Granite Group Advisors, LLC ("Granite Group") was formed in July 2003 to, among other things, provide discretionary and non-discretionary investment-related services. We assist clients in asset allocation and investment selection among various asset classes and sub-asset classes, including equities, fixed income, real estate, hedge funds, funds of hedge funds, private equity and other asset classes. Within each asset class, we recommend independent investment managers, and for certain clients, private investment funds (e.g., hedge funds, funds of hedge funds, private equity funds, real estate funds and others). As used in this brochure, the words “we,” “our” and “us” refer to Granite Group, and the words “you”, “your” and “client” refer to you as either a client or prospective client of our firm. Investment Management Services for Private Clients Granite Group provides discretionary investment management services to its Private Clients, individuals, including high net worth individuals, trusts, estates, charitable organizations, and business entities. Such services are provided pursuant to an Investment Management Agreement. Our operational structure is designed to utilize independent custodians, independent managers, and Granite Group Advisors to create a more transparent process for our clients. The client’s independent investment managers are only allowed to place trades in an assigned account. Granite Group believes that this structure provides clients with a better option than traditional institutions when the firm is the manager and custodian. We are engaged on a discretionary basis to engage and terminate independent investment managers on behalf of client accounts, and to implement customized allocations among asset classes, in our discretion, consistent with the client's investment objective(s). Investment managers hired by Granite Group will provide active portfolio management with respect to the assets that are allocated to them pursuant to their specific investment strategies and styles. On a more limited basis, we may be engaged to directly purchase and sell individual debt, equity and/or fixed income securities, mutual funds, exchange-traded funds and call writing in accordance with the client’s designated investment objective(s). Clients may place reasonable restrictions on their investment accounts such as specific securities and/or sectors and Granite Group will integrate such restrictions into the client’s investment program. Investment Management for Pension and Retirement Plans Granite Group also provides services to pension and retirement plans, including a Pooled Employer Plan, or PEP, sponsored by an entity owned by the principals of Granite Group (the “PEP”). We assist the plan sponsors to determine the investment objectives and requirements that are appropriate for each plan. We recommend various independent investment alternatives for the plan’s review and consideration including, but not limited to, mutual funds, separate account managers/programs and customized model portfolios based on risk (for approval by each plan sponsor) that best fulfill the investment objectives within each investment category. When it is appropriate, Granite Group can also provide plan clients with an option to participate in a pooled employer plan (PEP), sponsored by an entity owned by Granite Group’s principals and managed by Granite Group as a 3(38) Fiduciary. (Please see description below of services provided by a 3(38) Fiduciary.) Additional information about the PEP managed by Granite Group and potential conflicts of interest is provided under Item 10. We do not sell bundled solutions offered by other service providers. We do not offer any proprietary

products such as target date and lifestyle funds. We assist in the selection of independent mutual funds, record-keepers, custodians, TPAs, auditors and other vendors. We also offer model portfolios which enable plan participants to make a selection based on their personal set of circumstances. We offer two levels of service to retirement plans, defined by reference to provisions in the Employee Retirement Income Security Act of 1974 (“ERISA”) based on client needs as follows: (1) Our ERISA 3(21) service is an investment advisory service in which Granite Group serves as a co- fiduciary providing a defined investment selection process for mutual funds offered in the retirement plan. We will provide customized analytics on all funds, including proprietary online investment and market information to the plan sponsor and the employees/plan participants. This will enable the plan sponsors to make more informed investment decisions. We also perform investment seminars for the plan participants; however, Granite Group has no investment discretion when providing 3(21) services. Either the plan sponsor or another investment fiduciary will make the final decision as to which investments are offered to plan participants. (2) Our second service, ERISA 3(38) fiduciary service, includes the ERISA 3(21) services described above and also offers 5 customized model portfolios based on risk. Granite Group has the discretion to determine the investments to be included in the model portfolios and/or mutual funds to be offered by the applicable plan. In addition, Granite Group’s 3(38) service provides for Granite Group to offer support to employee/participants in the client plans. Employee/participants may call Granite Group directly to provide explanations about the investment options in the plan lineup upon request. This service also provides a custom online investment education solution for each plan and its participants. Granite Group also provides 3(38) Services to the PEP sponsored by Granite Group Retirement, LLC an entity owned by Granite Group’s principals. Additional disclosures about the PEP including potential conflicts of interest are provided under Item 10. Principals: The persons responsible for providing investment advice to Granite Group’s clients, including its private clients and Retirement/Pension plan clients, are Granite Group’s principals, Mr. Lyle B. Himebaugh III and Mr. Richard C. Zipkis.
• Mr. Himebaugh, born 1963, is the Chief Executive Officer of Granite Group. Mr. Himebaugh received a B.A. in Business/Economics from Washington College in 1986. Prior to forming Granite Group, Mr. Himebaugh was a registered representative at Credit Suisse First Boston ("CSFB") (and Donaldson, Lufkin and Jenrette prior to its acquisition by CSFB) from November 1995 to July 2003.
• Mr. Zipkis, born 1964, is the Chief Investment Officer and the Chief Compliance Officer of Granite Group. He received a B.A. in Psychology from Boston University in 1987. Prior to joining Granite Group in February 2004, Mr. Zipkis worked in various capacities at CSFB, including as Director and Chair of the Money Management Selection Committee and Chief of Performance Analytics (2001 through 2004), Member of the Global Tactical Asset Allocation Committee (2002 through 2004) and Head of Trust Advisory Board at CSFB (2003 and 2004). Assets Under Management Assets under management were calculated as of December 31, 2023, based on information provided by third party custodians as to the value of assets as of that date. As of December 31, 2023, assets under management were $ 565,199,742 ($288,607,742 on a discretionary basis and $276,592,000 on a non-discretionary basis).