Garland Capital Management, Inc. (Garland, us, we, our) is a registered investment adviser with the Securities and Exchange Commission. Garland began conducting business in 1998. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities owning 25% or more of this company):
• John Thomas Garland, President
• Joyce Mary Garland, Secretary Garland Capital Management, Inc. offers portfolio management services to our Clients (Client, you, your). Individual Portfolio Management We provide continuous asset management of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on the Client's particular circumstances are established, we document:
• Your individual objectives
• Time horizons
• Risk tolerance
• Prior investment experience
• Personal and family obligations, and
• Liquidity needs The output of this information is a personal Investment Policy Statement (IPS). Your IPS drives the management of the account, including the suitability of our recommendations (purchases and sales) for your account. We manage your account(s) with investment and brokerage discretionary authority (please see Items 12 and 16 for additional detail). We attempt to tailor your investment portfolio to your situation as you have described it to us. You may place limitations, or restrictions, on investment or brokerage discretionary authority. Please note that such limitations are required to be in writing. We also reserve the right to not accept an account or terminate an account if we believe, in our sole determination, that the limitations or restrictions prohibit us from delivering our services to you, as defined in our written agreement. Once the IPS is finalized and you agree that it accurately represents who you are,

your goals and objectives, risk tolerance and time horizons, we build your portfolios with securities we believe will achieve those objectives. In addition, as described in more detail under Item 8, we monitor your account and the securities held by all of our Clients on a regular basis. Should global or market events dictate, we may conduct more frequent reviews. One of the most important reasons we review your IPS or accounts is when you notify us of a change in your personal situation (divorce, lay-off, medical issue, birth of a child, death in the family, inheritance, etc.). We do not limit our recommendations; we do not have as a firm (or through our employees) any outside or additional financial services, affiliations, registrations, or licenses. 5 Our only income is from the advisory fees that we charge to you and our other Clients. We utilize the following types of securities in Client portfolios:
• Exchange-listed and Over-the-counter equity securities, including ETFs (Exchange Traded Funds)
• Foreign issuers through ADRs (American Depository Receipts)
• Real Estate Investment Trusts (REITs)
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares, and
• United States governmental securities Because some types of investments involve certain additional degrees of risk, those securities are only used when consistent with a Client's stated investment objectives, tolerance for risk, and liquidity. Garland does not participate in, nor is it a sponsor of, any wrap fee programs. Assets Under Management As of December 31, 2022, we manage approximately $222,722,805 of client assets, all on a discretionary basis. Garland does not manage any client assets on a non-discretionary basis.