Torrey Growth & Income Advisors, LLC (Torrey Growth & Income) is a registered investment adviser based in Del Mar, California. The firm is a limited liability company organized in the State of California. We have been providing investment advisory services since 2006. George R. Hoover Jr. is the owner of our firm. The following describes our services and fees. As used in this brochure, the words "we", "our", and "us" refer to Torrey Growth & Income and the words "you", "your", and "client" refer to you as either a client or prospective client of our firm. INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We offer discretionary and non-discretionary portfolio management services. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. We primarily offer advice on stocks, exchange traded funds (ETF's), options contracts on stocks, United States governmental securities. We may also provide advice on foreign issuers, warrants, commercial paper, certificates of deposit. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with

the client's stated investment objectives, tolerance for risk, liquidity and suitability. IRA ROLLOVER RECOMMENDATIONS Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. ASSETS UNDER MANAGEMENT As of March 15, 2024, we were actively managing $303,038,539 of clients' assets on a discretionary basis.