A. Granite Bay Wealth Management, LLC (GBWM) has been in business as an investment advisor since 2015, though its principals, Joseph R. Skees and Paul S. Stanley have each been in the business of providing investment advice for more than 20 years. Mr. Skees and Mr. Stanley rendered investment advice under the trade name of Granite Bay Wealth Management, LLC while still affiliated with their prior firm. B. GBWM seeks to provide clients with a thoughtful, client centered approach toward asset management and financial planning. In addition, GBWM provides investment consulting services to qualified plans and plan sponsors. Asset Management GBWM’s client centered approach to asset management begins with investigative client consultation. A representative of GBWM will meet with the client to determine needs and goals, risk tolerance, and any investment restrictions or preferences. This process includes a risk profile that aids in the discovery of the client’s actual risk profile. In some cases, the results of this profile differ from a client’s stated tolerances, or even what their age or other circumstances would traditionally indicate as an appropriate risk level. Once this is completed, GBWM researches various investment options for the client based on the client’s current investments and risk profile and prepares an asset allocation that will serve as a guideline for the client’s ongoing investments. For the duration of the relationship, GBWM continues to communicate with the client to ensure that the client’s objectives and asset allocation remain optimal for the client’s evolving circumstances. Many clients choose to work with GBWM on both asset management and financial planning, where both services are seamlessly integrated. All asset management clients whose assets are in excess of our minimum $250,000 account size, may upon request, receive financial planning services as part of their asset management services. In the alternative, clients may choose to work with GBWM for financial planning services on a stand-alone basis, without utilizing GBWM ongoing asset management services, pursuing the financial planning process separately. In very limited circumstances, GBWM may provide asset management services on a non- discretionary basis. Assets are managed with the same process, but clients are consulted prior to the implementation of recommendations. Financial Planning When working with GBWM on financial planning, clients will be led through a series of steps designed to ensure that each client’s process is similar, yet the results unique. The process begins with a clear definition between GBWM and the client of each party’s responsibilities. This definition is memorialized in a written agreement. GBWM will gather and analyze information, but the firm will not be able to accurately perform their obligations unless the client provides complete and accurate information. Thereafter, GBWM will interview the client and gather documents from the client which will allow the firm to identify the client’s ultimate financial goals, and also develop an outline of the client’s current financial circumstances. Once the current circumstances and future circumstances are determined, GBWM will analyze this information in order to determine potential paths toward reaching that particular client’s goals, and ultimately present these options and recommendations to the client. For clients receiving a complete financial plan on a stand-alone basis, the process results in a financial planning document that identifies and explains the recommendations. Planning services that are limited to a specific aspect of a client’s financial life may not warrant a plan document, but results and recommendations will be reviewed with a GBWM professional. In either case, it is the client’s choice whether to follow the recommendations, and if they choose to do so, whether they will seek assistance from GBWM in implementing the recommendations. Clients who elect to work with GBWM for financial planning and asset management services will have the benefit of GBWM leading an integrated process, whereby financial planning and the direction of asset management are combined, and thus a separate planning document not created. This integration includes the management of the assets identified in the plan in accordance with the directives of the plan, and an ongoing review of the client’s goals and maintaining a portfolio that is in keeping with those goals. Asset management processes are described more fully in Item 8 of this brochure. Subject matters raised will include some or all of the subject fields identified by the Certified Financial Planner Board’s Standards of Professional Conduct, which include financial statement preparation and analysis, risk management, employee benefits, investments, income taxes, retirement and estate planning. Frequently, a thorough financial plan will require the assistance of other professionals in implementation. Because GBWM’s professionals are neither attorneys nor accountants, no part of their services includes tax or legal advice. However, an attorney may be required for the purpose of executing an estate plan, or an accountant needed for additional tax consultation. If requested, GBWM will provide a recommendation for such a professional, but the client is under no obligation to accept that recommendation. GBWM does not receive any sort of referral fees from professionals it recommends. If you engage any professional recommended by GBWM, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Asset Management – Institutional Intelligent Portfolios™ Program GBWM has recognized certain clients

and their younger family members new to the investing space or with limited assets need an alternative to their traditional asset management methodology and program. For these clients and their families, GBWM will provide portfolio management services through an investment service called Institutional Intelligent Portfolios™, an automated, online investment management platform for use by independent investment advisors offered by Schwab Performance Technologies (the “Program” and “SPT,” respectively). Through the Program, GBWM will offer clients a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at SPT’s affiliate, Charles Schwab & Co., Inc. (“CS&Co”). We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co or their affiliates (together, “Schwab”). The minimum investment required to open an account in the Institutional Intelligent Portfolios Program is $5,000, therefore enabling certain clients to begin a formal investment program. We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Clients do not pay fees to SPT in connection with the Program, but GBWM charges clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. Retirement Plan Consulting Services The fiduciaries of self-directed retirement plans (which can include 401(k) plans) are required to, among other things, determine a selection of investments from which the plan’s participants choose for their personal allocation in their individual participant account. GBWM provides assistance to plan sponsors in meeting this obligation through a consultative relationship, which includes the selection of the plan investment options in accordance with the plan’s objectives, as well as the ongoing monitoring of those options to assist the plan sponsor in determining when changes to these options are needed. This advice is rendered on a non-discretionary basis, meaning the plan sponsor is free to accept or reject GBWM’s recommendations. C. All engagements are tailored to the specific needs of an individual client. GBWM does not use “model” portfolios where all clients in the model contain the exact same investments. Clients may place reasonable restrictions on the management of assets, including regarding specific securities or types of securities. However, clients should understand that significant restrictions cannot only decrease the ability of GBWM to meet the client’s goals, but also increase the costs associated with managing the client’s portfolio. D. GBWM neither participates in, nor sponsors a wrap fee program. E. As of December 31, 2023, GBWM managed $357,344,239 in client assets including $344,274,957 on a discretionary basis.