Individual Portfolio Management Fees .......................................................................................................................................................... 5 Wealth Advisory Fees ...................................................................................................................................................................................... 6 Consulting Services Fees ................................................................................................................................................................................. 6 General Information ....................................................................................................................................................................................... 6 Item 5 Performance-Based Fees and Side-By-Side Management ...................................................................................................................... 7 Item 6 Types of Clients ........................................................................................................................................................................................ 7 Item 7 Methods of Analysis, Investment Strategies and Risk of Loss................................................................................................................. 7 Methods of Analysis ........................................................................................................................................................................................ 7 Investment Strategies ...................................................................................................................................................................................... 7 Risk of Loss ...................................................................................................................................................................................................... 7 Item 8 Disciplinary Information ......................................................................................................................................................................... 7 Item 9 Other Financial Industry Activities and Affiliations ............................................................................................................................... 7 Item 10 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................................... 8 Item 11 Brokerage Practices ................................................................................................................................................................................ 9 Item 12 Review of Accounts .............................................................................................................................................................................. 10 Individual Portfolio Management ................................................................................................................................................................ 10 Item 13 Client Referrals and Other Compensation .......................................................................................................................................... 10 Item 14 Custody ................................................................................................................................................................................................ 10 Item 15 Investment Discretion .......................................................................................................................................................................... 11 Item 16 Voting Client Securities ....................................................................................................................................................................... 11 Item 17 Financial Information .......................................................................................................................................................................... 11 Item 18 Other Information ............................................................................................................................................................................... 11 Cybersecurity ................................................................................................................................................................................................. 11 Identity Theft ................................................................................................................................................................................................. 12 Disaster Recovery .......................................................................................................................................................................................... 12 Item 3 Advisory Business Gryphon Advisors, LLC ("Gryphon") services consist primarily of coordinated wealth advisory services based upon an analysis of a client's specific situation (including risk tolerance, investment horizon, rate of return objectives) and development of a group of strategies and tactics designed to achieve the client's goals and objectives. In general, the wealth advisory process will address tax planning, estate planning, risk management, education funding, cash flow and debt management, investment planning and management and any other area that may be important to the specific client situation. Implementation of the strategies and tactics is entirely at the client’s discretion. Gryphon's services to a particular client may or may not include investment advisory services. In those cases where Gryphon does provide investment advisory services (providing continuous advice for the client based upon the client's individual need), Gryphon will develop an investment policy/allocation model that will guide the entire investment planning and management process. Investment implementation guidelines are jointly developed and agreed to on a quarterly or semi-annual basis. In general, implementation guidelines consider changing market and economic conditions that may require amendment to the original plan. Gryphon will implement or supervise the implementation of the investment plan on the client’s behalf. In general, investment performance is reviewed with the client on a quarterly basis. Gryphon also provides a variety of consulting or other services that would not be considered wealth advisory or investment advisory services. Examples of these services include business plan development, organizational development, tax compliance and succession planning. Gryphon Advisors, LLC is a SEC-registered investment adviser with its principal place of business located in Illinois. Gryphon Advisors, LLC began conducting business in 2006. Gryphon Advisors offers the following advisory services to clients: In di vi dual Po rtfo lio M anag e me nt Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review

and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's objectives, as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Open and closed end mutual fund shares
• United States governmental securities
• Options contracts on securities and commodities
• Futures contracts on tangibles and intangibles
• Interests in partnerships and private placements Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's investment objectives, tolerance for risk, liquidity and suitability. We al th Advi so ry We provide wealth advisory services. Wealth advisory services include comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the wealth advisory process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. In general, wealth advisory services may address any or all of the following areas:
• Cash flow and debt management
• Income and transfer tax planning
• Investment planning and management
• Risk management and insurance planning
• Retirement planning
• Education funding
• Estate planning We gather information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives and attitudes towards risk. Implementation of financial plan recommendations is entirely at the client's discretion. Con sul ting Servi ces Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, business planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Amo un t o f M an ag ed Assets As of 12/31/2023, we were actively managing $421,329,209 of clients' assets on a discretionary basis plus $88,999,529 of clients' assets on a non-discretionary basis. The specific manner in which fees are charged is established in a client’s written agreement with Gryphon Advisors. All fee agreements are negotiable. Clients may elect to be billed on a monthly or quarterly basis in arrears. Clients may also elect to be billed directly for fees or to authorize Gryphon Advisors to directly debit fees from client accounts. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Clients also agree to reimburse Gryphon for all expenses directly related to the client’s engagement. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Gryphon Advisors’ fees do not include brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment managers and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Gryphon Advisors’ fee, and Gryphon Advisors shall not receive any portion of these commissions, fees, and costs. In di vi dual Po rtfo lio M anag e me nt Fe es Fees for Investment Supervisory Services may be charged as a percentage of assets under management, a fixed fee or on an hourly basis according to the following schedules: Assets Under Management Fee Schedule
• First $5,000,000 - 0.25% per quarter
• Next $5,000,000 - 0.1875% per quarter
• Next $90,000,000 - 0.125% per quarter
• Over $100,000,000 - 0.09375% per quarter Hourly fees are determined according to the following fee schedule: Hourly fee schedule
• Partner $375 - 675
• Manager $200 - 375
• Associate $125 - 200
• Assistant $85 - 125
• Administrative $45 - 85 We may group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the annualized fee. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. Limited Negotiability of Advisory Fees: Although Gryphon Advisors has established the aforementioned fee schedule, we may negotiate alternative fees, such as fixed fees or hourly billing on a client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future assets, related accounts, portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between Gryphon and each client. We al th Advi so ry F ee s Gryphon Advisors' Wealth Advisory fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Our Wealth Advisory fees may be calculated and charged on an hourly basis, ranging from $45 to $675 per hour, a fixed fee basis or as a percentage of net worth. We may request a retainer upon completion of our initial fact-finding session with the client; however, advance payment will never exceed $500 for work that will not be completed within six months. The balance is due upon completion of the plan. The client will be billed in arrears on a monthly or quarterly basis as earned. Con sul ting Servi ces F ee s Gryphon Advisors' Consulting Services fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Our Consulting Services fees are calculated and charged on an hourly basis, ranging from $45 to $675 per hour. An estimate for the total hours is determined at the start of the advisory relationship. The client will be billed in arrears on a monthly or quarterly basis as earned. Ge ne ral In fo rmation Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of written notice. As disclosed above, certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. Mutual Fund Fees: All fees paid to Gryphon Advisors for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $500 more than six months in advance of services rendered.