General Information Griffin Partners was formed in 2016 and provides financial planning, portfolio management, and general consulting services to its clients. At the outset of each client relationship, Griffin Partners spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, Griffin Partners generally develops with each client an understanding of the client’s financial circumstances and goals, and the client’s risk tolerance level, as well as the client’s investment objectives and guidelines. Where Griffin Partners provides general consulting services, Griffin Partners will work with the client to prepare an appropriate summary of the specific project(s) to the extent necessary or advisable under the circumstances. Financial Planning One of the services offered by Griffin Partners is Financial Planning, described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial Planning may include advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client’s particular situation, financial planning may include some or all of the following:
• Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning;
• Assessing risk and reviewing basic health, life and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals. Once Financial Planning advice is given, the client may choose to have Griffin Partners implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by Griffin Partners under a Financial Planning engagement and/or engage the services of any recommended professional. Portfolio Management As described above, at the beginning of a client relationship, Griffin Partners meets with the client, gathers information, and performs research and analysis as necessary to understand the client’s Investment Plan. To implement the client’s investment plan, Griffin Partners will manage the client’s investment portfolio on a discretionary or non-discretionary basis. As a discretionary investment adviser, Griffin Partners will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing

and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Griffin Partners may recommend clients participate in investment programs through third-party sponsors, such as Unified Managed Accounts (“UMA”) programs. UMA platforms provide access to investment strategies offered by unaffiliated investment managers. Clients must consent to their participation in the UMA program by completing additional forms and documents provided by the account custodian. Notwithstanding the foregoing, clients may impose certain written restrictions on Griffin Partners in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of Griffin Partners. General Consulting In addition to the foregoing services, Griffin Partners may provide general consulting services to clients. These services are generally provided on a project basis, and may include, without limitation, minimal cash flow planning for certain events such as education expenses or retirement, estate planning analysis, income tax planning analysis and review of a client’s insurance portfolio, as well as other matters specific to the client as and when requested by the client and agreed to by Griffin Partners. The scope and fees for consulting services will be negotiated with each client at the time of engagement for the applicable project. Investment Advice Specific to Retirement Account Rollovers When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care (give prudent advice)
• Never put our financial interests ahead of our clients (give loyal advice)
• Avoid misleading statements about conflicts of interest, fees, and investments
• Follow policies and procedures designed to ensure that we give advice in client’s best interest
• Charge no more than is reasonable for our services
• Give you basic information about our conflicts of interest. Principal Owner Mark T. Vandiver is the sole principal owner of Griffin Partners. Type and Value of Assets Currently Managed As of December 31, 2023, Griffin Partners manages approximately $208.4 million on a discretionary basis and $19.1 million on a non-discretionary basis. Total assets under management for the firm are approximately $227.5 million.