Item 5 Additional Compensation .......................................................................................................................................................... 23 Item 6 Supervision ............................................................................................................................................................................... 23 Brochure Supplement (Part 2B of Form ADV) ....................................................................................................................................... 24 Brian Remme, Chief Compliance Officer ............................................................................................................................................... 24 Item 2 Educational Background ............................................................................................................................................................ 24 Professional Certifications ..................................................................................................................................................................... 24 Educational Background: ....................................................................................................................................................................... 24 Business Experience .............................................................................................................................................................................. 24 Item 3 Disciplinary Information ............................................................................................................................................................ 24 Item 5 Additional Compensation .......................................................................................................................................................... 24 Item 6 Supervision ............................................................................................................................................................................... 24 Form ADV Part 2A (3/28/2023) [5] Gradient Securities, LLC Firm Description Gradient Securities, LLC, doing business as Gradient Wealth Management (GWM), was formed on April 9, 2003. On January 2, 2004, Gradient Securities, LLC, became a broker-dealer registered with the Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”) as an independent broker-dealer. The Investment Advisor’s (“RIA”) registration became effective with the SEC in 2015. The RIA division of Gradient Securities, LLC does business as Gradient Wealth Management (“GWM”). The Tami J. Lucius Revocable Trust is 100% owner. Types of Advisory Services Financial Planning and Consulting Services A financial plan is designed to help the client with all aspects of their financial situation through a comprehensive evaluation of a client’s current and future financial needs. The financial plan may include, but is not limited to, review of investment accounts, reviewing asset allocation, providing repositioning recommendations, strategic tax considerations, a review of retirement accounts and plans including recommendations, a review of insurance policies and recommendations for changes, providing retirement scenarios, estate planning review and recommendations, divorce planning review, and education planning with funding recommendations. Detailed investment advice and specific recommendations are provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client. Financial Planning/Consulting services cover various activities provided by advisors specifically designed to assist individuals and companies reach their financial objectives. This is accomplished by analyzing the client’s data, design and implement strategies to address individual investment needs. If a conflict of interest exists between the interests of GWM and the interests of the Client, the Client is under no obligation to act upon GWM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to execute the transaction through GWM. Investment Advisor Representatives (“IAR”) of GWM may charge clients for financial planning on a hourly or negotiable fixed fee basis described in detail in Item 5 of this brochure. Financial Planning/Consulting services are exclusive of other services that are offered through GWM. Third Party Managers GWM may recommend that Clients utilize the services of a Third Party Manager (TPM) to manage a portion of, or the entire Client’s portfolio. All TPMs that we recommend must either be registered as investment advisers with the Securities and Exchange Commission or with the appropriate state authority. After gathering information about your financial situation and objectives, an IAR of our firm will make recommendations regarding which TPM or investment style best suits you based on, but not limited to, your financial needs, investment goals, tolerance for risk, and investment objectives. Upon selection of a TPM(s), the IAR will monitor the performance of the TPM(s) to ensure their performance and investment style remain aligned with your investment goals and objectives. In such circumstances, GWM receives solicitor fees from the TPM. We act as the liaison between the Client and the TPM in return for an ongoing portion of the advisory fees charged by the TPM. We help Form ADV Part 2A (3/28/2023)

[6] Gradient Securities, LLC the Client complete the necessary paperwork of the TPM and provide ongoing services to the Client which include but are not limited to: 1. Meeting with the Client to discuss any changes in status, objectives, time horizon or suitability. 2. Update the TPM with any changes in Client status which is provided to GWM by the Client. 3. Review the statements provided by the TPM. 4. Deliver the Form ADV Part 2, Privacy Notice, and Solicitors Disclosure Statement of the TPM to the Client. Clients placed with a TPM will be billed in accordance with the TPM’s Fee Schedule which will be disclosed to the Client prior to signing an agreement. ASSET MANAGEMENT GWM offers non-discretionary direct asset management services to advisory clients. GWM will recommend the securities to be bought or sold and the amount of the securities to be bought or sold. GWM obtains prior client approval before executing any transactions. GWM will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. ERISA PLAN SERVICES GWM provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. GWM may act as a 3(21) advisor: Limited Scope ERISA 3(21) Fiduciary GWM may serve as a limited scope ERISA 3(21) fiduciary that can advise and assist plan sponsors with their investment decisions. As an investment advisor GWM has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using GWM can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal, and addition of investment options. GWM acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)- 5. Form ADV Part 2A (3/28/2023) [7] Gradient Securities, LLC
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands GWM’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, GWM is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. GWM will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. GWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between GWM and Client. 3. GWM has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities
• Real estate (except for real estate funds or publicly traded REITs)
• Stock brokerage accounts or mutual fund windows
• Participant loans
• Non-publicly traded partnership interests
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles) or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to GWM on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented through various methods which include the completion of client account forms, transactional analysis, and risk analysis documentation. Clients may also impose, through the investment advisory agreement process, restrictions on investing in certain securities or types of securities through GWM. Agreements may not be assigned without written client consent. Wrap Fee Programs GWM does not sponsor any wrap fee programs. Form ADV Part 2A (3/28/2023) [8] Gradient Securities, LLC Client Assets under Management As of December 31, 2023, GWM had approximately $475,170,843 of assets under management on a non-discretionary basis.