Description of our Firm & Principal Owners Grove Point Advisors, LLC (“Grove Point Advisors,” “we,” or “us”) was formed in 2020, is a Delaware limited liability company, and is a wholly owned subsidiary of Grove Point Financial, LLC, a Delaware limited liability company. Grove Point Advisor’s Registered Investment Adviser was registered by the SEC in 1999 under the name H. Beck, Inc. Grove Point Financial, LLC is wholly owned by AWS 10, Inc., a Delaware corporation, which is wholly owned by Atria Wealth Solutions, Inc., a Delaware corporation, which is in turn wholly owned by Atria Wealth Solutions Holdings LLC, a Delaware limited liability company, which is privately owned. Grove Point Advisors is registered as an investment adviser with the Securities and Exchange Commission. Grove Point Advisors is affiliated with Grove Point Investments, LLC, a registered securities broker- dealer and insurance agency. Grove Point Advisors provides investment advisory services to a variety of clients, including individuals, businesses, and retirement plans. Our primary methods of providing investment advisory services are: 1) wrap fee programs; 2) selection of other investment advisers; 3) financial planning; and 4) qualified and non-qualified retirement plan services. Investment advisory services are provided through our investment adviser representatives (“IARs”) located throughout the country. Our IARs may also be registered representatives (i.e., registered with the Financial Industry Regulatory Authority (“FINRA”)) of our affiliated broker-dealer, Grove Point Investments, LLC (“Grove Point Investments”) and licensed as insurance agents. To the extent your IAR provides fixed insurance products or services to you (other than fixed indexed annuities), he or she does so outside of Grove Point Advisors and without our supervision. Some of our IARs are also involved in other business activities, such as accounting, legal, tax, and other non-investment services for which Grove Point Advisors is not responsible. Unless otherwise provided by applicable law and the particular circumstances, services provided by our IARs outside of Grove Point Advisors will not be subject to a fiduciary standard. Grove Point Advisors does not provide accounting, legal, or tax advice and you should consult your own attorney or tax advisor for guidance relative to your specific circumstances. Advisory Services How Services are Tailored to Fit Your Needs Grove Point Advisors’ investment advisory services are tailored to the individual needs of our clients. The advice provided is based on the financial information provided by the client. Where possible, clients may impose reasonable restrictions on investing in certain securities or types of securities that are accepted by Grove Point Advisors. You should promptly notify us if there is a change in your financial circumstances or investment objectives so we may confirm any prior recommendations remain appropriate going forward or advise you as to any proposed changes. Form ADV Part 2A March 28, 2024 Page 5 of 38 Financial Planning Services Financial planning services typically involve either giving advice, creating financial plans or both. Typically, your IAR will (i) conduct an initial interview to determine your concerns and planning needs, (ii) assist you in selecting the specific financial planning services needed, (iii) negotiate an appropriate fee for such services, (iv) schedule additional consultations to discuss your needs and objectives, (v) gather, review, and analyze relevant information and (vi) summarize your situation and make general written recommendations to address your concerns and objectives. Financial Advice Services Clients can engage our IARs for general financial advice, which may or may not result in a written document given to the client. Examples of these services include, but are not limited to:
• Outside account monitoring – ongoing monitoring of a non-Grove Point Advisors account
• Asset allocation services – analysis of a client’s overall asset allocation or asset allocation analysis of a non-Grove Point account
• Advice on the pros and cons of a major financial decision. Financial Plans A comprehensive financial plan seeks to address a wide spectrum of a client’s long-term financial needs, including insurance, savings, tax and estate planning, and investments, taking into consideration the client’s goals and current financial situation and resources. The IAR assists clients in identifying long-term economic goals, analyzes their current financial situation, and prepares a written Financial Plan designed to help achieve those goals and which will identify gaps or obstacles to achieving those goals. A modular financial plan seeks to address one or more, but not all, of the client’s long-term financial needs. Financial Plans are provided in an array of formats and involve a variety of tools and techniques, including client questionnaires, educational materials and financial software. Financial planning services will include various recommendations and planning strategies, depending on the nature of the financial planning services selected. These may include recommendations to allocate your assets among various product or account types. The financial planning services do not include recommendations, however, to buy or invest in specific securities to implement a financial plan. Implementation of financial planning recommendations is the client’s responsibility. The actions necessary to implement a financial planning recommendation, including the development of specific implementation recommendations, are not included in financial planning services, nor are the costs of such implementation included in the financial planning fees charged to the client. The IAR, in addition to being Grove Point