Advisory Firm Griffin Black, Inc. (“Griffin Black”) has been providing investment advisory services since 2005. Jane Beule is the founder and President. Prior to 2005 she was the President of Jane Beule Associates, (now known as Griffin Black), a business and financial consulting firm. Advisory Services Griffin Black provides services to executives, professionals, entrepreneurs, retirees, and small business owners from all industries. The firm has also developed an expertise in working with Silicon Valley tech and bio-tech professionals. We work with clients based in the U.S., but who also may have family, assets, or business interests in another country. Griffin Black provides Holistic Wealth Management and Investment Management services. Most Griffin Black services are ongoing in nature and are priced relative to a client’s total available investable assets. We may, however, undertake more limited engagements under certain circumstances, particularly if a client would like to explore a longer-term engagement. Holistic Wealth Management. Griffin Black’s Holistic Wealth Management clients receive both the open-ended Financial Planning and Investment Management services described below. In addition, we seek to enhance each of these services for Holistic Wealth Management clients where possible by implementing them in a more integrated manner than a ‘siloed’ approach would facilitate. In addition, where appropriate, we may provide advanced financial analysis services that address more complex client situations and needs such as options/restricted stock units (“RSU”) strategies, executive compensation, advanced college funding strategies, and individualized analysis of non-securities investments such as individual real estate holdings. Investment Management. Griffin Black constructs client portfolios based on the individual needs and circumstances of each client, paying particular attention to a client’s financial goals, their emotional tolerance for risk, and the client’s financial ability to deal with investment risk. Clients fill out a risk assessment questionnaire, but the Financial Advisor is free to add observations and judgment in determining a client’s risk profile. Before a portfolio is implemented, the client-advisor team agrees on an Investment Policy, which describes the goals of the proposed portfolio, the likely investment risk associated with the general type of a portfolio that is being considered for a client, and any other relevant needs or restrictions that the client wishes to place on the operation of the portfolio. Financial Planning. Griffin Black approaches financial planning as a process rather than as a single event. Unless we have been engaged through our Pathfinder program, we do not deliver a one-time, written plan. Instead, our financial planning process focuses on helping clients (1) become more aware of and document their financial and life goals, (2) develop a more detailed understanding of their financial circumstances, (3) identify specific steps they believe will help them achieve their goals, and (4) implement those steps with appropriate products and/or practices. After an initial process of general exploration and fact finding, the planning process may focus on individual topics one-at-a-time in order to enhance the client’s understanding of each decision and to help ensure appropriate

implementation. Such individual topics may include long-term cash flow planning, risk management (insurance), basic college savings strategies, taxation, strategies to make appropriate use of public and private resources, and the estate planning process. A complete cycle may include different (more or fewer) topics and take as much as a year or longer depending upon the client’s availability and individual needs. In performing its services, Griffin Black is not required to verify any information received from the client or from a client’s associated professionals, and is expressly authorized to rely in good faith on information provided by the client. Neither Griffin Black nor any of its Financial Advisors serves as an attorney, accountant, or licensed insurance agent, and no portion of its services should be construed as the services of such professionals. To the extent requested by a client, Griffin Black may recommend the services of such professionals (e.g., attorneys, accountants, insurance professionals, etc.) for certain non-investment implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Griffin Black. If the client engages any professional recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional(s), and not Griffin Black, shall be responsible for the quality and competency of the services provided. Except in very unusual circumstances, Griffin Black portfolios are designed to be well diversified and to use different types of investments (“asset classes”) in differing amounts and combinations (“asset allocation”) in order to try to achieve the goals that have been defined for the portfolio. We use highly liquid investments such as mutual funds, closed-end funds, exchange traded funds (ETFs), individual stocks and bonds, and traded limited partnerships to build portfolios. Both the Investment Policy and quarterly billing statements remind clients that it remains the client’s responsibility to inform Griffin Black promptly if there is ever a change in their financial situation or investment objectives or if they wish to impose or modify account restrictions. The Financial Advisor will contact or attempt to contact the client annually on these matters. Clients receive timely confirmations and monthly or quarterly statements from a third-party custodian/brokerage firm which contain a description of all transactions and all account activity. In addition, Griffin Black makes an online Investment Portal available to its Investment Management and Holistic Wealth Management clients. The Investment Portal provides instant access to historical investment reporting information for all managed accounts, broken down by portfolio as well as by individual account. This information is updated on a daily basis. Clients can request additional investment reports if they wish. The client retains full ownership rights to all securities and funds in any accounts that are managed by Griffin Black. As of December 31, 2023, Griffin Black had $219,778,266 of assets under management on a discretionary basis.