Grant/GrossMendelsohn, LLC ("GGM"), doing business under the name GGM Wealth Advisors, provides investment advisory services to individuals, employee benefit plans, trusts, estates, charitable organizations or other business entities. The firm was formed in 2000 when Gross Mendelsohn & Associates (“GMA”), a regional CPA and consulting firm, was admitted as a 50% equity owner to the predecessor firm, Grant Capital Management, LLC. GMA is the parent company of GGM. Asset Management Services GGM provides its clients with investment advisory services ranging from discretionary comprehensive portfolio management to employee benefit plan and non-discretionary investment advising. We recognize that each client’s needs, constraints, preferences, and goals are unique. Accordingly, we strive to tailor our services and advice for each client on an individual basis, based upon needs and circumstances as determined at the time of the initial engagement and as modified from time to time. Our investment advisory services may include:
• Establishing investment objectives and goals in close collaboration with a client, taking into consideration the client’s needs/desires for a) long-term capital appreciation b) income/cash flow c) capital preservation and d) risk tolerance.
• Ongoing asset review and management
• Portfolio analysis and quarterly performance reporting.
• Coordinating with client’s legal, accounting, tax, and other advisors. (We do not, however, provide legal, tax or fund accounting advice.)
• Advising employee benefit plan sponsors on structure, model allocations and investment vehicles.
• Providing asset allocation advice.
• Analyzing risk exposures.
• Ongoing availability for questions on investment markets and strategies. In connection with portfolio management services, we are available at a client’s request and direction to provide modular components of financial planning that are specific and unique to a client’s personal situation. Such services are considered ancillary to the management of the accounts but help us to understand the client’s overall financial situation and to set financial objectives. When helping clients formulate an investment and financial plan, we can produce retirement projections and income-distribution projections. Our portfolio management services involve providing clients with continuous and ongoing supervision over their specified accounts. Clients generally appoint our firm as the investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under the client’s name. The qualified custodians maintain physical custody of all funds and securities of the Account, and the client retains all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by GGM based on the client’s financial situation, investment objectives, and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from clients to determine their financial situation and investment objectives. Clients will be responsible for notifying us of any updates regarding their financial situation, risk tolerance or investment objective and whether they wish to impose or modify existing investment restrictions; however, we will contact clients at least annually to discuss any changes or updates regarding their financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with clients relative to the status of their Account. Clients have the ability to impose reasonable restrictions on the management of their accounts, including the ability to instruct GGM not to purchase certain securities. It is important that clients understand that GGM manages investments for other clients and can give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to clients any security or other investment that we buy, sell or recommend for any other clients or for our own accounts. Conflicts can arise in the allocation of investment opportunities among accounts that we manage. GGM strives to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If GGM obtains material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Clients that determine to engage GGM on a non-discretionary investment advisory basis must be willing to accept that GGM cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, GGM will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. The Advisers Act imposes a fiduciary duty on investment advisers, as such, GGM acts in a fiduciary capacity for all of its clients. As a fiduciary, GGM has a duty of utmost good faith to act solely in the best interests of each of our clients. This fiduciary duty is the core principle underlying our work and represents the expected basis of all of our dealings with our clients. Selection of Sub-Advisers GGM can provide client recommendations to utilize one or more specific sub-adviser(s) (individually “Sub-Adviser” and collectively “Sub-Advisers”) to manage the account or a portion of the assets of the account. When a Sub- Adviser is selected by a client, the Sub-Adviser will have discretionary authority on your account to place trades and make changes to the account or the portion of your account the Sub-Adviser is authorized to manage. GGM will conduct due diligence of any recommended Sub-Adviser and monitor the performance of Sub-Adviser with respect to the Sub-Advisor’s management of the designated assets of Account relative to appropriate peers and/or benchmarks. GGM will be available to answer questions a client has regarding any portion of client’s Account managed by a Sub- Adviser and will act as the communication conduit between Client and the Sub-Adviser. The recommendation of Sub-Advisers is done on a non-discretionary basis with the specific terms outlined in your Advisory Agreement. A complete description of the Sub-Adviser’s services, practices and fees will be disclosed in the Sub-Adviser’s Form ADV Part 2A that will be provided to client. Types of Investments Equity securities utilized for portfolio management are primarily open and closed-end mutual funds and