Advisors’ IAR, may also be a registered representative authorized to provide securities brokerage services through Grove Point Investments. The IAR may also be an insurance agent licensed to conduct business with one or more insurance companies. In those capacities, and separate from the financial planning services, the IAR may help you implement one or more financial planning recommendations included with the financial plan. Form ADV Part 2A March 28, 2024 Page 6 of 38 If you accept the IAR’s offer to assist with implementation of the financial plan, the IAR may make additional recommendations to invest in specific products or accounts or to purchase additional investment advisory services, but any such recommendations will be limited to those products, accounts and services that Grove Point Advisors and Grove Point Investments have authorized the IAR to offer. For information about which products and services the IAR is authorized to offer on Grove Point Advisors behalf, please reach out to your IAR or contact Grove Point Advisors at 301-944- 5900. You are under no obligation to employ the IAR or Grove Point Advisors to implement the financial plan, or to purchase any investment or insurance product or obtain an advisory service from Grove Point Advisors or the IAR to implement the recommendations made in your financial plan. In circumstances where the IAR makes separate recommendations to implement a financial plan, the opportunity for the IAR and Grove Point Advisors (or its affiliates, including Grove Point Investments) to receive additional compensation from those recommendations creates a conflict between your interests and those of Grove Point Advisors and the IAR. In addition, if you separately purchase a product or service recommended by the IAR to implement a financial planning recommendation, you generally will be charged commissions or fees in connection with those transactions and services that are separate from and in addition to the fees charged by Grove Point Advisors for financial planning services. Your IAR’s obligations when acting as an insurance agent for you or providing securities brokerage services to you differ from your IAR’s obligations to you when your IAR is acting as an IAR. Termination of Financial Plan Service Delivery of your financial plan terminates the planning services agreement. You may also terminate your planning services agreement upon written notice to us or by us upon written notice to you. The termination or expiration of your planning service agreement with us also results in the termination of the investment advisory relationship that exists between you and us in connection with that agreement. This means we and our IARs will no longer owe you any duties in connection with your planning services agreement even if you receive securities brokerage or other services from us. Portfolio Builder Wrap Fee Program The Portfolio Builder Program (“Portfolio Builder” or “Program”) is an IAR-directed wrap fee program sponsored by Grove Point Advisors and supported by the Envestnet platform. Through this program, clients receive investment advisory, administrative, execution, custody and clearing services for a bundled fee. Grove Point Advisors acts as an investment adviser with respect to the Program and each client opens a brokerage account with Pershing, LLC (“Pershing”) to hold the assets. Pershing acts as the clearing broker and qualified custodian for the Program. Trades are executed through Grove Point Investments, in its capacity as a broker-dealer, and cleared through Pershing. Prior to opening a Portfolio Builder account with us, your IAR will gather information or meet with you to create an investment profile and will discuss, among other things, your investment experience, investment objectives, risk tolerance and general financial condition. These investment profiles help your IAR recommend appropriate investment products and services to you under the Portfolio Builder platform. You will enter into an agreement with us setting forth terms and conditions of the advisory services relationship, including fees to be charged and authorization for your IAR to buy and sell securities in accordance with your investment objectives. You are encouraged to contact your IAR Form ADV Part 2A March 28, 2024 Page 7 of 38 should you have questions about the management of your Portfolio Builder account. With an Advisor Managed Account, your IAR will be responsible for managing your account consistent with your defined objectives and risk tolerance and may assist you to develop a personalized asset allocation program and custom-tailored portfolio. The recommended portfolio will typically include investments such as mutual funds, exchange-traded funds, variable annuities, stocks, bonds, direct participation programs or a combination of these products. A portion of your account may also remain in cash or a money market fund. Your IAR typically will diversify your holdings across various asset classes unless your objective is to invest in specific assets. The percentage weightings within the asset classes will be based on your risk profile, investment objectives and individual preferences. We recommend you and your IAR meet on a regular basis to review the assets in your account, your financial situation and investment objectives. You should let your IAR know about any changes as they occur to your circumstances. You will maintain full and complete ownership of all assets held in your Advisor Managed Account. This means you retain the right to add or withdraw securities or cash, pledge securities, and vote securities. We will not pool your Advisor Managed Account assets with assets in other accounts. You will receive periodic statements from the account custodian. The investment advice under the Program is formulated