Description of Firm McGrath & Associates, Inc., doing business as Holcombe & McGrath, is a registered investment adviser based in Asheville, NC. We are organized as a corporation under the laws of the State of NC. Holcombe & McGrath was founded in 2008, by owner and president, Susan McGrath. However, our roots stretch back to an earlier financial advisory firm started by Harold Holcombe in 1985. Susan joined Harold's Firm in 2002, and ultimately acquired it in 2008 after Harold's retirement. We have been providing investment advisory services since 05/01/2008. We are owned by Susan Lee McGrath and Robert E. Baschnagel.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Holcombe & McGrath and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
This Brochure provides important information about Holcombe & McGrath, the nature and cost of our services, our compensation, and situations where our interests may conflict with our Clients, among other issues. The discussions about conflicts of interest are important because the conflicts can affect our judgment in managing your account, in choosing brokers to execute your trades, and in recommending custodians, among other important considerations.
Description of Our Services Holcombe & McGrath provides discretionary investment management services for client assets (the "Management Services"). We also offer separate "Financial Advisory Services" for individuals and businesses covering a wide range of financial and investment subjects. During the initial meeting with their "Representative," which can last between thirty and ninety minutes, prospective Clients will discuss in person or by telephone the Firm's services and the prospective Client's overall financial situation, objectives, goals, and experience. After the initial meeting, the prospective Client is free to decide whether or not to enter into a Management Agreement to engage us for the Management Services or to enter into a Financial Advisory Agreement to engage us for the Financial Advisory Services. The Management Agreement and Financial Services Agreement are referred to collectively as "client agreements." We caution Clients and prospective Clients reviewing the following information, to keep in mind that this information is necessarily general and does not address all possible details about our services. Our Representatives or management are available to answer questions not addressed below. Also, because we reserve the right to negotiate the terms of each client agreement, Clients should always refer to their individual client agreement for the specific terms and conditions that apply to them.
Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives.
If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will 4 also have discretion over the broker or dealer to be used for securities transactions in your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms.
In providing account management services, we accept reasonable client restrictions on the specific securities or the types of securities that may be held in your account.
For prospective Clients interested in our Investment Management Services, the Representative will meet with the Client and obtain information regarding the Client's personal and financial situation, and the investment objective, tolerance for risk, investment time horizon, liquidity needs, and reasonable investment restrictions (all the "Suitability Information") for each of the Client's accounts to be managed through the Management Services (collectively, the "Account"). Holcombe & McGrath uses a proprietary investment philosophy and system developed after years of research and experience managing Client assets. Although our investment system is influenced by many different investment philosophies and methods, in general, it focuses on broad diversification, low costs, and a management approach that finds the probability of a more favorable investment outcome tends to improve over the long-term. We do not require the use of our proprietary system in managing a Client's Account, and if requested, in our discretion, we may agree to use another strategy or portfolio that meets a Client's personal preferences. A Client may request, at any time, that we change the investment strategy being employed with respect to their Account. Notwithstanding the foregoing, in the event of any requested change by a Client, in our sole discretion, we reserve the right to terminate their Management Agreement if a mutually agreeable alternative cannot be identified. The Management Agreement does not include services to implement any advice or recommendation, except with respect to assets managed (or to be managed) as part of the Management Services. Client may elect to implement any advice or recommendations, at Client's sole discretion, through professionals selected by Client (including Client's accountant, attorney, insurance agent, broker, or other financial professionals).
Financial Planning Services We offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term

objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will guide you through a plan designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
5 Holcombe & McGrath provides separate, standalone "Financial Advisory Services" for: any Client who wishes comprehensive financial planning; or any Client who wishes limited scope or project-based financial planning services, or financial planning services that include a written report or Financial Plan.
The Financial Advisory Services will be described in a written Financial Advisory Services Agreement between the Client and Holcombe & McGrath. Once the Firm and Client have entered into the Financial Advisory Agreement, the Representative will work with the Client to collect the Suitability Information, and to the extent relevant to the engagement, information regarding insurance coverages, education plans, estate plans, retirement plans, and related or similar matters necessary to provide the Financial Advisory Services (all the "Financial Advisory Information"). The Suitability Information and Financial Advisory Information are referred to collectively as the "Client Information." The scope of the Financial Advisory Services varies, as each engagement is individually negotiated and tailored to accommodate the specific needs of the Client. Advice may be provided through individual consultations or a written report or Financial Plan, as agreed between the Firm and Client.
Pension Consulting Services Although we do not actively seek new business for this service, our firm currently provides pension consulting services to an employee benefit plan and its fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification;
•Asset allocation;
•Risk tolerance; and
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for services. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client.
6 Wrap Fee Programs We do not participate in any wrap fee program.
Types of Investments We may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your 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 we believe it is in your best interest.
Assets Under Management As of December 31, 2023, we provide continuous management services for $115,984,784 in client assets managed on a discretionary basis. We also have $7,104,434 of assets under advisement. 7