This brochure describes the wrap program sponsored by GYL (the “GYL Program”). Under the GYL Program, GYL offers investment advisory and portfolio management services on a “wrapped” basis, meaning that the fee for GYL’s services is bundled with the cost of custody and commissions (but not markups or markdowns embedded in fixed income transactions) for brokerage transactions executed at the wrap program broker the client chooses, Fidelity and/or Charles Schwab. (GYL also offers investment advisory and portfolio management services on an “unwrapped” basis, meaning that clients pay separate charges for portfolio management and execution. Information about these services is contained in GYL’s Disclosure Brochure, which is Part 2A of GYL’s Form ADV.) GYL serves as the sponsor and manager of the GYL Program. GYL primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), stocks, government and corporate bonds, alternative investments, and independent investment managers of separately managed accounts (“Independent Managers”). The annualized fees for the GYL Program are charged as a percentage of the value of the client’s portfolio, as specified in the client’s agreement with GYL. The fees vary from client to client, and are as much as 1.20% of a client’s assets under GYL’s management. GYL generally deducts fees or bill clients quarterly in arrears based upon the average daily market value of the client’s assets during the previous calendar quarter. Clients serviced by our New York office are billed quarterly in advance, based on the total market value of the portfolio as of the end of the preceding quarter. We have a business arrangement with SCS Capital Management LLC (“SCS”), who is an indirect, wholly-owned subsidiary of Focus LLC, under which certain clients of GYL Financial Synergies have the option of investing in certain private investment vehicles managed by SCS. GYL Financial Synergies is an affiliate of SCS by virtue of being under common control with it. Please see Item 9 of this brochure for further details. We do not receive any compensation from SCS in connection with assets that our clients place in SCS’s pooled investment vehicles. GYL’s clients are not advisory clients of and do not pay advisory fees to SCS. However, our clients bear the costs of SCS’s investment vehicle or vehicles in which they are invested, including any management fees and performance fees payable to SCS. The allocation of GYL client assets to SCS’s pooled investment vehicles, rather than to an unaffiliated investment manager, increases SCS’s compensation and the revenue to Focus LLC relative to a situation in which our clients are excluded from SCS’s pooled investment vehicles or invested in an unaffiliated third party’s pooled investment vehicles. As a consequence, Focus LLC has a financial incentive to encourage us to recommend that our clients invest in SCS’s pooled investment vehicles. Additional fees and expenses. As noted above, the GYL Program Fee covers GYL’s advisory services, custody and commissions for securities transactions effected through the program broker-dealer. In addition to the GYL Program fee, clients will be responsible for the fees and expenses of investing their assets, including fees and expenses charged by mutual funds, private investment funds, ETF’s, Independent Managers and any platform manager fee charged to access the Independent Managers, taxes, and any other fees, expenses and charges imposed by exchanges and broker-dealers other than the Program broker. The GYL Program Fee does not cover mark-ups or mark-downs for fixed income transactions. Fixed income transactions usually are cleared net, without any commissions. However, the broker-dealers executing fixed income transactions typically assess mark-ups or other trading related costs that are embedded into the price of the security allocated to client accounts. Cash Positions. At any specific point in time, depending upon perceived or anticipated market conditions or events (there being no guarantee that such anticipated market conditions/events will occur), GYL may maintain cash positions for defensive or other purposes. All cash positions (money markets, etc.), accrued but unpaid interest, and margin balances shall be included as part of assets under management for purposes of calculating GYL’s advisory fee. A wrap arrangement is not appropriate for every advisory client. Participants in the GYL Program may pay a higher or lower aggregate fee than if investment management and brokerage services are purchased separately. If the number of transactions in a client’s account is low enough, the wrap fee the client pays could potentially exceed the standalone investment advisory fee and any separate

brokerage fees and commissions that otherwise would have been charged. Under GYL’s agreements with Schwab and Fidelity, the broker-dealers participating in the GYL Program, GYL can choose whether to pay transaction-based pricing or asset-based pricing for transactions in client accounts. If GYL elects commissions rather than asset-based pricing, for those institutional clients who participate in the GYL Program, GYL has an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client’s account. However, as a fiduciary it remains GYL’s duty to always act in the client’s best interest. There will be times, including extensive periods, where there will be no recommendations to trade a client’s account, as a result of each individual client’s facts and circumstances, including tax reasons, and other financial decisions. GYL’s Chief Compliance Officer is available to address any questions that a client or prospective client may have regarding the conflict of interest a wrap fee arrangement may create. As referenced above, a portion of the GYL Program Fee paid to GYL is used to cover the securities brokerage commissions, transactional costs, and asset-based pricing fees attributed to the management of its clients’ portfolios. Our wrap program broker has eliminated transaction-based fees for electronic trades of equities and exchange-traded funds (ETF’s), and asset-based fees for accounts in households valued at $1,000,000 or more or for clients who opted to receive statements from wrap program broker electronically. For those eligible accounts now no longer subject to these transaction and asset-based pricing fees, GYL is no longer paying those transaction and asset-based costs on behalf of clients and thereby benefits from a reduction in expenses associated with its wrap program. Although this change does not impose any new costs on clients, it increases our profits by reducing the transaction costs we pay on clients’ behalf. Clients serviced by our New York office pay fees that vary based on the type of asset class the client is invested in. This is a potential conflict of interest, in that it gives us an incentive to recommend that clients invest in assets that pay us higher fees over assets that pay us lower fees. We also have a conflict of interest when we recommend that our clients invest in venture capital investments that have the potential to pay us a performance fee in that it creates an incentive for us to allocate client assets to speculative investments that have the potential to pay us a higher performance fee. We have addressed these potential conflicts of interest through disclosure. These clients sign agreements selecting the relevant asset class and fee rate we offer. Depending upon the percentage wrap-fee charged by GYL, the amount of portfolio activity in the client’s account, and the value of custodial and other services provided, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately. For institutional clients, GYL is willing to price its services on either a “wrapped” or “unwrapped” basis. Participants in the GYL Program may pay a higher or lower aggregate fee than if investment management and brokerage services are purchased separately. Conflict of Interest: A wrap arrangement is not appropriate for every advisory client. Participants in the GYL Program may pay a higher or lower aggregate fee than if investment management and brokerage services are purchased separately. If the number of transactions in a client’s account is low enough, the wrap fee the client pays could potentially exceed the standalone investment advisory fee and any separate brokerage fees and commissions that otherwise would have been charged. Under GYL’s agreements with the wrap program brokers, GYL can choose whether to pay transaction-based pricing or asset-based pricing for transactions in client accounts. If GYL elects commissions rather than asset- based pricing, GYL will have an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client’s account. However, as a fiduciary it remains GYL’s duty to always act in the client’s best interest. There will be times, including extensive periods, where there will be no recommendations to trade a client’s account, as a result of each individual client’s facts and circumstances, including tax reasons, and other financial decisions. As noted above, institutional clients can choose to retain GYL’s services on either a wrapped or an unwrapped basis. GYL’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the corresponding conflict of interest a wrap fee arrangement may create.