by the Grove Point Advisors IAR and generally is non-discretionary in nature, meaning Grove Point Advisors usually does not place securities orders without obtaining the prior approval of clients. If you want your IAR to have discretion over the timing and amount of securities purchased or sold in your account, you will be asked to sign an addendum authorizing your IAR to place orders for your account without contacting you in advance. Clients with questions about whether their IAR can exercise discretion should speak to their IAR. Aside from the exceptions noted above, clients in the Portfolio Builder Program are required to review and approve their IAR’s recommendations and Grove Point Advisors will not place securities orders without obtaining the prior approval of clients. Grove Point Advisors is responsible for monitoring client investments under Portfolio Builder on an ongoing basis to ensure adherence to the model asset allocation approved by the client or that the Strategy employed remains appropriate. IARs are responsible for the day to day and ongoing management of client accounts as well as the suitability of (i) the client’s participation in Portfolio Builder, (ii) the client’s recommended Investment Proposal and Strategy and (iii) the investments in the client’s account. The IAR will consult with a client at least annually regarding the account and whether the client’s financial circumstances have changed. This review is designed to ensure that the performance, composition, and risk profile of the account is still appropriate and consistent with the client’s financial circumstances. The IAR will consider how such changes may affect the appropriateness of the Portfolio Builder program, the recommended Investment Proposal/Strategy, or the investments in the account. The IAR also will be available on an ongoing basis to discuss a client’s account and the securities therein or to process instructions from clients concerning the account. You should let your IAR know about any changes as they occur to your circumstances. Form ADV Part 2A March 28, 2024 Page 8 of 38 Grove Point Advisors arranges, through Pershing, to deliver to clients confirmations of each purchase and sale of securities in client accounts, to deliver brokerage statements to clients for each month in which activity occurs in client accounts, to deliver quarterly statements to clients regardless of whether there has been activity in client accounts, and to provide other custodial functions customarily performed with respect to securities brokerage accounts. Grove Point Advisors also arranges for Pershing to maintain custody of all assets in client accounts and to perform custodial services that include, among other things, crediting of interest and dividends on assets and crediting of principal on called or matured securities in accounts. Other costs that may be assessed to you that are not part of the Portfolio Builder Program Fee include dealer markups, electronic fund and wire transfers, market maker spreads and exchange fees, among others. All brokerage account fees, including retirement account annual custodial fees, apply to each of your accounts. The above-listed amounts do not include other amounts that you may be subject to, such as the initial and ongoing expenses paid to third-party investments or third-party pooled investment vehicles, such as mutual funds, annuities or alternative investments. Such expenses are usually set forth in the applicable offering document of the investment and are payable or borne by you in addition to any fee outlined above. Please see our Form ADV Part 2A Appendix 1 Portfolio Builder Brochure for more information on this service, which is located at https://atriawealth.com/disclosures/grove-point-disclosures/. The following Programs are available through Portfolio Builder. Advisor as Portfolio Manager - Architect Series The Advisor as Portfolio Manager program (“APM” or “APM Program”) is an advisory program that provides clients with a portfolio of securities recommended by their IAR. It provides the IAR the ability to produce detailed proposals, create investment models, allocate assets, monitor client specifications on an account, aggregate trading and rebalance an account. The minimum new account size is $10,000. The initial account minimum can, however, be waived at Grove Point Advisors’ discretion, considering various factors. Such factors include length of client relationship, or combined values of other household/family member accounts. Each client in APM completes an investor profile questionnaire (the “Questionnaire”) providing the client’s investment objectives, risk tolerance and investment time horizon for the client’s program assets. The IAR then provides the client with an investment proposal (the “Investment Proposal”) that contains a proposed model asset allocation strategy for allocating the client’s program assets among a combination of asset classes in the capital markets. The Investment Proposal is based upon and objectively correlated to the Questionnaire responses and assists the client in making informed asset allocation decisions. The Investment Proposal allocates a client’s funds pursuant to the client’s risk tolerance. In response to the Investment Proposal, the client may seek to impose reasonable restrictions on the percentage of program assets allocated to certain asset classes. Any restrictions that a client seeks to impose on an allocation to a particular asset class that is accepted by Grove Point Advisors may result in the development of an asset allocation proposal for the client that deviates from the allocation Grove Point Advisors would otherwise propose. Form ADV Part 2A March 28, 2024 Page 9 of 38 In most cases, the IAR will recommend long-positions

