Grand Wealth Management, LLC (also referred to as “we” and “our”) is an independent investment advisory and financial planning firm that serves select individuals, families and institutions. We provide the following services, described in further detail below:  Wealth Management Services  Institutional Investment Management Services  Retirement Plan Advisory Services  Portfolio Management Services  Financial Planning and Consulting Services We are a fee-only firm, which means our only compensation comes from our clients and not from any other individual or entity. We do not sell any commissioned products such as annuities and insurance, nor do we accept commissions in any form, including fees from mutual fund companies whose funds we recommend to clients. Grand Wealth Management serves as a fiduciary to clients. As a fiduciary, we uphold a duty of loyalty, fairness and good faith towards each client and seek to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Grand Wealth Management was founded in 2004 and is wholly employee owned. Principal owners are Jeffrey S. Williams and Steven A. Starnes. As of December 31, 2023, Grand Wealth Management managed $604,519,119 in regulatory assets under management on a discretionary basis. Wealth Management Services Grand Wealth Management offers wealth management services to individuals, including business owners, professionals, executives, retirees and their family members. Wealth management combines discretionary investment management with financial planning to deliver a personalized experience for each client. We use a systematic wealth management process to determine and implement a plan that is best suited to each client. This process is designed to enable us to: 1. Understand each client’s true goals, needs, concerns and opportunities; 2. Create the best possible plan for achieving those goals; and 3. Keep track at each step of the process. The result of the process is a written wealth management plan, which includes an assessment of the client’s current situation as well as recommendations for repositioning the client’s portfolio. Recommendations take into account portfolio costs as well as the potential tax impact of the restructuring. We offer an initial complimentary consultation to review the client’s needs and objectives, and may provide a written plan describing our recommendations at no cost. However, wealth management services are initiated only with the execution of an investment management agreement and investment policy statement. Regular progress meetings are scheduled to discuss any new developments in the client’s personal or financial situation and to review the client’s investments. Investment reviews entail analyzing client portfolios to help ensure the investment strategy and expectations are structured to continue to meet the client’s stated needs and objectives. While we encourage regular client contact, the frequency and timing may vary depending upon the client’s situation or desires, but will typically occur no less than annually. Based on the client’s situation, needs and objectives, wealth management services also include financial assessment and planning. Financial planning may address specific client needs such as retirement planning, tax planning, charitable planning, succession planning, risk management, education funding, major purchases, business planning and estate planning. We may provide comprehensive planning services or the client may desire advice on certain planning components. Use of Independent Managers Grand Wealth Management may recommend that a client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a client’s investment portfolio. In such instances, the client may be required to authorize and enter into an advisory agreement with the Independent Manager that defines the terms in which the Independent Manager will provide investment management and related services. We may also assist in the development of the initial policy recommendations and managing the ongoing client relationship. We will perform initial and ongoing oversight and due diligence over the selected Independent Manager to ensure the Independent Manager’s strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The

client, prior to entering into an agreement with unaffiliated investment manager or investment platform, will be provided with the Independent Manager’s Form ADV2A (or a brochure that makes the appropriate disclosures). Retirement Accounts When Grand Wealth Management provides investment advice to clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), we are 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, we 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 we 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 us. Institutional Investment Management Services Grand Wealth Management offers institutional investment management services for foundations and endowments, corporations and other business entities. Institutional investment management involves developing, implementing and monitoring investment programs for institutional funds. We structure a prudent investment approach designed to meet the fiduciary standards of care. A data gathering process is completed in an effort to determine the client’s needs, goals, objectives, time horizons and any other relevant information. Based upon information provided by the client, and with the client’s input, we prepare an investment policy statement, including a target asset allocation. With the approval of the client, the recommended investment policy statement is implemented and managed in an effort to help achieve the client’s goals. Retirement Plan Advisory Services Grand Wealth Management delivers investment advisory and management solutions to employer- sponsored retirement plans. Specifically, our services include: (1) discretionary investment management services, (2) nondiscretionary investment advisory services, and/or (3) consulting services. Depending on the type of the plan and the specific arrangement with the client, we may provide one or more of these services. When providing investment advisory and/or management services to retirement plans covered under the Employee Retirement Income Security Act (“ERISA”), we acknowledge our status as a “fiduciary” under Section 3(21) with respect to the investment-related services described in our investment fiduciary and retirement plan consulting agreement. We may also exercise discretion over select plan investments and serve as an “investment manager” as defined under ERISA Section 3(38). As a fiduciary under ERISA, we will act solely in the interests of plan participants and beneficiaries with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. Portfolio Management Services At our discretion, we may offer portfolio management services for those who would not otherwise meet the minimum criteria for wealth management services. Portfolio management utilizes the same discretionary investment management approach provided to wealth management clients, but does not include comprehensive financial planning. Our recommendations are presented to each client based on their circumstances. As with wealth management services, portfolio management services are initiated only with the execution of an investment management agreement and investment policy statement. Financial Planning and Consulting Services At our discretion, we may offer financial planning and consulting services at an hourly rate or at a fixed fee project rate for those who do not desire comprehensive wealth management or other ongoing investment management services. Financial planning and consulting services may address general financial matters or be focused on particular issues, depending upon the client’s needs. Topics may range from overall investment advisory questions, research and analysis, discussions pertaining to the financial impact of a life event, assistance with goals and objectives, or various issues as may be requested by the client.