Overview GPLS is an investment management firm, founded in 2021, that takes a systematic research-driven approach to portfolio management. GPLS commenced operations in January 2021 and is registered under the Investment Advisers Act of 1940 and regulated by the Securities and Exchange Commission. The firm was founded by Garrison Leach, who leads the firm as our Chairman and Chief Executive Officer. Since our founding, we have focused on the investment counseling business. The firm is located in one office in Aledo, Texas. The firm is not affiliated with a brokerage firm. Advisory Service GPLS specializes in quantitative investment analysis, utilizing proprietary models to form investment views that are carried out through a disciplined and systematic process. GPLS provides investment advice on a variety of securities and instruments in accordance with agreed upon investment objectives and strategies. Under certain circumstances, GPLS tailors advisory services to the individual needs or requirements of a Client. Multi-Strategy Product GPLS’s primary investment product is our Multi-Strategy Product, which offers total return exposure by combining subsequent GPLS strategies in an optimal manner. This strategy is available directly to both institutions and individuals via advisory and/or sub-advisory arrangements. The Multi-Strategy Product implements a combination of GPLS strategies in a way that is focused on maximizing risk-adjusted returns. In its implementation, the base multi-strategy primarily utilizes large and highly liquid exchange traded funds. However, because GPLS is able to customize component strategies as described below, a broad variety of instruments may be used in implementation. Varying degrees of leverage can be taken in the implementation of the Multi-Strategy Product, to be determined in accordance with Client preference and suitability. Risk Parity Product GPLS offers total return exposure through its Risk Parity Product, which is available directly to both institutions and individuals via advisory and/or sub-advisory arrangements. The Risk Parity Product implements a strategy that is designed to produce consistent and uncorrelated returns. The Strategy is focused on achieving an optimal strategic asset allocation by building a portfolio based on risk allocations rather than capital allocations. Instead of generating returns through active trading, this strategy seeks to collect the returns from holding assets that naturally diversify each other based on their fundamental relationship to changing growth and inflation environments. The strategy allocates risk exposure with the objective of creating a portfolio that is balanced to perform across shifts in the economic environment. The base strategy asset classes include domestic equities and bonds. However, GPLS is able to custom tailor the strategy to include other asset classes such as inflation-linked bonds, commodities, corporate credit, and/or other asset classes. The base strategy utilizes exclusively exchange traded funds in its implementation. This strategy can use varying amounts of leverage, to be determined in accordance with Client preference and suitability. Volatility Risk Premium Product GPLS offers absolute return exposure through our Volatility Risk Premium Product, which is available directly to both institutions and individuals via advisory and/or sub-advisory arrangements. The Volatility Risk Premium Product implements a strategy that seeks to generate returns by exploiting investors tendency to overestimate the probability of significant losses. In its implementation, this strategy systematically buys and sells exposure to S&P 500 volatility through various means including, but not limited to, exchange traded funds and futures contracts. This strategy is designed to provide beta neutral positive returns with moderate risk over the long run and low correlation to many traditional and alternative return sources. Due to embedded leverage within the various instruments used in implementation, the strategy is delivered on a de-levered basis by default. However, the strategy can be implemented with varying degrees of leverage, to be determined in accordance with Client preference and suitability. Large Capitalization Equity Product GPLS offers traditional equity exposure through our Large Capitalization Equity Product, which is available directly to both institutions and individuals via advisory and/or sub-advisory arrangements. The Large Capitalization Equity Product implements a strategy that is focused on domestically traded common stocks with large market capitalizations and high daily trading volumes. We invest in the stocks of high quality, financially sound industry leaders that have an expanding global presence. We maintain a medium to long term investment perspective, which generally results in low portfolio turnover and is typically tax efficient for taxable investors. This strategy is quantitative in nature and is based on momentum factors. This strategy can use varying amounts of leverage, to be determined in accordance with Client preference and suitability. Sector Rotation Product GPLS offers traditional equity exposure through our Sector Rotation Product, which is available directly to both institutions and individuals via advisory and/or sub-advisory arrangements. The Sector Rotation Product implements a strategy that invests in domestic equity sectors which have exhibited recent relative performance strength. In evaluating a sector’s relative strength, the strategy measures the performance of each sector against the performance of the other sectors in the strategy’s investing universe. The Fund will rotate assets into, and out of, sectors on

a periodic basis, and the strategy’s portfolio may therefore be traded frequently. During certain market conditions, notably those which the strategy identifies to be relatively unattractive for equities, the strategy may take positions that focus on bonds and fixed income securities as an alternative to equities in an attempt to preserve capital. The level of hedging, as well as any leverage applied to the strategy, is subject to Client preference and suitability. Balanced Portfolios GPLS will also construct balanced portfolios for our institutional and individual Clients. These balanced portfolios can combine the firm’s strategies in proportions tailored to Client requirements or can be wholly customized to meet the Client’s needs. Portfolio Management Services GPLS manages separate portfolios for institutions and individuals on an account-by-account basis, taking into consideration a Client’s financial resources, investment objectives, and needs. The firm creates an Investment Policy Statement for each Client, which outlines the Client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each Client's specific situation. GPLS evaluates the current investments of each Client with respect to their risk tolerance levels and time horizon. GPLS will request discretionary authority from Clients in order to select securities and execute transactions without permission from the Client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each Client. GPLS seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GPLS’s economic, investment or other financial interests. To meet its fiduciary obligations, GPLS attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain Client portfolios, and accordingly, GPLS’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its Clients to avoid favoring one Client over another over time. It is GPLS’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its Clients on a fair and equitable basis over time. Subadvisor Services GPLS may also act as a subadviser to advisers unaffiliated with GPLS. These third-party advisers would outsource portfolio management services to GPLS. This relationship will be memorialized in each contact between GPLS and the third-party adviser. Services Limited to Specific Types of Investments GPLS generally limits its investment advice to fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), and commodities. Under certain circumstances, GPLS may use other securities as well to help diversify a portfolio or implement certain strategies when applicable. Client Tailored Services and Client Imposed Restrictions GPLS may tailor a program for each individual Client. This will include an interview session to get to know the Client’s specific needs and requirements as well as a plan that will be executed by GPLS on behalf of the Client. GPLS may use model allocations together with a specific set of recommendations for each Client based on their personal restrictions, needs, and targets. The firm may manage accounts subject to Client instructions that prohibit holding certain securities or types of securities or that limit weightings in individual sectors, industries, or securities. GPLS prefers not to be constrained by Client instructions that prohibit holding certain securities. We believe that the ability to select from the widest range of investments that are consistent with our strategy results in higher returns over time. However, the firm can manage accounts subject to instructions that specify various exclusions or that limit weightings in individual sectors, industries, or securities. We will accept new accounts subject to these types of instructions as long as we do not view the proposed directives as overly restrictive or too difficult or impossible to implement and monitor. Fiduciary Acknowledgement GPLS may provide investment advice regarding retirement plan accounts or individual retirement accounts. In doing so, GPLS is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way GPLS makes money creates some conflicts with Client interests, so we operate under a special rule that requires us to act in the Client’s best interest and not put our interest ahead of that of the Client. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of the Client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in the Client’s best interest;
• Charge no more than is reasonable for our services; and
• Give the Client basic information about conflicts of interest.
Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. GPLS does not participate in any wrap fee programs. Assets Under Management As of December 31, 2023, GPLS has approximately $34 5,000 in assets under management that are managed on a discretionary basis and $0 in assets under management that are managed on a non-discretionary basis.