A. Firm Information Steel Grove Capital Advisors, LLC (“Steel Grove” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Tennessee. Steel Grove was founded in 2001 and is owned and operated by Steven W. Sanson (Managing Member). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Steel Grove. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Steel Grove's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. If you have any questions about the content of this Disclosure Brochure, please contact our Chief Compliance Officer (“CCO”), Craig Sneed at (901) 498-6300. B. Advisory Services Offered Steel Grove offers investment advisory services to affluent individuals and families, trusts, estates, charitable organizations, corporations, and business entities (each referred to as a “Client”). Wealth Management Services Steel Grove provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and/or non-discretionary investment management and related advisory services. Steel Grove works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Financial Planning Services – Financial planning services are provided as a component of wealth management services, but may also be offered as a stand-alone engagement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to:
• Trust & Estate Planning
• Retirement Planning
• Cash Flow Analysis
• Consolidated Reporting
• Wealth Transfer
• Charitable Giving
• Tax Planning A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Steel Grove may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Page 5 Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Investment Management Services – Investment management services are provided as a component of wealth management services. Steel Grove will

typically diversified portfolios of mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, options, affiliated managers, and/or private placements (e.g., hedge funds, private equity, etc.). The Advisor may also advise on a Client’s legacy holdings or held- away assets, such as concentrated stock positions, employer-sponsored retirement plans, annuities and/or 529 plans. Steel Grove’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Steel Grove will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Steel Grove evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Steel Grove may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Steel Grove may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Steel Grove may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Under certain circumstances, Steel Grove may accept or maintain custody of Client’s funds or securities. Please see Item 15 – Custody for more information. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No Client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging Steel Grove to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Steel Grove, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Steel Grove will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. Page 6
• Portfolio Construction – Steel Grove will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Steel Grove will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Steel Grove does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Steel Grove. E. Assets Under Management As of December 31, 2023, Steel Grove manages $1,355,751,329 in Client assets, $1,131,305,648 of which are managed on a discretionary basis and $224,445,681 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.