A. Description of the Advisory Firm GPS Financial, LLC (hereinafter “GPS”) is a Limited Liability Company organized in the State of New York. The firm was formed in September 2017, and the principal owner is Brian Imrich. B. Description of Advisory Services We Offer GPS provides One Time & Ongoing Financial Planning Services and Ongoing Investment Management Services. Financial Planning Services Initial & One Time Financial Planning At the onset of a client relationship, GPS provides an initial & a one-time financial planning services under either a Full (Focused) Financial Planning or a Project & Meeting (Limited Scope) Financial Planning delivered through a structured and systematic process. The fee charged is based on the scope of the work, time involved, and the complexity of the situation and previous relationships. Should your situation not warrant the breadth of our Full Financial Planning process, it is possible to engage in our Project & Meeting Financial Planning option. The services provided by GPS pursuant to this level of service are limited to the areas described in the Planning Agreement. This level of service is not a substitute for a full comprehensive plan. Upon completion of our work, additional or ongoing services provided by GPS are agreed to in a separate contract with our firm’s Ongoing Financial Planning. For appropriate client situations, where a client is at a crossroad and looking for help making a specific decision(s), GPS is available to provide recommendations and guidance at an hourly rate. These fees are not negotiable, and the final fee will be included in the summary. All fees are paid upon completion with the delivery of the written summary. Recommendations may address the following topics/areas:
• Household Cash Flow
• Upcoming Major Expenses
• Upcoming Life Events
• Distribution & Withdrawal Rates
• Contribution & Savings Rates
• Tax Planning
• Debt Planning
• Risk & Insurance
• Estate & Legacy
• Workplace Retirement Plans
• Retirement Planning
• Investment Risk & Return
• Investment Product Review
• Investment Strategy Review
• Frequency of Rebalance/Reallocation
• Goal Planning (college funding etc..) | 5 Implementation of our recommendations is at your sole discretion. In our recommendations, we may refer you to an accountant, attorney or other specialist as necessary for non-advisory related services we believe are appropriate. Ongoing Financial Planning Upon completion of your initial financial plan, you may continue to engage us in an ongoing financial planning relationship based on what areas of your plan needs updating and monitoring. Ongoing Financial Planning is separate from Ongoing Investment Management. Portfolio Management Services GPS’ main offering is our Flagship Level: Ongoing Portfolio Management (Comprehensive Portfolio Management) and Atlas Level: Guided Portfolio Solutions (Asset Management). We will meet on an ongoing basis (semi-annual or annual meetings) to review your goals, priorities, changes in your situation, general economic conditions and outlook, progress toward your goals. GPS creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). These areas are the variables that impact the decisions of how your portfolio is invested

and assists in the recommended changes year over year:
• ☐ Household Cash Flow
• ☐ Upcoming Major Expenses
• ☐ Upcoming Life Events
• ☐ Distribution & Withdrawal Rates
• ☐ Contribution & Savings Rates
• ☐ Tax Planning
• ☐ Debt Planning
• ☐ Risk & Insurance
•
• ☐ Estate & Legacy
• ☐ Workplace Retirement Plans
• ☐ Proximity to Goal (i.e. Retirement)
• ☐ Investment Risk & Return
• ☐ Investment Product Review
• ☐ Investment Strategy Review
• ☐ Frequency of Rebalance/Reallocation
• ☐ Other:_____________________ Should you experience any significant changes to your financial or personal circumstances between regular review meetings, we will need you to notify us so that we can consider such information in managing your investment portfolio. GPS may direct clients to a third-party platform provider. However, GPS does not utilize third party money managers for the management decisions of client accounts. The client may select that 3rd party platform provider and separately select GPS to manage all or a portion of the client's assets. GPS has existing relationships with Orion Portfolio Solutions, Aspire Financial Services, and MTG, LLC dba Betterment Securities (“Betterment Securities”). GPS seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GPS’s economic, investment or other financial interests. To meet its fiduciary obligations, GPS attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain | 6 client portfolios, and accordingly, GPS’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is GPS’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments GPS generally limits its investment advice to exchange traded funds (“ETFs”), mutual funds, real estate funds, fixed insurance products including annuities, equities and ETFs, although GPS primarily recommends ETFs and mutual funds but may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services & Client Imposed Restrictions GPS offers individualized investment advice to clients utilizing our Flagship Level: Ongoing Portfolio Management service and our Atlas Level: Guided Portfolio Management service. We offer general investment advice to clients utilizing a third party platform. GPS may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GPS from properly servicing the client account, or if the restrictions would require GPS to deviate from its standard suite of services, GPS reserves the right to end the relationship. D. Participation in Wrap Fee Programs We do not participate in any wrap fee programs. E. Assets Under Management GPS manages $52,831,390 in discretionary accounts and $0 in non-discretionary accounts as of December 31, 2023.