exchange traded funds (ETFs), although individual equities (stocks, preferred stocks, and convertible securities) may also be included. Inverse (short the market) ETFs may be employed as a “hedging” strategy on a selected basis. In addition to bond mutual funds, individual taxable and tax-exempt (municipal) bonds may be utilized where appropriate. We also provide advice on Real Estate Investment Trusts (REITs) as well as private placements such as hedge funds, private equity funds and other, properly exempt from registration, limited offerings. Clients can restrict the use of certain securities or types of securities (e.g. options, futures contracts, commodity contracts or "sin" stocks). When open-end mutual funds are selected, only "no-load" funds or "load-waived" funds are used. (Note: selected funds may require payment of a "transaction" fee payable to the custodian, Charles Schwab & Company.) Individual bonds purchased on behalf of clients are delivered to clients at GGM's cost with no price markup. Transaction charges payable to Charles Schwab (currently $25/trade for each client purchase) are charged to the client account. (See Brokerage Practices) Pension Consulting and Retirement Plan Services GGM offers pension consulting and retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services GGM provides the following Fiduciary Retirement Plan Consulting Services:
• Non-Discretionary Investment Advice. GGM will provide you with general, non-discretionary investment advice regarding assets classes and investment options.
• Investment Selection Services. GGM will provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. GGM will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. GGM will monitor investment options periodically for investment performance and consistency of fund management. GGM will make recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. GGM will provide you with non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval

or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and GGM does not serve as administrator or trustee of the plan. GGM does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). GGM acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. GGM will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause GGM to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, GGM (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Fiduciary Management Services GGM provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. GGM will provide you with continuous and ongoing supervision over the designated retirement plan assets. GGM will actively monitor the designated retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with you. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services. GGM will monitor the investment options of the Plan and add or remove investment options for the Plan. GGM will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants.
• Default Investment Alternative Management. GGM will develop and actively manage qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. If you elect to utilize any of GGM’s Fiduciary Management Services, then GGM will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and GGM hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Non-Fiduciary Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. GGM provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. GGM will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. GGM’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. GGM will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.
• Due Diligence Review. GGM will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, GGM cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. GGM will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learns of such error or omission. Proprietary Exchange Traded Fund: GGM Macro Alignment ETF GGM Wealth Advisors serves as the investment adviser to the GGM Macro Alignment ETF , an actively managed exchange-traded fund (“ETF”) that seeks long-term capital appreciation by dynamically shifting among the sector and style factors best suited for the prevailing macro-economic environment. It is listed on the NYSE, trading under the symbol “GGM”. The GGM Macro Alignment ETF is registered as an investment company under the Investment Company Act of 1940. As investment adviser, we provide investment advice and management services to the GGM Macro Alignment ETF. We maintain limited power of attorney to act on a discretionary basis when managing the GGM Macro Alignment ETF. We are responsible for investment selection, asset allocation, and asset management decisions (trading and overall portfolio allocation decisions) regarding the GGM Macro Alignment ETF. We are responsible for communicating strategy commentary and performance attribution to the ETF’s shareholders (i.e. investors). We are also involved in seeking new investors to the ETF with the intent of growing the ETF’s overall assets. This will include the development and distribution of presentation materials, market commentary, and other strategies designed to provide investors and potential investors with information about the GGM Macro Alignment ETF. We, therefore, have an incentive and inherent conflict of interest to recommend and favor the ETF for the following reasons:
• GGM is the investment adviser to the ETF and receives a management fee for its services. Please refer to Item 5 of this Brochure for a description of our fees. Increases in GGM Macro Alignment ETF assets will result in increases in the management fee paid to GGM.
• We provide the ETF with certain administrative services and personnel needed to fulfill our obligations as the investment adviser. Please refer to additional details provided in Item 10 and Item 11. Regulatory Assets Under Management As of December 31, 2023, GGM managed $419,177,732 on a discretionary basis and $23,900,517 on a non- discretionary basis.