in mutual funds, exchange traded funds, and other equity and fixed income securities. Unless a client provides authorization for discretionary trading services, the advice provided under the APM program is non-discretionary in nature and clients must decide whether to accept or reject Grove Point Advisors’ recommendations. Grove Point Advisors will not place securities orders in APM accounts without obtaining the prior approval of clients unless approved to do so by the client and Grove Point Advisors. Grove Point Advisors is authorized to follow the instructions of clients in every respect concerning the client’s participation in APM. However, Grove Point Advisors may reject such instructions if, in Grove Point Advisors’ reasonable judgment, such instructions (i) are not consistent with the terms of the APM Program, or (ii) if implemented, would violate any applicable law, rule or regulation. Third-party Strategists - Blueprint Series Envestnet has entered into agreements with various Third-Party Strategists that provide allocation models for investments in mutual funds and exchange-traded funds (ETFs). This option provides the IAR the ability to use the models provided by these strategists to recommend an allocation of your assets among mutual funds and/or ETFs. Envestnet is responsible for the trading and investment of your assets based on your IAR’s recommendation of the strategist model. The result is an account portfolio comprised of selected mutual funds and/or ETFs based on your investment objectives and risk tolerance. The minimum new account size is $10,000. The initial account minimum can, however, be waived at Grove Point Advisors’ discretion, considering various factors. Such factors include length of client relationship, or combined values of other household/family member accounts. Grove Point Advisors’ strategy and securities recommendations will be consistent with the financial information provided by the client and any reasonable guidelines or restrictions provided by clients in writing and agreed to by Grove Point Advisors. Our Compliance Department is available to address any questions that a client or prospective client may have regarding the corresponding conflict of interest. Please see our firm’s Form ADV Part 2A, Appendix 1 Portfolio Builder Brochure for more information on these services. Portfolio Management – Recommendation of Other Advisers Our IARs can delegate investment advisory responsibilities or discretionary authority to a third-party investment adviser through external advisory platforms that are offered at Grove Point Advisors. Typically, you will enter into an agreement directly with that third party, which will outline, among other things, the fees and trading of your account by that investment adviser. Depending on the Advisory Program, you either pay us directly or pay one fee to the third-party investment adviser, who will then remit a portion of the fee to us. You will receive a copy of both the third-party investment adviser’s brochure as well as this document if we and the third party are acting as co- investment advisers. If investment advisory services are delegated to a third-party investment adviser, your IAR will monitor your assets and will provide services such as, but not limited to, helping you choose the third-party investment adviser, reviewing your accounts, and assisting you with administrative functions related to your portfolio. Form ADV Part 2A March 28, 2024 Page 10 of 38 On a non-discretionary basis, Grove Point Advisors makes available various programs that provide asset allocation services, recommendations for the purchase and sale of individual securities, and/or access to one or more investment management firms. Some of these asset allocation services involve the use of model asset allocation portfolios that diversify your assets among asset classes and styles using either mutual funds or individual securities. Each of the model portfolios employed in these programs represents a different asset allocation strategy. With some programs, we first develop an allocation strategy consistent with your investment objective and then recommend one or more investment management firms to manage individual securities consistent with your allocation strategy. In all cases, your account is invested in accordance with the strategy you choose. Grove Point Advisors will assist you in reviewing one or more of the investment management programs, their terms and conditions, and the options thereunder. Grove Point Advisors will collect certain financial information from you; review your investment objective, investment time horizon, and risk profile; and recommend a program and allocation strategy appropriate for you. Some of the advisory programs Grove Point Advisors recommends are available directly without payment of fees to us or from other investment advisers, possibly at a lower fee than Grove Point Advisors charge. You will be provided confirmations of all the transactions that occur in your account, statements at least quarterly showing all activity in your account, and quarterly performance reports. Confirmations and statements are not provided by us and are generally provided by the custodian of your account. Performance reports are generally provided by the sponsor of the program. Your IAR will review your account with you at least once each year to determine whether the assets in your account are allocated consistently with the allocation strategy you selected. The review covers such things as changes in the value of your account, the success of your allocation strategy in meeting your investment needs and objectives, whether any material changes have taken place in your financial circumstances or investment objectives, and any recommendations the IAR may make with respect to your account(s). Grove Point Advisors