A. Description of the Advisory Firm B. Types of Advisory Services Selection of Other Advisers GSWML may direct clients to third-party investment advisers. Before selecting other advisers for clients, GSWML will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where GSWML is recommending the adviser to clients. On-going Financial Planning On-going financial planning services may include: 1. Initial Consultation (Free) a. Assess current financial situation and discuss the financial planning process and my services. 2. Detailed meeting to go through Clients financial situation in depth and better understanding of client’s financial goals and concerns. 3. Client Recommendation Meeting a. Delivery of a financial plan including current net worth (Balance Sheet), goals, action items and more. b. Recommendations. c. Client walkthrough of plan and any questions. Included in the ongoing plan: 1. Biannual check ins with clients to assess financial plan, implementation of the plan, limitations, adjustments needed, and assess new variables in a client’s financial picture. 2. End of Year meeting to discuss financial plan 3. A new/updated financial plan annually In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Advisor Credit Exchange (ACX) Credit solutions for GSWML clients offered through the Adviser Credit Exchange. Services to include: collateralized and unsecured personal loans. GSWML receives a commission for each loan that they refer to ACX, ranging from 0 - .25% of the loan amount. Therefore, GSWML has a financial incentive to recommend ACX to their clients. Clients are not required to use ACX and may select any lender of their choosing. Credit solutions offered through Advisor Credit Exchange (“ACX” a third party owned by Envestnet). The Advisor Credit Exchange solution do charge an interest rate based amount borrowed and terms of loan. GreenUp Protection Solutions LLC Upon review of an investor's financial status, GSWML may propose that the investor include, as part of his or her financial portfolio, one or more types of products that are not part of the investment advisory services provided by GSWML, such as insurance products. If the investor chooses to include such a product in his or her financial portfolio, GSWML recommends that the investor work closely with his or her attorney, accountant, insurance agent and other related professionals. Incorporation of the non-advisory financial product into the investor's financial plan is entirely at the client's discretion. For insurance products, GSWML provides access to a platform of insurance products by GreenUp Protection Solutions, LLC. (“GPS”), a licensed insurance agency and affiliate of GreenUp. The investor is under no obligation to use GPS’s service and may seek insurance advice from any licensed agent. The insurance products and fee structures available

from GPS may differ from those available from other third- party insurance agents. GSWML recommends that the investor fully evaluate products and fee structures to determine which arrangements are most favorable to the investor prior to making an investment decision. GPS is entitled to receive commissions and other renumeration on the sale of insurance products. As such, GPS affects insurance transactions and receive separate, yet customary compensation. Pontera GSWML provides an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSAs, and other assets GSWML does not custody. GSWML regularly reviews the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary Services Limited to Specific Types of Investments GSWML generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), 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. GSWML may use other securities as well to help diversify a portfolio when applicable. GSWML offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). 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 C. Client Tailored Services and Client Imposed Restrictions GSWML from properly servicing the client account, or if the restrictions would require GSWML to deviate from its standard suite of services, GSWML reserves the right to end the relationship. A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. GSWML does not participate in any wrap fee programs. GSWML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $508,512,466 $2,316,568 February 2024 Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $500,000 1.25% $500,001 - $2,000,000 1.00% $2,000,001 - $5,000,000 0.85% $5,000,001 - $10,000,000 0.70% $10,000,001 – and Up 0.45% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. Lower fees for comparable services may be available from other sources. Selection of Other Advisers Fees For clients utilizing the direct indexing solution from Veriti through First Trust the additional fees range from 25 – 40bps depending on total assets of the advisor. D. Wrap Fee Programs E. Assets Under Management