Firm Description Gray Private Wealth, LLC (“GPW” or the “Firm”) was founded in 1999. The Firm provides discretionary as well as non-discretionary investment management services to individuals, pension and profit-sharing plans, trusts, partnerships, estates, corporations, foundations and charitable organizations. Advice is provided through consultation with each client of the Firm (each, a “Client”) and may include determination of financial objectives, tax planning, insurance review, investment management, cash flow, education funding and college planning, retirement planning, and estate planning. In general, the Firm seeks to provide their Clients with maximum after-tax, risk adjusted returns over long term time horizons consistent with each Client’s investment objectives. Principal Owners The Firm is organized as a Massachusetts limited liability company. The Firm is owned by the following nine individuals: Concetto Joseph Ciccarello, Daniel C. Romano, James A. DeLeo, Michael L. Cecere, Richard A. Hirschen, Kelly A. Berardi, Derrick J. Rebello, Justin J. Klunder and Paul J. Gerry Jr.”). Daniel Romano is Chief Executive Officer (“CEO”) of the Firm and is responsible for the day-to-day operations of the Firm. Stephen Kenney is the Chief Compliance Officer (“CCO”). Justin J. Klunder is the Chief Investment Officer (“CIO”) of the Firm. Types of Advisory Services The Firm provides investment advisory services, also known as asset management services. This means that the Firm provides its Clients with regular and continuous investment advice which is particularly tailored to that Client’s investment needs. As part of the asset management services, GPW may use one or more sub-advisors to manage a portion of a client’s account(s) on a discretionary basis. The sub-adviser(s) may use one or more of their model portfolios to manage a client account. GPW will regularly monitor the performance of the accounts managed by sub-advisor(s) and may hire and fire any sub-advisor without

prior approval from the client. GPW may pay a portion of the client advisory fee to the sub-advisor used. This amount will be deducted from the fee that the client pays GPW and will not result in any additional cost or expense to the client. The Firm also furnishes advice to Clients on matters not involving securities, such as financial planning matters, taxation issues, and retirement planning services that often include 401(k) investment and planning. GPW may also enter into consulting or ad-hoc engagements. GPW has adopted policies and procedures to comply with the ERISA fiduciary standards when advising retirement asset rollovers, as set forth in the Department of Labor Fiduciary Rule that became effective January 31, 2022. As of December 31, 2022, the Firm has approximately $324,543,914 in assets under management for approximately 256 households. The Firm manages $ 321,724,436 of its assets under management on a discretionary basis and $2,819,478 of its assets under management on a non-discretionary basis. Assets under management consist solely of assets for which the Firm provides investment advice on a regular and continuous basis to Clients. Tailored Relationships GPW provides investment advisory services, which it defines as providing continuous advice to a Client or making investments for a Client based on the individual needs, objectives and unique circumstances of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, GPW develops a Client's personal investment policy and creates and manages a portfolio based on that policy. GPW provides this service to individuals, pension and profit-sharing plans, trusts, partnerships, estates, corporations, foundations and charitable organizations. GPW will manage most advisory accounts on a discretionary basis. Account supervision is guided by the stated objectives of the Client (i.e., maximum capital appreciation, asset protection, growth, income, or growth and income).