Firm Description GCM was established in 1993. GCM is majority owned by Gallacher, LLC. Gallacher Equity Management (“GEM”) is wholly owned by GCM. As of January 31, 2023, GCM managed approximately $422,440,545; $380,954,040 of client assets on a discretionary basis and $41,486,505 on a non-discretionary basis. Investment Advisory and Management Services Through its Investment Advisory Agreement (“IAA” or “Client Agreement”), GCM offers Investment Advisory Services (“IAS”) as an integrated approach that includes, but is not limited to, wealth management, investment management, financial planning and consulting. GEM Investment Management Service is offered to clients of GCM as a separate investment platform of proprietary strategies created or sourced by GCM, which may change from time to time, and is independent from IAS mentioned above. More information regarding GEM analysis is available in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss within this Brochure. IAS and GEM consider information collected from their clients, such as their financial status, investment objectives, investment restrictions and tax status, among other data. The GEM investment strategy options are described further below in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss within this Brochure. GCM does not serve as an attorney or accountant, and no portion of their services should be construed as legal, tax or accounting services. GCM may also provide client access to eMoney, an internet-based service which can incorporate all the client’s investment assets, including those investment assets that are not part of the assets that GCM manages (“Assets Held Away”). The client remains solely responsible for the investment performance of the Assets Held Away. Private Investment Funds GCM may also provide investment advice regarding both affiliated and unaffiliated private investment funds. GCM, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds. As of March 31, 2023, GCM is affiliated with three private investment funds: GEM Private Equity Fund, L.P., GEM Private Equity Fund II, L.P., and GEM goHomePort Fund I, L.P. (together “Affiliated Funds”). GCM also serves as an adviser to a separate affiliated investment, SR36 Self Storage, LLC, that is discussed further in Item 10 – Other Financial Industry Activities and Affiliations within this Brochure. The GEM Private Equity Fund, L.P. (“GEM Fund I”) and GEM Private Equity Fund II, L.P. (“GEM Fund II”) are single purpose private equity funds organized to make a total investment of $24 million via a debt offering which includes warrants in Folium BioSciences, a United States (“U.S.”) based fully integrated whole hemp genetic, cultivation, extraction, production and distribution company. The GEM goHomePort Fund I, L.P. (“GEM goHomePort Fund”) is a private fund organized to invest in real estate and other related investments. As of December 31, 2022, the fund investment window was closed with a total investment of $16.6 million. If a client invests in a private investment fund, the assets invested are generally included in calculating GCM’s fees. Since GCM and/or its affiliates can earn compensation from the Affiliated Funds (i.e., management fees and/or incentive compensation) that may exceed the fee that GCM and/or its affiliates would earn under its IAA referenced in Item 5 – Fees and Compensation below, the recommendation that a client purchase an interest in any Affiliated Fund presents a conflict of interest. No client is under any obligation to become an Affiliated Fund investor. GCM’s CCO, Colin Cox, remains available to address any questions regarding this conflict of interest. Private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the investor client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Retirement Plan Consulting Services GCM may be engaged to provide discretionary and/or non-discretionary pension consulting services, pursuant to which it assists

sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives, generally open-end mutual funds, from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, GCM shall also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Services Agreement between GCM and the plan sponsor. Retirement Account Rollovers. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax and penalty consequences). If a client rolls over their retirement plan assets into an account to be managed by GCM, it could create a conflict of interest if GCM will earn a new (or increase its current) advisory fee as a result of the rollover. GCM and/or its affiliates do not recommend any one option as it relates to client rollovers for new or existing clients, but rather, educates the client on their options available to them. No client is under any obligation to rollover retirement plan assets to an account managed by GCM. ERISA/IRC Fiduciary Acknowledgment. When GCM provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way GCM makes money creates some conflicts with client interests, so GCM operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, GCM must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that GCM gives advice that is in the best interest of the client;  Charge no more fees than are reasonable for GCM’s services; and  Give the client basic information about conflicts of interest. Financial Planning and Consulting Services GCM offers personal financial planning tailored to a client’s individual needs. This financial planning may be included as part of IAS or through a separate Financial Planning Agreement. GCM also offers consulting services with services specified in the consulting agreement. Financial planning and consulting services may include, as selected by the client, information and recommendations regarding tax planning, investment planning, retirement planning, estate planning, business planning, education planning, life and disability insurance needs, long-term care needs and cash flow/budget planning. These services consider information collected from the client such as financial status, investment objectives and tax status, among other data. The Investment Advisor Representatives (“IAR”) may or may not deliver to the client a written analysis or report as part of these services. Client Obligations. As GCM performs these services, GCM shall not be required to verify any information received from the client or from clients’ other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify GCM if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating or revising GCM’s previous recommendations and/or services.