GIM was incorporated on December 1, 1999. L. George Rieger joined GIM on January 1, 2007. L. George Rieger owns 85 percent of GIM, and Peter L’H. Courtney owns 15 percent. THE ADVISORY SERVICE OF GIM GIM advises persons and institutions to allocate their savings to financial assets whose characteristics are explained in this descriptive material. GIM describes such persons or institutions as clients of GIM. GIM’s only source of revenue is the fees that GIM charges clients for investment counsel. In this descriptive material, we describe the relationship between GIM and clients as the Client-Counsel Relationship. GIM assigns to clients a team that consists of the primary or senior adviser, the associate adviser, and a client liaison for administrative client services. The GIM client may select client’s senior advisor. The senior and associate advisors have the responsibility to develop with the client the Statement of Investment Objectives (SIO). Each SIO is unique to the client’s needs, requirements and important characteristics. The SIO includes an overview of the investment strategy to be employed and types of assets that will be used to meet client objectives. The Client-Counsel Relationship commences with a thorough review of client’s financial and personal circumstances. The purpose of the review is to quantify how a client’s financial assets will meet the needs and objectives of the individual or institution. GIM tailors its investment advice, account investment strategy and risk tolerance as described in the completed SIO. Clients may direct, influence, suggest, restrict and otherwise control assets in client’s portfolio. Such restrictions may affect the composition and performance of the client’s portfolio. The performance of client portfolios will not be uniform because of differences in strategy and tactics that reflect client preferences. Client service is an important part of the GIM culture. GIM’s goal is to make accessible to every client the investment and administrative personnel and resources of the firm. Clients are able to communicate with GIM personnel directly, and through the GIM website. Periodically, clients have in person meetings with GIM advisors. THE SCOPE OF GIM INVESTMENT SERVICE GIM is not an asset allocator. GIM specializes in the analysis and management of financial assets that offer what GIM considers a generous level of current income. The income that clients receive is either dividends or interest. Dividends come from the ownership of common stock. Interest comes from ownership of fixed income securities such as bonds. Bonds may account for 0 percent to 100 percent of client’s assets. Equities may account for 0 percent to 100 percent of client’s assets. The SIO as defined above describes the allocation of client assets between bonds and equities (for more information on concentration risk and fixed income assets managed by GIM, please refer to Item 8). As discussed above, GIM emphasis is current income as the primary objective for GIM Clients. There are two kinds of current income. One is taxable to the client (investor) and consists of interest, dividends or distributions from partnerships. The other is income that is exempt from federal income taxes. The lawful avoidance of federal income taxes is the objective of many GIM clients. Such clients typically select tax-exempt bonds as the dominant asset in client’s portfolio. Many clients of GIM have all of their portfolio invested in bonds whose income is federally tax exempt. THE UNIVERSE OF POTENTIAL INVESTMENTS GIM purchases and manages money denominated instruments that trade on established stock and bond exchanges in the United States. Historically, GIM has not purchased assets in any foreign country other than Canada and has not purchased exchange-traded funds, open-end mutual funds (except money market funds), derivatives, auction rate securities or commodities. GIM client portfolios may include both Equity and Fixed Income assets. Additional information on GIM’s investment strategies, methods of analysis and the risk of loss on investment can be found in Item 8 of this descriptive material. DEFINITION OF “RETURN” GIM defines return as the literal return of money from an investment to its owner. Return defined by GIM consists of dividends from common stocks and interest from bonds, or fixed income securities. GIM does not define “return” as the increase or decrease in the market value or price of a security. In the GIM strategy, capital appreciation and capital depreciation are not a return. The sale of an asset at either a profit or a loss is a capital transaction and does not constitute income. The financial community uses the phrase “total return” to describe the combination of cash income and change in market value. GIM believes that the phrase “total return” combines two distinct events. “Total return” may mislead investors to believe that an increase or decrease in market value of an asset is a return. Believing that rising market value is a return may lead an investor to spend the “money in the newspaper.” GIM designs its investment strategies, policies, and tactics to generate money in the bank. The money received as cash distributions is money in the bank. Unrealized decrease in market value is not money withdrawn from a bank. CALCULATION OF PERFORMANCE GIM’s portfolio management software, calculates performance in accordance with accepted standards. Client may request