A. OWNERSHIP/ADVISORY HISTORY Gilpin Wealth Management LLC (the “Firm”) was founded in September 2020. The Firm is a Colorado limited liability company and became registered as an investment adviser in December 2020. Anthony McEahern and Joseph Glasman are the owners of Gilpin Wealth Management, LLC. B. ADVISORY SERVICES OFFERED 1. FINANCIAL PLANNING SERVICES (I) COMPREHENSIVE FINANCIAL PLANNING: The Firm offers comprehensive financial planning services that involve a review of clients’ financial situation, goals and risk tolerance. Through a series of personal interviews and/or the use of risk tolerance tools/questionnaires the Firm may collect pertinent data, identify goals, objectives, financial problems, and potential solutions. With this information, the Firm may tailor a client’s financial plan and advice to accomplish stated goals and objectives. This advice may cover any of the following topics: net worth; cash flow analysis; tax analysis; insurance and long-term care analysis; tax planning strategies; retirement planning; 401k review; financial goal setting; risk management; college savings or other needs as identified during meetings with clients. The Firm may also offer, as part of the plan, accounting, tax preparation, wealth and estate planning services. A financial plan may be created and documented following these client meetings. (II) ONGOING FINANCIAL PLANNING: The Firm also offers ongoing services in which it may monitor, update and manage financial plans. The ongoing service may cover a client’s financial situation, current income, future income needs, assets not managed by the Firm, such as an employer sponsored retirement plan and/or personal investment held in personal brokerage accounts. In such instances, at the beginning of the relationship the Firm may meet with the client to review their financial situation, current income and futures income needs. Thereafter, the Firm may reach out to the client periodically to cover changes or updates to the financial situation provided by the client to the Firm (Please see Item 13 – Review of Accounts, for additional details). Additionally, for employer sponsored retirement plans, the Firm may review the employer sponsored plans’ available investment options and make an asset allocation recommendation to the client. Similarly, for personal assets held away, the Firm may review the assets and propose an asset allocation. (III) FINANCIAL CONSULTING: The Firm’s financial consulting services may be provided when a client needs assistance with one or two individual topics described above. The chosen topics are written in the financial planning agreement. This service generally does not involve creating a documented financial plan. Typically, the Firm meets with the client to discuss any questions, conduct research and present Gilpin Wealth Management LLC Page 5 ADV Part 2A 9/27/2023 findings through a second meeting. Upon completion of the presentation, the engagement is concluded. 2. PORTFOLIO MANAGEMENT The Firm may offer portfolio management services that involve assisting with the ongoing management of a client’s investment accounts. The Firm may work with a client to formulate an individualized portfolio based upon the client’s objectives, time frame, risk parameters and other investment considerations. Once the Firm has this information, the Firm may create a customized portfolio using a combination of model portfolios. The Firm will require discretionary authority from the client in order to select securities and execute transactions without the client’s prior permission.

The Firm may base the investment recommendations on a variety of factors including, but not limited to, performance risk, fees, tax efficiency of different investment strategies, as well as client input and preferences regarding the strategies to be implemented. 3. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISERS On occasion, the Firm may recommend the services of a Third-Party Investment Adviser (“Third- Party Adviser”) to manage the client’s accounts(s). The Firm may work with the client to select and customize a model portfolio based upon client objectives, time frame, risk parameters and other investment considerations. Once the Firm has this information, the Firm may recommend one or several of the Third-Party Adviser’s model portfolios to the client. The client always has the right to choose whether to use a recommended Third-Party Adviser or not. The Firm reviews each Third-Party Adviser before making a recommendation to the client. The Firm may consider the following factors during a review: fees, reputation, performance, financial strength, management, price, reporting capabilities, and client financial situation, goals, needs, and investment objectives. After the review, the Firm presents the client with one or more recommendations. If the client wishes to proceed with the recommendation, the Firm may enter into a solicitor arrangement with the recommended Third-Party Adviser. Under this arrangement, the Third- Party Adviser is responsible for portfolio management, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. The Firm maintains a relationship with the client by monitoring the status of client accounts with the Third-Party Adviser, making recommendations about the Third-Party Adviser meeting with client in person or by telephone on an annual basis, and acting as client’s primary financial adviser. All questions regarding the Third-Party Adviser’s services and performance should be directed to the Firm. The client will receive full disclosure, including services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant Third-Party Adviser’s Form ADV Part 2A or equivalent disclosure document before receiving investment advisory services from the Third- Party Adviser. The Third-Party Adviser offers separate services that are outlined in its Adv Part 2A. 4. RETIREMENT PLAN CONSULTING For retirement plan accounts, the Firm may provide the following ERISA fiduciary and ERISA non- fiduciary services: Selection of Investments; Education Services to Plan Committee; Participant Gilpin Wealth Management LLC Page 6 ADV Part 2A 9/27/2023 Education Services; Plan Search Support; Review of Fiduciary Liability Insurance Coverage; Monitoring of Qualified Fiduciary; or Participant Advise. Upon a client’s request, the Firm may provide any of the following ERISA non-discretionary fiduciary services: create an Investment Policy Statement; provide Investment Recommendations & Performance Monitoring; or Selection of Qualified Default Investment Alternative. Please note that the Firm’s ERISA fiduciary services generally include but are not limited to ERISA Section 3(21) and ERISA Section 3(38) investment management fiduciary services. 5. TAILORED SERVICES The Firm may document client goals and objectives before any investment takes place. The client may impose restrictions on investing in certain securities or types of securities. 6. WRAP PROGRAM The Firm does not sponsor a wrap program. C. CLIENT ASSETS MANAGED As of September 14, 2023, the Firm manages $105,882,916 in client assets on a discretionary basis.