GFG Capital is a registered investment adviser owned by GFG Holdings, LLC. GFG Holdings, LLC is owned by Mr. Eduardo Gruener, Mr. Mauricio Gruener, and Mr. Leon Perez. GFG Capital was registered with the SEC in August 2003 and has total regulatory assets under management of USD $838,257,753 as of December 31, 2023; USD $811,016,685 in discretionary assets and USD $27,241,068 in non-discretionary assets. GFG Capital focuses on providing a combination of investment services based on each client's individual goals and circumstances. Through in-depth personal discussions with clients, GFG Capital develops a client's investment portfolio, determining with each client an appropriate investment strategy and risk tolerance model. Once an appropriate model has been determined, GFG Capital will either: (i) invest a client’s assets in various asset classes, matching the investment strategy determined with the client; or (ii) manage a portion of a client’s assets in ETFs and/or mutual funds and retain a separate independent registered investment advisers (herein “Independent Managers”) for the remaining portion of the client’s assets. The determination to retain an Independent Manager to advise on a portion of the client’s assets is based on the investment strategies determined and risk tolerance preferred. Generally, GFG Capital's investment recommendations are based on long-term investment strategies. GFG Capital Investment Management Services GFG Capital will manage portfolios primarily consisting of a mix of mutual funds and ETFs and, as appropriate, portfolios of fixed income and equity securities. As discussed, GFG Capital's management services may be offered in circumstances when GFG Capital determines that an Independent Manager may not add value or meet the client's needs, or if a client's portfolio does not meet account minimums set out by the relevant Independent Managers. In addition, some clients may request GFG Capital’s investment management services. GFG Capital employs various asset allocation models (conservative, moderate, growth, focused growth, quality focus, fixed income, and cash management) as a basis for working with a client to establish an appropriate investment strategy. All portfolios are separately managed based on the clients’

individual considerations such as liquidity requirements, cash flow and risk tolerance. Once an appropriate asset allocation has been established, GFG Capital will manage the clients' assets on a continuous basis within the parameters of the model. GFG Capital will rebalance the portfolio periodically, based on the clients’ financial goals and their individual needs. Clients have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio and retain individual ownership of all securities. Independent Manager Searches GFG Capital will perform searches of Independent Manager(s) to manage specific portions of a client's investment portfolio. GFG Capital will determine which Independent Manager(s) is(are) appropriate for the client based on the individual needs and circumstances of the client. Factors considered in making this determination include the sum of investments relative to the total dollar value of the client’s advisory portfolio, the client’s stated risk tolerance, the client’s prior experience with investments, and the investment philosophy of the Independent Manager. GFG Capital will allocate the client’s assets to/from the Independent Manager, taking into consideration the client’s objectives and the overall management style selected by the client. GFG Capital may utilize an investment platform to allocate clients’ assets among Independent Managers, such as a managed account solution. The client should refer to the Independent Manager’s Form ADV disclosure document (or other disclosure brochure in lieu of the Form ADV disclosure document) for information regarding the investment strategies, fees, qualifications and brokerage practices of that Independent Manager. GFG Capital will continuously monitor all Independent Managers on behalf of the client, review the performance of each Independent Manager against appropriate benchmarks, and review the investment style of the Independent Manager against the client's investment parameters to ensure the Independent Manager continues to meet the client's investment goals. GFG Capital will request the discretion to hire and fire Independent Managers on a client's behalf. GFG Capital has discretionary and nondiscretionary relationships with clients to hire and fire Independent Managers.