a detailed description of performance calculation. The most important fact of performance calculation is that monthly compounding links total return (market value change, plus income). The compounding of performance gives credit to the manager for earning income even if client elects to spend it. FIXED INCOME MANAGEMENT BY GIM GIM specializes in the analysis, acquisition and ownership of a particular type of fixed income security, Private Activity Bonds (PAB). PABs are issued by a state or the agency of a state. The word “agency” includes any entity that has the authority to issue bonds for purposes that benefit the state and the public at large. State agencies include entities such as marine and airport authorities, transportation authorities, authorities that sponsor health, education, senior living, charter schools and detention centers. Such projects and bonds typically depend on revenue derived from use of Property Plant and Equipment (PP&E). In the marketplace, these bonds are referred to as “Revenue Bonds.” The bonds issued by such authorities and agencies may have no rating by any of the three nationally recognized agencies such as Moody’s, Standard & Poor’s Corp. or Fitch. GIM has focused its resources on the analysis, ownership and management of such agency bonds that have no rating. Bonds favored by GIM finance the construction of PP&E. The PP&E is the collateral for the obligation to repay indebtedness and is secured by first mortgage and other forms of liens. The face value of bonds outstanding may account for 100 percent or more of a project’s PP&E or appraised value. In most cases at inception, the property itself is valued at less than the debt outstanding. Over time, debt amortizes, and the value of the collateral may be greater than the debt outstanding. In 2021 and 2022, GIM experienced rising defaults by projects that serve the “senior citizen” market. Such projects typically have Independent Living Units (ILU), Assisted Living Units (ALU) and Memory Care (MC). The COVID pandemic materially contributed to severely adverse operating conditions for the projects. The COVID pandemic overtaxed management and exacerbated adverse conditions at the property level. Senior care projects generally continue to suffer from both staff shortages and increased cost of staff. Senior care managements across the country have had difficulty passing increased costs through to residents. The impact on GIM bonds is decreased debt service coverage and increased defaults. In 2023, GIM continued to work on remediation of defaulted bonds. Security Cusip Austin Village Sen Liv Proj Ser B Tax Pub Fin Auth 74443ubu6 Austin Village Senior Liv Proj Ser A Public Fin Auth 74443ubt9 Avondale Senior Living Ser A SC Jobs EDA 837031zp1 Avondale Senior Living Taxable Ser B SC Jobs EDA 837031zq9 Beach House At Wiregrass Ranch Fl Cap Trust Agency 140532bp6 Bridgemoor Senior Living New Hope Cultural Ed Facs Fin Corp Tex Sr Living 64542per2 Bridgemoor Senior Living New Hope Cultural Ed Facs Fin Corp Tex Sr Living 64542pgh2 Dahlonega Senior Living Public Fin Auth Wis Sr Living Rev 74443ucj0 Fountains Of Hope Proj Ser 2017 Capital Trust Agency 14052wda2 Fountains Of Hope Proj Taxable Ser 2017 Capital Trust Agency 14052wdb0 Harvest Gold Silica Proj Amt Arizona Indl Dev Auth Rev 04052abb1 Harvest Gold Silica Proj Taxable Arizona Indl Dev Auth Rev 04052abc9 Harvest Gold Silica Proj Taxable Arizona Indl Dev Auth Rev 04052abf2 Harvest Gold Silica Proj Taxable Arizona Indl Dev Auth Rev 04052abg0 Liberty Park Senior Living Jonesboro Ark Residential Hsg & Healthcare Facs 48026caa0 Liberty Park Senior Living Jonesboro Ark Residential Hsg & Healthcare Facs 48026cab8 McClellan Assisted Living Fac Lp Proj Ser A 579501aa5 Meredith Bay Colony A Club New Hampshire St Business Sr Hsg -Ser A 64468kba3 Meredith Bay Colony Club New Hampshire St Business Sr Hsg -Ser B 64468kbb1 Renaissance Senior Living South Carolina Jobs-Economic Dev Auth 837031xs7 River Park Independent Living Proj Ser A Sc Jobs Eda Econ Dev Rev 837031yt4 River Park Independent Living Proj Ser B Taxable Sc Jeda Econ Dev Rev 837031yu1 River Park Independent Living South Carolina Jobs-Economic Dev Authority 837031yt4 Tallahassee Tapestry Capital Tr Agy Fla Rev 14052wch8 Tallahassee Tapestry Capital Tr Agy Fla Rev 14052wck1 Tallahassee Tapestry Capital Tr Agy Fla Rev 14052wcl9 Tapestry Moon Pennsylvania Economic Dev Auth Rev 70869ply1 Tapestry Walden Capital Tr Agy Fla Rev 14052wcy1 Tapestry Walden Capital Tr Agy Fla Rev 14052wcv7 Tapestry Wickliffe Lake County Port And Economic Development Authority 50944tad2 Tapestry Wickliffe Lake County Port And Economic Development Authority 50944tac4 Tuscan Gardens Delray Beach Palm Beach County 69655qaa3 Tuscan Gardens Delray Beach Palm Beach County 69655qab1 Tuscan Gardens Palm Coast Capital Tr Agy Fla Rev 14052wcr6 Tuscan Gardens Palm Coast Capital Tr Agy Fla Rev 14052wcn5 Tuscan Gardens Palm Coast Capital Tr Agy Fla Rev 14052wcs4 Woodbridge Clinton Senior Living Sc Jobs Economic Dev Auth Rev 837031xp3 Woodbridge Clinton Senior Living Taxable Sc Jobs Economic Dev Auth Rev 837031xq1 The number and collective size of the challenged projects has surpassed GIM’s remedial resources, both personnel and liquidity. A defaulted project imposes two immediate costs on GIM. The first is legal counsel. The second is the possible injection of GIM liquidity into the project to stabilize operations. An example is the Sarasota, Florida

