GPWM has been in business as a registered investment adviser since January 2012 and is principally owned by Richard I. Lerach. The Firm provides financial planning, consulting, and wealth management services. Prior to engaging GPWM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with the Firm setting forth the terms and conditions under which GPWM renders its services (collectively the “Agreement”). As of December 31, 2023, GPWM had approximately $129,998,748 in assets under management, all of which were managed on a discretionary basis. While this brochure generally describes the business of GPWM, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on GPWM’s behalf and is subject to the Firm’s supervision or control. Investment Management Services GPWM manages client investment portfolios on a discretionary basis, by allocating assets among various Exchange-Traded Funds (“ETFs”) and, to a lesser extent, independent investment managers (“Independent Managers”), mutual funds, and Exchange-Traded Notes (“ETNs”). GPWM tailors its advisory services to the individual needs of clients. GPWM consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. GPWM seeks to ensure that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. Clients are advised to promptly notify GPWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon GPWM’s management services. Clients are permitted to impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in GPWM’s sole discretion, we determine that such conditions will not materially impact the performance or risk of a portfolio strategy or prove overly burdensome to its management efforts. GPWM does not participate in wrap fee programs. Use of Independent Managers As mentioned above, GPWM recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain Independent Managers. The terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement between the Client and the Independent Manager. In addition to this brochure, clients also receive the written disclosure brochure of the designated Independent Manager engaged to manage their assets. GPWM evaluates various information about the Independent Managers in which it recommends or selects to manage client portfolios under the Program. The Firm generally reviews a variety of different resources, which generally include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves, and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposures. GPWM also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other related factors. GPWM continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. GPWM has discretion to appoint, terminate and/or replace any Independent Manager. GPWM does not, however, actively supervise the trading activities of the Investment Managers, nor is it liable for any losses in the value of assets as a result of their trading activities. Clients should be aware that in most cases, they have the opportunity to invest directly with Independent Managers without the involvement of GPWM. ERISA (Other

than Individual Retirement Accounts) If the client is: (i) a retirement plan (“Plan”) organized under the Employee Retirement Income Security Act of 1974 (“ERISA”); (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take a distribution; (iii) the beneficial owner of an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iv) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code: then GPWM represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by GPWM or its representatives or with respect to any investment recommendations regarding an ERISA Plan or participant or beneficiary account. Retirement Plan Rollovers A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If GPWM provides a recommendation as to whether a client should engage in a rollover or not, GPWM is acting as a fiduciary within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Furthermore, if GPWM recommends that a client roll over their retirement plan assets into an account to be managed by GPWM, such a recommendation creates a conflict of interest if GPWM will earn new (or increase its current) compensation as a result of the rollover. To mitigate this conflict, GPWM will in good faith assist the client in understanding the tradeoffs and options related to the rollover through written analysis and discussion. No client is under any obligation to roll over retirement plan assets to an account managed by GPWM. Financial Planning and Consulting Services As part of our investment management process, GPWM provides its clients with a broad range of comprehensive financial planning and consulting services at no additional expense. These services vary, but generally includes matters such as retirement planning, educational funding, basic estate planning, insurance planning, basic tax planning and cash flow analysis. In performing its services, GPWM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. GPWM recommends the services of itself, its Supervised Persons in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if GPWM recommends its own services. The client is under no obligation to act upon any of the recommendations made by GPWM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including GPWM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of GPWM’s recommendations. Clients are advised that it remains their responsibility to promptly notify GPWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising GPWM’s previous recommendations and/or services. Clients have the option to also engage GPWM to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e. 529 plans). In these situations, GPWM directs or recommends the allocation of client assets among the various investment options available with the product. Each situation is handled differently. Client assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider.