Grace Capital Management, LLC is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. We specialize in offering Comprehensive Portfolio Management and Selection of Third-Party Advisory services to our clients. Our firm is a limited liability company formed in the State of Texas. We have been in business as an investment adviser since 2009 and are one hundred percent (100%) owned by Mr. George Duff, Managing Member and Chief Compliance Officer. Types of Advisory Services Offered Comprehensive Portfolio Management: Our Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting, and pension consulting services to individual plan participants and clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person, if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Financial Planning and Consulting Services: Financial Planning Services include, but are not limited to, a thorough review of Cash Flow, Businesses, Wills, Estate Plan/Trusts, Investments, Taxes, and Insurance. Services are determined based on the nature of the services provided and the complexity of each client’s circumstances. All fees are agreed upon prior to the commencement of any services and will include entering into a contract (the “Client Agreement”) with the client. Prior to the planning process, the client will be provided with an estimated plan fee. Payment is required to be provided prior to service. Selection of Third-Party Advisory Services: We may utilize Third-Party Advisor Services, where we may design an investment portfolio and provide ongoing corresponding asset management services on a fee-only basis for a percentage of assets in conjunction with another investment advisory firm. Before selecting other advisers, we make sure that the other advisers are properly licensed or registered. In order to assist the Client in the selection of a Third-Party Advisory Service, we will typically gather information from the Clients about the Client’s financial situation, investment objectives, and reasonable ADV Part 2A – Firm Brochure Page 5 Grace Capital Management, LLC restrictions the Client wants imposed on the management of the account. We will not offer advice on any specific securities or other investments in connection with this service. We will periodically review reports provided to the Clients, but no less often than on a quarterly basis. The Investment Advisory Representatives of our firm will contact the Client periodically, as agreed to with the Clients, in order to review the Client’s financial situation and objectives; communicate information to the Third-Party Advisors managing the account as warranted; and assist the Clients in understanding

and evaluating the services provided by the Third-Party Advisory Service. Clients will be expected to notify us of any changes in their financial situation, investment objectives, or account restrictions. Clients may also contact the Third-Party Advisors directly managing the account or sponsoring the program. IRA Rollover Recommendations: For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020- 02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are 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 we make money creates some conflicts with client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interests ahead of the clients. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that we and our employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when our and our employees believe it is in the clients’ best interest. Tailoring of Advisory Services We offer individualized investment advice to clients utilizing our firm’s Comprehensive Portfolio Management service. Additionally, we offer general investment advice to clients utilizing our firm’s Selection of Third-Party Advisory Service. We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their account. In the rare instance that we allow restrictions, it would be limited to our firm’s Comprehensive Portfolio Management service. ADV Part 2A – Firm Brochure Page 6 Grace Capital Management, LLC Participation in Wrap Fee Program We sponsor and act as portfolio managers of a wrap fee program as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”). Clients participating in a wrap fee arrangement pay a single fee for advisory, brokerage and custodial services. Clients’ portfolio transactions will be executed without commissions charge in a wrap fee arrangement. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by paying transaction costs separately with another advisor. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies, the brokerage commissions charged by broker/dealers, and the advisory fees charged by investment advisers. We will review with clients any separate program fees that may be charged to clients. Regulatory Assets Under Management We managed $109,475,469 on a discretionary basis and $30,540,749 on a non-discretionary basis as of March 15, 2024.