Fountains Of Hope Proj Ser 2017 Capital Trust Agency project. Through March 2023, GIM and related entities have invested, loaned, or otherwise provided financial support of approximately $1.45 million to keep the project operationally supported. Another project that has been a drain on GIM resources is Arizona Industrial Development Authority Revenue Bonds (Harvest Gold Silica Project-Congress, Arizona) Series 2019 (AZ) (Cusips: 04052abb1, 04052abc9, 04052abf2, 04052abg0). GIM as Bond Holder Representative is in litigation with the underwriters. We seek the rescission of the transaction through our law firm in Denver, Colorado. GIM pursues and funds a separate action through our counsel in Tallahassee, Florida for the appointment of a receiver to sell the silica for repayment of the bonds. GIM estimates that the total cost of the two lawsuits will be not less than $1,500,000. In March 2024, the Federal district Court in Phoenix, Arizona ruled against GIM’ claim of standing to sue on behalf of clients. GIM believes that our clients are entitled to a trial on the merits and have asked the trial judge to amend his ruling. GIM intends to pursue all possible remedies to recover clients’ investments in projects that have defaulted. The cost of our remedial efforts may exceed our resources. In 2023, we completed Sawgrass Grand with substantial loss of principal in client portfolios. The negative developments described above have damaged the reputation of GIM and led to client attrition. GIM has experienced a decline in revenue that diminishes GIM’s ability to remediate challenged projects. GIM will underwrite projects in the $3-$20,000,000 range and avoid completely senior care projects. In respect to the latter, GIM may make an exception when the new bond is to finance expansion of a successful project. The subjects that we describe above are complex. GIM welcomes client inquiry and meetings during which we will provide details and background on challenged projects. SINGLE HANDED BOND TRANSACTIONS DEFINED GIM may direct the purchase of entire bond issues into GIM client portfolios. GIM believes that its purchase of entire bond issues for allocation among client portfolios is unusual or atypical of traditional RIA’s. We believe that single handed transactions are advantageous for the reasons discussed in this ADV and in client’s SIO. Clients and prospective clients should be aware that the management of single handed bonds is a complex activity. There are potential benefits as well as potential risks. The benefits and risks of ownership of single handed bonds require thorough explanation and careful consideration by prospective clients. GIM negotiates the purchase of the entire bond issue and allocates the bonds among client portfolios. At that moment what is the “market” for the bond? There may or may not be a market in the common use of the word. Certainly, there is no auction market such as exists for publicly traded common stocks. What we state here would apply to any PAB that is a new issue for the construction of a project. If the bonds issuance price is 100 (par), the presumed value of the bonds is 100. That presumed value holds whether one entity controls the entire issue, or five entities control the entire issue. Remember that we are describing Private Activity Bonds (PABs) not typical tax-exempt bonds offered to the general public in $5,000 denominations. The GIM single handed bond is similar to bonds purchased by the tax- exempt high yield mutual funds. Prior to 2021, GIM single handed bonds typically were issued in $25,000 denominations. The least dollar investment was $25,000. In 2021, GIM purchased new issues in $5,000 bond denominations. GIM expects new bond issues to be in $5,000 denominations. Greenwich Investment Management, Inc., is deemed a Bond Holder Representative (BHR) and shall serve as Bond Holder Representative by written designation by beneficial owners of a majority, in aggregate, principal amount of bonds. Rights of Bond Holder Representative may have negative impact on liquidity. Specifically, among other powers, the Bond Holder Representative has the right to approve certain modifications involving an extension of the maturity of, or a reduction of the principal amount of, or a reduction of the rate of, or extension of the time of payment of interest on, or a reduction of a premium payable upon any redemption of a bond issue. GIM has the authority and the obligation to represent our clients and enforce these security provisions as Bond Holder Representative. It is important for clients to consider the illiquid nature of these bonds and their size denominations, as it could impact the ease of liquidating such investments. If a client terminates GIM’s management with odd lot denominations or otherwise has holdings lower than the minimum denominations discussed in the bond offering documents, liquidity can be severely impaired. However, Municipal Securities Rulemaking Board (MSRB) allows for the sale of bonds below the stated minimum denominations. Upon a client portfolio liquidation request, GIM will use its best efforts to meet client liquidations. Please speak with your GIM representative for more information and refer to important information in the investment Offering Statement. GIM financed projects, including but not limited to senior living facilities, charter and private schools may require as much as 24 months for