will also be available on an ongoing basis to discuss any changes that may have occurred in your circumstances or investment objective. It is your responsibility to advise us or your IAR of any changes in your situation, investment objectives, or any other changes that would affect the way your account should be managed. Grove Point Advisors is not responsible for any adverse tax consequences of purchases or sales of securities in your account(s), whether such transactions are related to rebalancing of your account, maintaining your account in accordance with a model portfolio, the payment of our or other parties’ fees, liquidation of your account, or otherwise, including any penalties on early withdrawals from retirement accounts. You should consult your tax professional regarding all such matters. Grove Point Advisors is not responsible for any third party’s actions, inactions, performance, or compliance with law. Third parties include, but are not limited to, sponsors or co-sponsors of the programs, portfolio or investment managers, sub-managers, custodians, executing brokers, etc. Form ADV Part 2A March 28, 2024 Page 11 of 38 Grove Point Advisors provides investment advisory services to other clients and may give different advice, or take different action for, any other client than the advice Grove Point Advisors gives you or the actions Grove Point Advisors takes for you. Grove Point Advisors and our affiliates (and their respective partners, directors, officers, agents and employees) may buy, sell, or trade securities for their own accounts and such actions may differ from the actions Grove Point Advisors takes for you. Clients are responsible for any and all fees related to the transfer or liquidation of their assets as well as the costs assessed on the accounts in which the assets are maintained after the termination of their account, including, but not limited to: (i) commissions or other charges imposed by broker- dealers or other entities for executing and/or clearing transactions; (ii) transaction fees (e.g. sales loads or deferred sales charges) related to investments in collective investment vehicles (e.g. mutual funds); (iii) dealer markups or markdowns; (iv) costs relating to trading in foreign securities; (v) expenses charged by a retirement plan, (vi) costs related to individual retirement accounts; (vii) charges imposed by law; and (viii) custodial fees. Therefore, you should carefully review all the documents related to your account for a full description of any such fees. You should consult your tax professional regarding any tax consequences related to the liquidation of your account. Referrals to Third-Party Investment Advisers Grove Point Advisors also has access to and recommends investment advisory programs in which third- party investment advisers manage clients’ assets. These programs provide clients the opportunity to receive the investment management expertise of a diverse set of advisers that specialize in different asset classes, investment styles and portfolio management techniques. To ensure the third-party investment advisers and their approaches to portfolio management are suitable for clients and consistent with their investment objectives and financial circumstances, Grove Point Advisors conducts due diligence of third-party investment advisers before they are added to the platform of advisers available to Grove Point Advisors clients. Grove Point Advisors also conducts diligence of third-party investment advisers on an ongoing basis to ensure they continue to be suitable for Grove Point Advisors clients. Based on a client's individual circumstances and needs, Grove Point Advisors’ IARs will recommend an appropriate investment advisory program to the client. Factors considered in making recommendations include account size, risk tolerance, the needs and financial characteristics of the client, and the investment philosophy and approach of the third-party investment adviser. Grove Point Advisors will provide this information to the program sponsors selected by the client. The services that Grove Point Advisors and our IARs provide vary from program to program. In some third-party programs, neither Grove Point Advisors nor the IARs provide investment advice regarding the investment of client assets that are in the programs. With other third-party programs, Grove Point Advisors and our IARs provide investment advice with respect to these assets that are distinct from the advice the third-party advisers provide. These services are summarized below. Form ADV Part 2A March 28, 2024 Page 12 of 38 Co-Advisory Relationship
• AssetMark Privately Managed Account Program. The IAR provides advice as to the investment of the client’s portfolio based on the client’s objectives and instructions and is responsible for determining that the strategy selection for the client’s portfolio is suitable based on these objectives and instructions. The IAR is available to the client for consultations regarding the administration of the account and the client’s financial situation and investment objectives.
• Buckingham Strategic Wealth Program. The IAR provides advice as to the investment of the client’s portfolio based on the client’s objectives and instructions and is responsible for determining that the strategy selection for the client’s portfolio is suitable based on these objectives and instructions. The IAR is available to the client for consultations regarding the administration of the account and the client’s financial situation and investment objectives.
• Envestnet Asset Management, Inc. An advisory program, which is sponsored by Envestnet Asset Management, Inc., that provides clients with a portfolio of securities consistent with the client’s investment objectives, risk tolerance and investment time horizon.
