Overview of the Firm Grey Street Capital has been an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since April 2017. The Firm is wholly owned by Jay F. Page, Jeffrey S. Friedstein, and Timothy R. Mullen. While this Form ADV Part 2A Brochure (“Brochure”) generally describes the business of Grey Street Capital, certain sections of the Brochure also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or other persons who provide investment advice on Grey Street Capital’s behalf and are subject to the Firm’s supervision or control. 3 | P a g e Advisory Services, Financial Planning, and Consulting Services Grey Street Capital offers clients a limited range of financial planning and consulting services, which may include any or all of the following functions: cash flow modeling and management; liability management; review of tax preparation; and review of estate planning. These services are provided in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Grey Street Capital is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants) and is expressly authorized to rely on such information. Grey Street Capital may recommend clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Grey Street Capital to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Grey Street Capital under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Grey Street Capital’s recommendations and/or services. Wealth Management Services Grey Street Capital provides clients with wealth management services which include the financial planning and consulting services, as described above, as well as discretionary and/or non- discretionary management of investment portfolios. Grey Street Capital primarily allocates client assets to third-party investment managers (“Independent Managers”) and private funds but also allocates client assets among various exchange-traded funds (“ETFs”), and individual equity and debt securities. Although not managed on a discretionary basis, Grey Street Capital also advises clients on private investments. Where appropriate, the Firm may also provide advice about any type of legacy position or other investments held in client portfolios. Clients may engage Grey Street Capital to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Grey Street Capital directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or at the custodian designated by the product’s provider. Grey Street Capital tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Grey Street Capital consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints, and other factors relevant to the management of their portfolios. Clients are advised to promptly notify Grey Street Capital if there are changes in their financial

situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Grey Street Capital determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. 4 | P a g e As mentioned above, Grey Street Capital may recommend certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. The Firm evaluates a variety of information about Independent Managers, which may include the applicable public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. The Firm considers each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. Grey Street Capital continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Grey Street Capital seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Sponsorship and Management of Private Funds Grey Street Capital sponsors and serves as the manager of various private funds that invest in underlying private funds (the “Funds”). Interests in the Funds are privately offered pursuant to Regulation D under the Securities Act of 1933 (“the Securities Act”), as amended. The Funds rely on an exemption from registration as an investment company under the Investment Company Act of 1940 (“Company Act”), as amended. Participation as an investor in the Funds is restricted to investors that are both "qualified clients" as defined in Rule 205-3(d) under the Investment Advisers Act of 1940 (“Advisers Act”), as amended, and “accredited investors” as defined in Rule 501(a) of the Securities Act. Other investor eligibility criteria may also apply. Any investment in the Funds involves a significant degree of risk. All relevant information, terms and conditions relative to an investment in the Funds , including the compensation received by Grey Street Capital, suitability, risk factors, and potential conflicts of interest, are set forth in the Confidential Private Placement Memorandum (the “Memorandum”), the Limited Liability Company Operating Agreement or similar agreement (the “Operating Agreement”), and/or Subscription Agreement (together, the “Offering Documents”) for each Fund, which each investor is required to receive and/or execute prior to being accepted as an investor. Where the Firm provides wealth management services to a client and recommends an investment in any Fund, the Firm does not charge the wealth management fee (as discussed below in Item 5) on the assets that a client has invested in such Fund. The Firm does receive the investor’s share of the management fee and incentive allocation payable to Grey Street Capital by the Fund, as applicable, which could ultimately result in more compensation earned by the Firm with respect to the management of such assets. As a result, a conflict exists when Grey Street Capital recommends an investment in the Fund to its clients. 5 | P a g e Assets Under Management As of 12/31/23, Grey Street Capital had $2,028,277,602 in assets under management, $1,903,388,620 of which were managed on a discretionary basis and $124,888,982 of which were managed on a non-discretionary basis.