construction to be completed. During construction, the only market for GIM bonds may be within the GIM client population. In this development phase of a project’s life GIM assumes that the value of the issued bonds is par. Interest rate fluctuations and changes in the surrounding circumstances may cause price fluctuations. We invite all GIM clients to meet with your portfolio management team to discuss the concept and facts of PAB management at GIM. CROSS TRADING OF PRIVATE ACTIVITY BONDS BY GIM GIM developed a policy that we believe benefits existing and new clients, which is the cross transaction of GIM bonds within our client portfolios, resulting in the rebalancing of client portfolios and continuity of interests. GIM defines such a sale and purchase as a “client cross transaction.” GIM effects the transaction through an independent bond broker familiar with PABs. We trade through SEC or FINRA regulated fixed-income trading firms known for their expertise or experience in PABs. Typically, professional bond traders with expertise in the specific PAB bond will execute transactions by independently identifying the market bid and ask in the public market. In instances where the transaction price of a bond may not be readily available, GIM may require the broker to seek bids for the bonds in the open market. The public market determines price discovery. A client cross transaction occurs “at arm’s length,” independent of GIM’s influence. The transacting broker determines the market price for the transaction. The transacting broker executes the transaction at a price that is expected to fairly represent the interests of both the seller and the buyer. GIM maintains data files of prices for bond transactions. Those data files are available for inspection by GIM clients. Clients of GIM are invited to discuss any bond transaction with their GIM portfolio team. During episodes of market volatility, price determination may be difficult to ascertain and may reflect economic and market dynamics. Independent brokers will analyze the comparative prices at recently traded transactions and will use available market data to fairly determine bond prices. In discretionary portfolios, GIM utilizes client cross transactions in the best interest of clients wanting to rebalance cash and fixed income portfolios. GIM’s goal is in the best interest of the clients single handed bond asset diversification across client portfolios. Principals of GIM and their family members are clients of GIM and are proponents of the investment strategy. As such, principals and their families participate in client cross transactions. Upon request, GIM will give to clients, records of principal bond transactions. THE COST OF TRADING GIM PRIVATE ACTIVITY BONDS GIM clients pay broker commissions for trading common stocks and bonds. GIM works to minimize trading expenses. GIM receives no compensation for transacting client trades from executing bond brokers. The following are rules of thumb. There may be exceptions. When GIM trades bonds for projects under construction the following applies. Typically, the price will be par ($100), and the seller will pay the commission or spread. The seller will receive $99.80, and the buyer will pay $100. If the seller owns (example) $100,000 of a 4% bond for 12 months and sells to another GIM client, the seller will have earned $4,000 in interest and experience a capital loss of $200. For bonds of seasoned projects, the price is determined by examining the pricing service’s price, the most recent financial statements from the borrower and all other potentially relevant information. For seasoned projects’ bonds the traded price will usually be the median price with the seller and buyer paying an equal commission. For instance, if the median price selected by the broker is $103, the seller will receive $102.75, and the buyer will pay $103.25. In some cases, the entire cost of the transaction may be paid by the buyer or seller. GIM BONDS NOT REGISTERED WITH THE SEC Bonds issued by the 50 states and their agencies are not registered with the SEC. Such bonds and all GIM recommended bonds are the subject of an Official Statement (OS) issued by a state or an agency of the state. GIM clients are welcome to inspect Official Statements and the due diligence files of GIM that relate to GIM bonds. Official Statements and other disclosures are available on the Electronic Municipal Market Analysis, website https://emma.msrb.org/ which is a service offered by Municipal Securities Rulemaking Board (MSRB). Municipal bond transactions are available for view on EMMA. THE FIDUCIARY ROLE OF GIM In 2019, The SEC issued a clarification of the law. The clarification stated that an RIA functions in service to clients as a fiduciary. The precise meaning and consequences of the clarification remain murky. COMMON STOCK (EQUITY) MANAGEMENT BY GIM GIM may purchase common stocks for GIM clients. Common stocks may account for 0 percent to 100 percent of a client’s assets. The SIO describes the allocation of client assets between bonds, equities and other assets as deemed suitable by GIM. (for more information on concentration risk and equity assets managed by GIM, please refer to Item 8). ASSETS MANAGED ON A DISCRETIONARY BASIS On December 31, 2023, GIM managed $588,066,198 of securities on a discretionary basis. On December 31, 2023, GIM client portfolios held $4,632,016 of securities on a non-discretionary basis.