Advisory Firm Description GFSA has been in business since May 2007. The principal owner is GFS Holdings, LLC (“GFS Holdings”). GFS Holdings is currently principally owned by Lee Equity Partners, LLC through intermediaries. In January 2018, an organizational restructuring occurred when GFS Holdings was created to replace Summer Wealth Management, LLC as the direct owner of GFSA. Like Summer Wealth Management LLC, GFS Holdings is 100% owned by Affiliated Wealth Partners Holdings, LLC (“AWPH”). Consequently, the restructuring did not result in changes to the management or ownership of AWPH, or in any of the holding company entities “above” AWPH in its corporate structure. Moreover, the restructuring did not result in a change of control or management of the investment adviser and is not an assignment for purposes of section 205(a)(2) of the Investment Advisors Act. Investment Advisory Services G FSA’s offers a fully customizable asset allocation and investment management program. The client retains GFSA and the Investment Adviser Representative (“Representative”) for the purpose of opening an investment advisory account (“Advisory Account”). An asset-based advisory fee (“Advisory Fee”) will be charged to clients based on the total aggregate assets in the investment advisory program. The Representative considers the client’s financial situation, goals and investment objectives, risk tolerance, time horizon, and other relevant factors, as described by the client, in selecting the client’s asset allocation. Using the investor questionnaire, the client’s Representative assists the client in selecting the portfolio allocation that best meets the client’s investment objectives, financial situation, and risk tolerance. Based on the c lient’s financial situation and completion of the investor questionnaire, a tailored asset allocation is chosen from a mix of equity and fixed income securities; but may also include alternative investments1 for certain qualified clients. An allocation is implemented using individual securities, mainly stocks and bonds, but could also include a combination of open-end mutual funds and exchange-traded funds (“ETFs”) with a broad range of asset classes, and alternative investments including private equity, private credit, and hedge funds. The Representative will manage and invest the assets in the Advisory Account on a discretionary or non- discretionary basis. If discretionary, the Representative will have limited trading authorization with respect to the Advisory Account and, as such, the Representative, in his or her sole discretion and at the client’s risk, can purchase, sell, exchange, convert, and otherwise trade the securities and other permitted investments in the 1 Alternative investments are a disparate group of investments that are distinguished from long-only, publicly traded investments in stocks, bonds, and cash (often referred to as traditional investments). Alternative investments include such assets as real estate, commodities, and non-traditional approaches to investing within special vehicles, such as private equity and hedge funds. Alternative investments often provide fund managers flexibility to use derivatives and leverage, to make investments in illiquid assets, and to take short positions. Alternative investments have many of the following characteristics: relatively low correlation of returns with those of traditional investments; less regulation and less transparency than traditional investments; limited historical risk and return data; unique legal and tax considerations; higher fees, often including performance or incentive fees; concentrated portfolios; and/or restrictions on redemptions. Consequently, alternative investments are suitable only for persons of adequate financial means who have no need for liquidity with respect to their investment and who can bear the economic risk, including significant loss of their investment. There is no guarantee

that any investment or allocation will achieve its objectives, generate profits, or avoid losses. Advisory Account. Neither GFSA nor its Representative will have authority to withdraw the assets in the Advisory Account or to transfer assets to a third party without written authorization from the client. Transactions in the investment advisory program may be executed through GFSA ’s affiliated broker-dealer, Global Financial Services, LLC (“GFS”), through which the Representatives of GFSA are licensed as broker-dealer representatives. Representatives of GFSA have the ability to earn additional compensation based on the level of net income achieved by the combined broker-dealer and investment advisor entities. This may create an incentive for Representatives to enact trades and generate additional transaction fees or markups on broker-dealer client trades. To eliminate this potential conflict, GFSA clients do not incur commissions, markups, or markdowns when executing trades through the affiliate broker-dealer GFS; however, trades executed through an unaffiliated broker-dealer will incur such fees. Please refer to Item 5 below on Fees and Compensation for information on “12b-1” fees which may be paid to Representatives of GFSA resulting from client transactions effected through the investment advisory program. In addition, please refer to Item 10 below on Other Financial Industry Activities and Affiliations and Item 12 below on Brokerage Practices for more information on our affiliation with GFS and related brokerage practices. The client should inform the Representative if changes occur in investment objectives or financial situation, or if the client wishes to impose reasonable restrictions on the Advisory Account which are not fundamentally inconsistent with the client’s investment objective or the nature or operation of the advisory program. Financial Planning Services Upon request, a Representative will prepare a financial plan for clients based on their financial and personal circumstances. GFSA will charge a one-time fee when the plan is created, which can be waived in part or in whole at our discretion. Each financial planning client has the choice of selecting GFSA to invest on a discretionary or non-discretionary basis by establishing an Advisory Account. Clients can also implement the financial plan elsewhere or on their own. Clients who choose to implement the financial plan elsewhere will not receive ongoing investment advice from GFSA. GFSA provides ongoing financial planning services to clients who participate in the investment advisory program; however, Representatives do not provide legal or tax advice. Financial planning services are tailored to the needs of each client and are based on their financial situation and personal circumstances. The Representative may also, at his/her discretion, decline to assist the client with the implementation of investment strategies or choices that have not been recommended or that the Representative deems not to be in the client’s best interest. Tailored Advisory Services The Representative will obtain information prior to opening an Advisory Account regarding the clie nt’s financial situation, goals and investment objectives, risk tolerance, time horizon, and other relevant factors, as described by the client in selecting the client’s asset allocation model. The Representative will also inquire as to the client’s interest in imposing any reasonable restrictions on the management of the Advisory Account. Assets Under Management As of December 31, 2023, the following represents the amount of client assets under management, and includes securities portfolios for which we provide continuous and regular supervisory or management services, separated by discretionary vs. non-discretionary account types: Type of Account Assets Under Management Discretionary $ 1,998,334,076 Non-Discretionary $ 856,199,998 Total $ 2,854,534,074