice pits buyer versus seller in determining prices. Obermeyer Wealth will not cross trades between client accounts. Our Code of Ethics is designed to ensure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. A copy of our Code of Ethics is available on request. Item 12 Brokerage Practices To fulfill our obligation to achieve best execution for our clients, Obermeyer Wealth endeavors to select those brokers or dealers that will provide the best services for the best value. The reasonableness of commissions is based on the broker’s stability, reputation, and ability to provide professional services including trade execution, competitive commission rates and prices, research, trading platform, and other services that will help us in providing investment management services to clients. We sometimes recommend or use a broker that provides useful securities transaction services even though a broker that offers less securities transaction assistance might charge a lower commission. Not every client benefits equally from the securities transaction services a broker provides. Obermeyer Wealth no longer has any soft dollar arrangements with any of our executing brokers. This means that Obermeyer Wealth now pays directly for all research instead of using client brokerage commissions to pay for research or brokerage services. We buy research and other news, information, and analysis services directly from providers such as Bloomberg L.P., FactSet Research Systems Inc., Morningstar Inc., ValueLine, and Grant’s. Brokers that we select to execute transactions from time to time refer clients to our firm. However, we do not make commitments to any broker or dealer to compensate that broker or dealer through brokerage or dealer transactions for any client referrals. We conduct periodic reviews of trading practices, analyzing price and commissions offered by the various brokers used and volume of client commissions directed to each broker. Our trading staff also performs a qualitative evaluation of the brokers in coordination with the chief compliance officer. 12  Obermeyer Wealth aggregates trades where possible and when we believe it will reduce costs or facilitate executions. Obermeyer Wealth’s block trading policy and procedures are designed to treat clients fairly and equitably. Although we recommend certain custodial institutions, it is the client’s decision as to which custodian to use. See Item15 for more information. The financial institutions with which Obermeyer Wealth does business provide us with access to their institutional trading and custody services, which are typically not available to retail investors. These services are not contingent on our firm committing to any specific amount of business (assets in custody or trading commissions). Their brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Custody, trust, and brokerage providers also make available to our firm other products and services that benefit us in servicing our clients but do not directly benefit our clients’ accounts. We use many of these products and services to service all or some substantial number of our client accounts, including accounts not maintained with the service provider. Products and services that assist us in managing and administering our clients’ accounts include software and other technology that: facilitate payment of our fees from clients’ accounts; and • provide access to client account data (such as trade confirmations and account statements); • facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • provide research, pricing, and other market data; • • assist with back-office functions, recordkeeping, and client reporting. Some custody, trust, and brokerage providers also offer other services intended to help us manage and further develop our business enterprise. These services 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. Custody, trust, and brokerage providers make available, arrange, or pay third-party vendors for the types of services rendered to Obermeyer Wealth. These providers discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to our firm. Custody, trust, and brokerage providers also provide other benefits such as educational events or occasional business entertainment for our personnel. In evaluating whether to recommend that clients custody their assets at these providers, we consider the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely the nature, cost, or quality of custody, trust, and brokerage services they provide, which creates a potential conflict of interest. Our Chief Compliance Officer, Charlton Rugg, is available to address any questions that a client or prospective client has regarding the above arrangements and their associated conflicts of interest. Directed Brokerage: In certain circumstances, Obermeyer Wealth can accept directed brokerage arrangements (when a client requires that account transactions be effected through a specific broker-dealer). In such client- 13  directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Obermeyer Wealth will not seek better execution services or prices from other broker-dealers, and will not be able to “batch” the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Obermeyer Wealth. As a result, a client will likely pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Please Note: If a client directs Obermeyer Wealth to effect securities transactions for the client’s accounts through a specific broker-dealer, the client must acknowledge that such direction will likely cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through Obermeyer Wealth. Higher transaction costs adversely impact account performance. Please Also Note: Transactions for directed accounts will generally be executed after the execution of portfolio transactions for non-directed accounts. Item 13 Review of Accounts REVIEWS: The underlying securities within clients’ accounts are continually monitored. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. More frequent reviews are triggered by material changes in variables such as the client’s individual circumstances or the market, political, or economic environment. These accounts are reviewed by one or more of the following: Walter (Wally) Obermeyer; Roger Hennefeld, CFA; Bret Hirsh; Dana Nightingale, CFA & CFP®; Alexandra Phillips; Adam Savin; G. Tod Wood, CFA; Nicholas Barnes, CFA; Brian Brady, CFP®; Kimbo Brown-Schirato, WMCP®,; Brooke Gais, CFP®; Hayden Porter, CFP®,;or Patrick Yarborough, CFA. REPORTS: We provide quarterly reports summarizing investment results, balances, and holdings. In addition, bank custodians provide quarterly statements, and broker-dealers provide monthly statements and transaction confirmations. We encourage clients to compare the statements we provide with those their custodians provide. We encourage clients to receive their quarterly reports by electronic delivery to our client portal. Item 14 Client Referrals and Other Compensation As discussed in Item 12 above, Obermeyer Wealth receives from certain broker-dealers and custodians, at no cost or at a discount, support services and products. Obermeyer Wealth’s clients do not pay more for investment transactions effected or assets maintained at any such broker-dealer or custodian because of these arrangements. Obermeyer Wealth makes no corresponding commitment to any such broker-dealer or custodian, 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 arrangements. Obermeyer Wealth receives client referrals from Charles Schwab through participation in Schwab Advisor Network® (SAN). SAN is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with Obermeyer Wealth. Schwab does not supervise Obermeyer Wealth and has no responsibility for our management of client portfolios or our other advice and services. Obermeyer Wealth pays Schwab for receiving client referrals through SAN, which raises the conflicts of interest described below. Obermeyer Wealth pays Schwab a participation fee, based on a percentage of the client’s assets at Schwab, on all referred clients’ accounts that are maintained in custody at Schwab, and a non-Schwab custody fee on all accounts that are maintained at, or transferred to, another custodian. Obermeyer Wealth pays Schwab the participation fee quarterly so long as the client account is at Schwab. We do not increase the advisory fee we charge clients referred to us by Schwab through SAN. 14  Obermeyer Wealth has agreed to pay Schwab a non-Schwab custody fee, based on a percentage of the assets transferred, if custody of a referred client’s account is not maintained at or assets in the account are transferred from Schwab. This fee does not apply if the client was solely responsible for the decision not to maintain custody at Schwab. The non-Schwab custody fee is higher than the participation fees Obermeyer Wealth generally would pay in a single year. Thus, Obermeyer Wealth has an incentive to recommend that client accounts be held in custody at Schwab. The participation and non-Schwab custody fees are based on assets in accounts of Obermeyer Wealth clients who were referred by Schwab and those referred clients’ family members living in the same household. Thus, Obermeyer Wealth has an incentive to encourage household members of clients referred through the service to maintain custody of their accounts and execute transactions at Schwab. Schwab does not charge Obermeyer Wealth clients who maintain accounts at Schwab for custody, but it does receive compensation from our clients in the form of commissions or other transaction-related compensation on certain securities trades executed through Schwab. Schwab also receives a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker-dealer’s fees. See Item 12 for more information about brokerage practices and Obermeyer Wealth’s duty to seek best execution. Obermeyer Wealth also receives client referrals from Wealthramp. Wealthramp is an investor education and lead matching service (the "Referral Platform"); Obermeyer Wealth participates in the Referral Platform. As part of its service, Wealthramp conducts interviews and conversations with investors to determine whether a particular investor’s needs and goals would be a good match for Obermeyer Wealth’s services and expertise. If Wealthramp determines an investor would be a good fit for Obermeyer Wealth, Wealthramp introduces the investor to Obermeyer Wealth. At that time, the investor is free to decide whether to retain Obermeyer Wealth to provide investment advisory services. If the investor becomes a client of Obermeyer Wealth, we pay Wealthramp a referral fee that is a portion of the fees we receive from each referred client. The referral fee is equal to 25% of gross fees we receive in the first year from the referred client, 15% in the second year, and 10% thereafter for as long as the client relationship continues. If the client’s relationship with Obermeyer Wealth terminates, our obligation to pay the referral fee for that client ceases. We do not increase the advisory fee we charge clients referred to us by Wealthramp. Obermeyer Wealth also receives client referrals from SmartAdvisor by SmartAsset. SmartAsset offers a web-based 25- 30 question survey to potential investors interested in being referred to a financial advisor. After a potential