Established in 2007 by sole owner, President and Chief Compliance Officer, Vance Gray, Gray Wealth Management, Inc. d/b/a VanceGray Wealth Management, Inc. (“VanceGray Wealth Management”, "VanceGray" or “Firm”), provides asset management, financial planning and consultation, pension consulting services, and educational seminars and workshops. Each of these services is offered separately under contract and there are separate fee schedules for each type of service offered. Asset Management Services The Firm practices custom management of client assets according to the client's stated goals and objectives. Client assets are generally managed on a discretionary basis. Discretionary authorization is granted in writing by the client in the Investment Advisory Contract; however, clients have the option to have their accounts managed on a non-discretionary basis, as specified in the Contract. If authorized by the client in writing, VanceGray has discretion over the securities, securities amounts, broker to be used as applicable, and the commission rates to be paid in client transactions. Client accounts are generally held at Charles Schwab & Co. (“Schwab”); however, a client account may be established with another broker at the client's request and as specified in the Investment Advisory Contract. If accounts are managed on a non-discretionary basis, VanceGray will obtain client consent before executing transactions on behalf of the client. Clients who enter into an Investment Advisory Contract for Asset Management Services will complete a Client Profile Form which requests information about the client's goals, investment objectives, tax status, and risk tolerance to assist VanceGray in managing the client's assets. All accounts are managed separately, tailored to the individual needs of clients. At the client's request, the client may impose restrictions on investing in certain securities or types of securities. The Firm's primary approach is to use a tactical allocation strategy aimed at reducing risk and increasing performance. The Firm uses exchange listed securities, over-the-counter securities, foreign securities, corporate debt securities, CDs, fixed life insurance and annuities, municipal securities, mutual funds, and United States government securities to accomplish this objective. The Firm’s recommendations for client portfolios are based on client individual situations and include, but are not limited to, the following. The Firm measures and selects mutual funds by using various criteria such as the fund manager's tenure, and/or overall career performance. The Firm recommends, on occasion, redistributing investment allocations to diversify the portfolio in an effort to reduce risk and increase performance, specific stocks to increase sector weighting and/or dividend potential and employing cash positions as a possible hedge against market movement which may adversely affect the portfolio. The Firm recommends selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of the client, or any risk deemed unacceptable for the client's risk tolerance. 401(k) Plan Advisory Services The Firm also provides investment advice to clients regarding assets in their 401(k) program(s). Client assets are generally managed on a discretionary basis. Discretionary authorization is granted in writing by the client in the Investment Advisory Contract; however, clients have the option to have their accounts managed on a non-discretionary basis, as specified in the Contract. Assets are held at the plan’s custodian and VanceGray will access

and aggregate account information to the extent that it is authorized by the client and permitted by the custodian’s technology. If authorized by the client in writing, VanceGray has discretion over the securities and securities amounts selected, as available within the specific 401(k) program. If accounts are managed on a non- discretionary basis, VanceGray will obtain client consent before executing transactions on behalf of the client. Clients who enter into an Investment Advisory Contract for 401(k) Advisory Services will complete a Client Profile Form which requests information about the client's goals, investment objectives, tax status, and risk tolerance to assist VanceGray in managing the client's assets. All accounts are managed separately, tailored to the individual needs of clients. At the client's request, the client may impose restrictions on investing in certain securities or types of securities. Financial Planning and Consultation Services The Firm also furnishes investment advice through comprehensive financial planning and consultative services. Clients who enter into an Investment Advisory Contract for Financial Planning services will receive comprehensive financial planning services, including review of the client's overall financial situation, personal and financial goals, and risk tolerance and objectives. The service provided to the client will include a written financial plan delivered to the client, and the client will be asked to acknowledge receipt of the plan. Clients who enter into an Investment Advisory Contract for Consultative services will receive a review that focuses on the client's personal and/or financial goals and objectives as they apply to a particular area of concern for the client, generally estate planning, education planning, retirement planning, or some other specific area of concentration requested by the client. Retirement Account Advice VanceGray provides investment advice to clients regarding their retirement plan account or individual retirement account and are fiduciaries within the meaning of Title I of the Employee Retirement Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The receipt of an advisory fee for making a recommendation creates a conflict of interest under ERISA/IRC with client interests, so we operate under a special rule that requires the Firm to act in client’s best interest and not put the Firm’s interest ahead of client’s. For example, if the Firm recommends that client roll over assets from one retirement account to another, and will receive increased compensation as a result of that recommendation, we have a conflict that requires the Firm to operate under this special rule. Pension Consulting Services & Educational Seminars and Workshops VanceGray offers pension consulting services to corporations and businesses on a non-discretionary basis. In providing this service, VanceGray will assist the client/plan sponsor with implementation of the employer's defined benefit or defined contribution plan and sometimes offers educational seminars and workshops to plan participants. In conducting such educational seminars, VanceGray provides general instruction regarding the structure of the plan and discusses overall investment strategies, including asset allocation and diversification among various asset classes. VanceGray does not provide product-specific advice to plan participants. Assets Under Management As of December 31, 2023, VanceGray had $321,986,361 in discretionary regulatory assets under management and $6,792,359 in non-discretionary regulatory assets under management, representing a total of $328,778,720 in regulatory assets under management.