• Manning & Napier. The IAR provides advice as to the investment of the client’s portfolio based on the client’s objectives and instructions and is responsible for determining that the strategy selection for the client’s portfolio is suitable based on these objectives and instructions. The IAR is available to the client for consultations regarding the administration of the account and the client’s financial situation and investment objectives.
• Morningstar Managed Portfolios. Grove Point Advisors’ IAR reviews the client’s responses to the program questionnaire and assists the client in determining the most appropriate portfolio for the client from among the portfolios available under the program. Furthermore, the IAR is responsible for determining whether the client’s clearing and custody fees are charged on an “asset” or “per transaction” basis.
• SEI Asset Management Program. Under this program, client grants Grove Point Advisors and the IAR a limited power of attorney with respect to trading authorization so that the IAR can instruct the custodian of the account to reallocate the client’s investments in accordance with the client’s asset allocation policy, and so that Grove Point Advisors and the IAR can direct the custodian to rebalance the investments within the account at least quarterly. Referral Relationship Grove Point Advisors has entered into agreements with various third-party investment advisers that participate in, manage, or sponsor different types of money management services and investment advisory programs. Depending on our relationship with the third party, our IARs may refer clients for such third parties, in which case Grove Point Advisors will not provide investment advice or have discretionary authority over your assets. These referral arrangements are structured in accordance with the rule 206(4)-1 under the Investment Advisers Act of 1940 (“Advisers Act”) which requires, Form ADV Part 2A March 28, 2024 Page 13 of 38 among other things, that Grove Point Advisors disclose to you that compensation will be provided to the IAR when you become a client of the Money Manager; whether the IAR is currently a client of the Money Manager that is being recommended and any associated conflicts of interest that exist. Examples of common conflicts are: a) Whether the IAR receives business expense or marketing reimbursements from the Money Manager or b) whether the Money Manager refers prospects to the IAR in turn for their recommendation to you. Where Grove Point Advisors acts solely as a referrer, you will not enter into an agreement directly with Grove Point Advisors and Grove Point Advisors is not responsible for the services provided by the third- party investment adviser. In such an arrangement, you establish a direct relationship with the third- party investment adviser, and Grove Point Advisors will receive a referral fee from the adviser based on a percentage of the advisory fee they charge you. The amount of the fee varies by the referral arrangement with a maximum fee of 3%. The referral disclosure you receive when you establish an account with the third-party adviser will specify the total fee you will be charged, and what portion of that fee is payable to Grove Point Advisors. You should read the third-party adviser’s brochure and any compensation disclosure statements provided in connection with these referral arrangements for information regarding the services of the third-party adviser and applicable fees and charges. With respect to all third-party investment advisory programs, Grove Point Advisors will meet with the client on a regular basis, or as determined by the client, to review the account. Grove Point Advisors will contact the client on at least an annual basis to review the client's investments and to determine whether the client wishes to impose or modify reasonable restrictions on the management of their account. Grove Point Advisors will also provide updated information about the clients' financial circumstances as necessary to program sponsors. Every client that has selected a third-party investment adviser should receive a copy of the adviser’s Form ADV 2A disclosure brochure. This document should be reviewed carefully as it will contain details about the third-party investment adviser, its advisory business, methods of analysis and investment strategies, fees, conflicts of interest, and other important information. Retirement Plan Services We provide services to pension, retirement, and profit-sharing plans and to the sponsors of such retirement plans. Grove Point Advisors, through its IARs, provides fiduciary services under the Employment Retirement Income Security Act of 1974, as amended, which include investment policy statement consultation and review, performing due diligence review on and recommending investment options, and monitoring investment performance. We also provide various non-fiduciary services, including but not limited to assistance with provider selection and participant enrollment and education. To receive retirement plan services, you are required to execute a retirement plan advisory services agreement. For more detailed information about the services, see the retirement plan advisory services agreement that you entered into with Grove Point Advisors. The retirement plan advisory services agreement may be terminated at any time by either party upon written notice to the other party. Form ADV Part 2A March 28, 2024 Page 14 of 38 Management of Client Assets Grove Point Advisors manages client assets on both a discretionary basis and a non-discretionary basis. As of December 31, 2023, Grove Point Advisors had a total of $2,359,870,084 in assets under management, with $424,988,720 of such assets managed on a discretionary basis, and $1,934,881,364 of such assets managed on a non-discretionary basis.