investor completes the survey, SmartAdvisor’s concierge team validates leads by phone, text, and email. Once validated, a survey participant’s information is passed on to three financial advisors in their local geographic area. Obermeyer Wealth is a verified member of SmartAsset’s recommended financial advisors. When SmartAsset passes a lead to Obermeyer Wealth, we receive the results of the potential investor’s survey, contact information, and permission to contact the potential investor. Obermeyer Wealth makes a one-time payment to SmartAsset in the range of $200- $240 for each referred lead. The one-time payment is Obermeyer Wealth’s only financial obligation to SmartAsset for each lead. We do not increase the advisory fee we charge clients referred to us by SmartAsset. ANY QUESTIONS: Obermeyer Wealth’s Chief Compliance Officer, Charlton Rugg, remains available to address any questions that a client or prospective client has regarding the above arrangements and the corresponding conflict of interest such arrangements may create. 15  Item 15 Custody Obermeyer Wealth is independently owned and operated and not affiliated with any of the institutions that it or our clients use for custody services. Obermeyer Wealth uses two types of custodians: bank trust departments and brokerage firms. The two types of custodians offer different services and charge different fees. The discount brokerage firms with whom we work are typically less expensive than the banks because they charge only transaction fees, and many transactions have no fee, whereas the banks also charge custodial fees. However, we have found that both types of custodians serve the needs of clients well and have reasonable costs in relation to the services provided. Ultimately, the client can use a custodian of its choice with Obermeyer Wealth’s approval. We previously disclosed in the “Fees and Compensation” section (Item 5) of this brochure that our firm directly debits advisory fees from client accounts. As part of this billing process, the client’s custodian is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian must send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there is an error in their statement. Please Note: The custodian does not verify the accuracy of Obermeyer Wealth’s fee calculations. Our firm does not have physical custody of client accounts. Certain clients have established asset transfer authorizations that permit the qualified custodian to rely upon instructions from Obermeyer Wealth to transfer client funds or securities to third parties. These arrangements are disclosed in Item 9 of Part 1 of Form ADV. However, in accordance with the guidance provided in the SEC’s February 21, 2017, Investment Adviser Association No-Action Letter, the affected accounts are not subject to an annual surprise CPA examination. In addition, we have direct authority over a small number of client accounts that does require an annual surprise CPA examination. This includes any accounts for which one of our representatives serves as trustee. Our most recent examination began in March 2024 and concluded with no exceptions noted. ANY QUESTIONS: Obermeyer Wealth’s Chief Compliance Officer, Charlton Rugg, is available to address any questions that a client or prospective client has regarding custody-related matters. Item 16 Investment Discretion Clients generally hire us to provide discretionary asset management services, in which case we place trades in a client’s account without contacting the client before each trade to obtain the client’s permission. Our discretionary authority includes the ability to do the following without contacting the client: • Determine the security to buy or sell; and • Determine the amount of the security to buy or sell. Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also change such limitations by providing us with written instructions. 16  Item 17 Voting Client Securities We vote proxies for all client accounts unless otherwise directed. However, clients always have the right to vote proxies and can do so if they instruct us. We vote proxies in the best interests of clients and in accordance with our established policies and procedures. Our firm retains all proxy voting books and records for the requisite period, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to deciding how to vote proxies, and a copy of each written client request for information on how the adviser voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third party to cast a vote. Upon request, we will provide clients with a copy of our proxy voting policies and procedures and a record of how we voted on their behalf. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. We are available to discuss the filing of “Proofs of Claim” in class action settlements, but we cannot advise or act on behalf of the client in legal proceedings on claims involving companies whose securities are held in the client’s account(s). If desired, clients may direct us to transmit copies of class action notices to the client or a third party. In addition, accounts held at certain custodians are enrolled with a class action service provider who will file claims on behalf of the client. See Item 5 above for more information. Item 18 Financial Information Obermeyer Wealth has no financial commitments that impair its ability to meet contractual and fiduciary commitments to clients and has not been the subject of bankruptcy proceedings. Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. Any questions: Obermeyer Wealth’s Chief Compliance Officer, Charlton A. Rugg, is available to address any questions regarding this Part 2A. 17