A. Description of the Advisory Firm GFS Wealth Management Advisors, Inc. dba Ganim Private Wealth (hereinafter “GFS”) is a Corporation organized in the State of Connecticut. The firm was formed in September 2016, and is owned by Coastline Holdings Group, LLC. B. Types of Advisory Services Portfolio Management Services GFS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GFS creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring GFS evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GFS will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. GFS seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GFS’s economic, investment or other financial interests. To meet its fiduciary obligations, GFS attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GFS’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 GFS’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services GFS offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • Identifying investment objectives and restrictions • Providing guidance on various assets classes and investment options
• Recommending money managers to manage plan assets in ways designed to achieve objectives
• Monitoring performance of money managers and investment options and making recommendations for changes
• Recommending other service providers, such as custodians, administrators and broker-dealers • Creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific

Types of Investments GFS generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. GFS may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you 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 when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions GFS will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by GFS on behalf of the client. GFS may use “model portfolios” 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 GFS from properly servicing the client account, or if the restrictions would require GFS to deviate from its standard suite of services, GFS reserves the right to end the relationship. D. Wrap Fee Programs GFS acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Clients utilizing GFS’s wrap fee portfolio management should see the separate Wrap Fee Program Brochure. GFS manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. Fees paid under the wrap fee program will be given to GFS as a management fee. Please also see Item 5 and Item 12 of this brochure. E. Assets Under Management GFS currently has $ 350,000,000.00 in assets under advisement. GFS has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 131,543,639.00 $ 0.00 December 2023