Groesbeck Investment Management Corporation is an employee-owned investment adviser, providing equity portfolio management services to endowments, foundations, pension plans, trusts, IRA’s and high net worth individuals and individual customers. Since our founding in 1993, we’ve provided above-market investment performance through a disciplined, risk-sensitive process. Total discretionary assets under management at December 31, 2023, were $76,873,882. Groesbeck Investment Management offers distinct equity portfolio management investment strategies depending on the client’s requirements and objectives. Our Growth of Income style seeks to provide a growing stream of current income and a total return in excess of the S&P 500. Our Growth style seeks to generate higher than market returns, primarily through capital appreciation. The MLP investment product seeks to provide high current income and distribution growth through investments in Master Limited Partnership securities (MLP). The investment processes of these portfolio management strategies are discussed further in Item 8. We conduct our business through several methods. Clients may sign on individually with our firm by signing a client agreement and either chooses a broker-dealer, custodian and broker or delegate that decision to us. For more information regarding brokerage practices, please see Item 12. In some cases where we have discretionary authority, some clients impose restrictions, such as: (1) the mix of the portfolio between stocks, bonds and/or cash equivalent; (2) the percentage invested in a particular issue or industry; (3) the quality of the securities held; (4) prohibit the purchase or sale of particular stocks or securities, among others. Another method of investment is through sponsored “wrap” programs or “overlay” programs that refer business to us. In the wrap business, the customer generally pays a bundled single fee (said to be wrapped) to the sponsoring organization which is usually a bank or broker-dealer. Please see ADV Part 1 Item 5 Section 5.I.(2) Schedule D for a list of wrap and referral sponsor organizations. Please note that the wrap programs are not directly offered by Groesbeck Investment Management Corp. In these lines of business, we provide portfolio management services only and do not negotiate fees, or provide custody or trading services. Key Personnel: Robert P. Groesbeck, CFA - President Mr. Groesbeck, age 83, is the founder of the firm and serves as Senior Portfolio Manager. He was formerly a Vice President of Argus Investors’ Counsel, where he was responsible for managing assets of $525 million. The largest single account was $200 million. He has over 50 years of investment experience in economic and investment research, security analysis with concentrations in twelve different industries, and portfolio management for both taxable and tax-exempt assets. Mr. Groesbeck earned a BS degree in Economics from St. Peter’s College and an MBA in Finance from New York University. He holds

the Chartered Financial Analyst designation and is a member of the CFA Society of New York. Mr. Groesbeck is the principal owner of the firm. Theodore M. Groesbeck, CFA – Vice President Mr. Groesbeck, age 54, is a portfolio manager and security analyst. He joined the firm in 1999 and has over 25 years of investment experience. Prior to joining the firm, he was an analyst at Palisade Capital Management, Standard & Poor’s and Gruntal & Co. Mr. Groesbeck’s security analysis experience covers a broad number of economic sectors and industries. Mr. Groesbeck earned a BS degree in Finance from the University of Rhode Island. He holds the Chartered Financial Analyst designation and is a member of the CFA Society of New York. Mr. Groesbeck has partial ownership in the firm. John D. Mattesich, CFA – Equity Analyst Mr. Mattesich, age 58, is a security analyst with over 20 years of experience. Prior to joining the firm in 2006, he was an analyst at Hayground Cove Asset Management, Bear Stearns & Co., Dresdner Kleinwort Wasserstein, and Credit Lyonnais Securities. Mr. Mattesich earned his MBA degree in Finance from Indiana University and a B.B.A. degree from Pace University in accounting. He holds the Chartered Financial Analyst designation and is a member of the CFA Society of New York. The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to:
• Place their clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters To learn more about the CFA charter, visit www.cfainstitute.org.