A. Firm Information Twin Gryphon Advisors LLC (“Twin Gryphon” or the “Advisor”) is a registered investment advisor registered with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of the Commonwealth of Massachusetts. Twin Gryphon was formed in May 2018 and became a registered investment advisor in November 2018. Twin Gryphon is owned by Wellspring Financial Insurance Agency, Inc. and Timothy C. Withers. The Principal Officer of Twin Gryphon is Timothy C. Withers (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Twin Gryphon. B. Advisory Services Offered Twin Gryphon offers investment advisory services to individuals, high net worth individuals, trusts, estates, small businesses, retirement plans and a pooled investment vehicle (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Twin Gryphon’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Advisor’s Code of Ethics, please see Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Twin Gryphon provides tailored investment advisory solutions to its Clients. This is achieved through personal Client contact and interaction while providing discretionary investment management over Client portfolios and a broad range of comprehensive financial planning. These services are described below. Investment Management Services - Twin Gryphon provides discretionary investment management for its Clients. The Advisor provides customized investment management services, based on its internal investment management strategies. The Advisor works closely with each Client both initially and ongoing basis to assist them in achieving their investment goals and objectives. Twin Gryphon starts each Client engagement with a discovery process to determine what type of investment strategies to employ given the Client’s financial situation and risk tolerance. Twin Gryphon will then construct a portfolio, based on its internal investment strategies, which may include individual equity securities, and/or exchange-traded funds (“ETFs”). The Advisor may employ proprietary funds, covered options, inverse ETFs and other types of investments for certain Clients, as appropriate for a particular Client’s situation. For new Clients, the Advisor generally repositions the investment portfolio to align with its investment strategies. However, the Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. The Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Twin Gryphon’s investment approaches employ both long-term and short-term investment philosophies. The Advisor may buy, sell or re-allocate positions based on its internal research and investment process. At times, the Advisor may recommend employing cash positions as a possible hedge against market movement. Twin Gryphon may recommend 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 Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Twin Gryphon accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated Account[s] at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices. www.twingryphonadvisors.com Page 6 Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client roll over its retirement plan account into an account managed by the Advisor. In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest as the Advisor will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by the Advisor. Financial Planning and Consulting Services Twin Gryphon provides financial planning and consulting services to Clients, pursuant to a written financial planning or consulting agreement or part of its overall wealth management services. For individuals and families, financial planning or consulting services may address one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, insurance needs, education savings and other areas of a Client’s goals and objectives. For businesses, financial planning or consulting services are tailored to the needs of business owners and may include the services listed above as well as financial consultations regarding business transactions, retirement plan strategies and other financial matters, depending on the business’s goals

and objectives. Generally, financial plans and consultations include general recommendations for a course of activity or specific actions to be taken by the Client. For certain financial planning and consulting engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Twin Gryphon may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. Financial planning and consulting recommendations poses a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Twin Gryphon provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company/sponsor (the “Plan Sponsor”) and the individuals enrolled in a Plan (the “Plan Participant”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized based on the requirements set forth by the Plan Sponsor. The Advisor’s services may include:
• Analysis of Retirement Platforms and Vendors
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight (ERISA 3(21))
• Discretionary Investment Management (ERISA 3(38))
• Plan Participant Education
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance These services are provided by Twin Gryphon serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Twin Gryphon’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Page 7 Private Fund Advisor Services The Advisor serves as the General Partner and investment manager to a pooled investment vehicle (the “Fund”). These services are detailed in the offering documents for the Fund, which include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Advisor manages the Fund based on the investment objectives, policies and guidelines as set forth in the Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in the Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. In general, investors in the Fund are not permitted to impose restrictions or limitations. However, the Advisor may enter into side letter agreements with one or more investors that may alter, modify, or change the terms of interest held by investors. Certain types of side letters create a conflict of interest between the Advisor and the investors in the Fund, and/or between investors themselves. For more detailed information on investment objectives, policies and guidelines, please refer to the Fund’s Offering Documents. C. Client Account Management Prior to engaging Twin Gryphon to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Twin Gryphon, in connection with the Client, will develop an investment strategy that seeks to achieve the Client’s goals and objective
• Asset Allocation – Twin Gryphon will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Twin Gryphon will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision - Twin Gryphon will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Twin Gryphon does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Twin Gryphon. E. Assets Under Management As of December 31, 2023, Twin Gryphon manages $107,889,787 in Client assets, $84,547,532 of which are managed on a discretionary basis and $23,342,255 on a non–discretionary basis. Clients may request more current information at any time by contacting the Advisor.