A. Description of the Advisory Firm This firm has been in business since June 4, 2010, and the principal owner is David Harvey Graham Jr. B. Types of Advisory Services Grand Strategy Capital, LLC (hereinafter “GSC”) offers the following services to advisory clients: Investment Supervisory Services GSC offers ongoing portfolio management services based on the individual goals, objectives, time horizon and risk tolerance of each client. GSC 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 (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring GSC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GSC 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. 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 credit/debt planning. These services are based on fixed fees or hourly fees and the final fee structure is documented in the Advisory Agreement. Selection of Other Advisers GSC may hire outside advisors and/or sub-advisors that it recommends or selects for its clients. GSC will supervise and review accounts managed by outside advisors and/or sub-advisors. Third-Party Platform GSC may use a third-party platform to facilitate management of held away assets, such

as defined contribution plan participant accounts. GSC is not affiliated with the platform in any way and receives no compensation for using it. The platform does NOT provide GSC custody of client assets since GSC does not receive or have access to client log-in credentials. Clients must authorize use of this platform through a link provided to them which connects their account(s) to the platform. This platform does permit GSC to set asset allocation percentages, make trades, and rebalance accounts on a discretionary or non-discretionary basis per a client’s agreement with GSC. Services Limited to Specific Types of Investments GSC limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, third party money managers, REITs, limited partnerships, private placements and government securities. GSC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions GSC offers the same suite of services to all of its clients. However, specific client financial plans 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) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs and targets. Clients may impose restrictions to investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GSC from properly servicing the client account, or if the restrictions would require GSC to deviate from its standard suite of services, GSC reserves the right to end the relationship. D. Wrap Fee Programs GSC does not participate in any wrap fee programs. E. Amounts Under Management GSC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $88,462,207.00 $10,260,285.00 December 2022