Lanier Asset Management, LLC (“LAM”) is an independent, SEC-registered investment advisory firm. The firm utilizes an open architecture investment structure to combine proprietary and independent investment strategies in an effort to achieve superior absolute and relative returns. Our management team comes from highly diverse backgrounds such as investment management, investment banking and international business consulting. LAM provides financial planning, consulting, and investment management services. LAM also acts as the managing member to Lanier Bridgepointe Gardens Fund, LLC, Lanier Avalon Fund, LLC and Lanier Four Charters Fund, LLC (the “Funds”), pooled investment vehicles formed as private real estate syndications. As the managing member of the Funds, LAM is primarily responsible for the management of the Funds. The Funds are structured as Delaware limited liability companies. Prior to engaging LAM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with LAM setting forth the terms and conditions under which LAM renders its services (collectively the “Agreement”). LAM has been in business since August 2009. Junius “Trip” Beaver III and Mark Hoffman are the principal owners of the firm. As of January 31, 2024, LAM has $116,060,176 in assets under management, of which $104,698,568 was managed on a discretionary basis and $11,361,608 was managed on a non- discretionary basis. This Disclosure Brochure describes LAM’s business. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of LAM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on LAM’s behalf and is subject to LAM’s supervision or control. Financial Planning and Consulting Services LAM provides its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment related matters). In performing its services, LAM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. LAM may recommend the services of itself, its Supervised Persons in their individual capacities as registered representatives, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if LAM recommends its own services. The client is under no obligation to act upon any of the recommendations made by LAM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including LAM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of LAM’s recommendations. Clients are advised that it remains their responsibility to promptly notify LAM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising LAM’s previous recommendations and/or services. P A G E 5 Investment Management Services Clients can engage LAM to manage all or a portion of their assets on a discretionary and non-discretionary basis. LAM primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities and/or options as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. In addition, LAM may recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which include debt, equity, and/or pooled investment vehicles when consistent with the clients’ investment objectives. LAM also provides advice about any type of investment held in clients' portfolios. LAM also may render discretionary and non-discretionary investment management services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In so doing, LAM either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. LAM tailors its advisory services to the individual needs of clients. LAM consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that impact the clients’ investment needs. LAM ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify LAM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon LAM’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in LAM’s sole discretion,

the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. The Funds LAM provides investment advice to the Lanier Bridgepointe Gardens Fund, LLC, which invests solely in a property holding company (the “Property Holding Company”) that owns a 131-unit Class A assisted Living property located in Jeffersonville, Indiana (the “Property”). There can be no assurance that the Fund will achieve its investment objective or avoid substantial losses. An investor should not make an investment in the Fund with the expectation of sheltering income or receiving cash distributions. Investors are urged to consult with their personal advisers before investing in the Fund.
P A G E 6 LAM provides investment advice to the Lanier Avalon Fund, LLC, which invests solely in a property holding company (the “Property Holding Company”) that owns a 131-unit Class A assisted Living property located near Greenwood, Indiana (the “Property”). There can be no assurance that the Fund will achieve its investment objective or avoid substantial losses. An investor should not make an investment in the Fund with the expectation of sheltering income or receiving cash distributions. Investors are urged to consult with their personal advisers before investing in the Fund. LAM provides investment advice to the Lanier Four Charters Fund, LLC, which invests solely in a property holding company (the “Property Holding Company”) that owns four 79-unit assisted Living properties located in Paducah, KY, Linden, MI, White House, TN and Murray, KY (the “Properties”). There can be no assurance that the Fund will achieve its investment objective or avoid substantial losses. An investor should not make an investment in the Fund with the expectation of sheltering income or receiving cash distributions. Investors are urged to consult with their personal advisers before investing in the Fund. This document is not an offer to sell or a solicitation of an offer to buy interests in the Funds. Such an investment may be made only after receipt and review of each Fund’s Confidential Private Placement Memorandum (the “Memorandum”). Each Memorandum contains important information concerning risk factors and other material aspects of the corresponding Fund and it must be read carefully before making an investment decision. The information in this document is qualified in its entirety by, and should be read in conjunction with, the information contained in each Memorandum. LAM provides investment advisory services to the Funds based on the investment objectives of the Funds. LAM does not provide tailored investment advice to the Members in the Funds. Membership interests (“Interests”) in each Fund are being offered for investment by up to one hundred (100) persons who are “accredited investors” as defined in Rule 501(a) of Regulation D under the Federal Securities Act of 1933 (“Securities Act”). The Interests will not be registered under the Securities Act or the securities laws of any state. Use of Independent Managers As mentioned above, LAM recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between LAM or the client and the designated Independent Managers. LAM renders services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers. LAM also monitors and reviews the account performance and the client’s investment objectives. LAM receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers.
P A G E 7 When recommending or selecting an Independent Manager for a client, LAM reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that LAM considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, LAM’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by LAM, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to LAM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers impose more restrictive account requirements and varying billing practices than LAM. In such instances, LAM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Sponsor / Manager of Wrap Program LAM is not the sponsor or manager of a wrap fee program.