A. Describe your advisory firm, including how long it has been in business. Identify your principal owner(s). Greenwich Wealth Management, LLC is an SEC Registered Investment Advisor located in Greenwich, Connecticut and West Palm Beach, Florida. As a privately owned boutique firm, we develop and manage custom tailored investment portfolios without the need to promote internal products. GWM has been in business since December of 2006. Michael J. Freeburg is the founder and principal owner. B. Describe the types of advisory services the firm offers. If the firm holds itself out as specializing in a particular type of advisory service, explain the nature of that service in detail. If the firm provides investment advice only with respect to limited types of investments, explain the type of investment advice the firm offers and disclose that the advice is limited to those types of investments. GWM provides investment supervisory services to high net worth individuals, families, trusts, estates, endowments, charitable organizations, corporations, defined benefit/contribution plans and profit sharing plans. GWM charges a fixed annual fee as a percentage of assets under management when managing client assets and investment portfolios at qualified custodians. Third Party - GWM also offers third party investment managing and monitoring services. GWM will provide this service to high net worth individuals and their families, trusts, estates, corporations and profit sharing plans. At the outset of an advisory relationship, GWM typically receives discretionary authority from the client to select third-party investment managers and/or select the identity and amount of securities to be bought or sold by means of the discretion contained in the investment management agreement. GWM exercises its investment discretion consistent with the stated investment objectives for the particular client account. Portfolio Manager Licensing Agreement - GWM has executed a Portfolio Manager Licensing Agreement with Covestor Limited. Covestor Limited (doing business as Interactive Brokers Asset Management) is an SEC-registered investment adviser affiliated with Interactive Brokers LLC, the broker and custodian for some of our client accounts. Pursuant to that agreement, a GWM portfolio manager provides Covestor with information regarding the trading in an IB brokerage account owned by the portfolio manager GWM. The GWM portfolio manager trades that account in accordance with a specific investment strategy. Based on this trading data, Covestor creates a portfolio discussed on its website, which Covestor clients may invest in, if Covestor deems it appropriate based on the client’s suitability profile. Covestor mirrors (subject to certain limits) the trading activity in the GWM portfolio manager’s brokerage account into the accounts of investing clients using Covestor’s proprietary replication logic. Neither GWM nor its portfolio manager offer any investment advice to Covestor clients, have discretionary trading authority over Covestor clients’ accounts, or know the identity or suitability profile of those clients. ERISA 3(21) Retirement Plan Advisor Services – Greenwich Wealth Management, LLC ~ Page 2 of 24 Pages ~ provides advisory services for defined benefit/contribution plans that are designed to assist the plan sponsor. These include but are not limited to: investment menu selection, share class guidance, review of plan structure, and educational support. In acting in a 3(21) fiduciary capacity Greenwich Wealth Management is responsible for providing investment advice, educational materials and educational support to the plan sponsor and is also responsible for the quality of the advice and recommendations offered. Greenwich Wealth Management agrees to apply a fiduciary standard and is thereby subject to certain responsibilities (i.e., acting with exclusive purpose and prudence solely in the interest of the plan sponsor). GWM will work in conjunction with the Plan Sponsor and the plan TPA to review the plan structure at least annually. C. Explain whether (and, if so, how) the firm tailor’s advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. GWM provides continuous advice to clients regarding the investment of client funds based on the individual needs of the client. In initial discussions, goals and objectives based on a client's investment profile is established. These are then developed into a client's personal investment guidelines at which point GWM executes and manages this portfolio based on these guidelines. Securities will be selected for inclusion within a client portfolio based on factors such as the risk tolerance of the client, liquidity needs, the adequacy of portfolio diversification among markets, sectors, industries, investment objectives and tax considerations. Clients will retain individual ownership of all securities and have the opportunity to place reasonable restrictions on the types of investments made. D. If the firm participates in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how the firm manages wrap fee accounts and how it manages other accounts, and (2) explain that the firm receives a portion of the wrap fee for its services. Greenwich Wealth Management does not offer a Wrap Fee Program to clients. E. If the firm manages client assets, disclose the amount of client assets it manages on a discretionary basis and the amount of client assets on a non-discretionary basis. Disclose the date “as of” which it calculated the amounts. GWM has $2,186,775,212 regulatory assets under management as of 12/31/2023. Breakdown Discretionary: $1,948,551,249 Non-Discretionary: $238,223,963 Total: $2,186,775,212 Total: I TEM 5: FEES AND COMPENSATION Describe how the firm is compensated for its advisory services. Provide the fee schedule. Disclose whether the fees are negotiable. Describe whether the firm deducts fees from clients’ assets or bills client for fees incurred. Explain how often the firm bills clients or deducts its fee. GWM is primarily a fee based financial advisory and portfolio management firm. ~ Page 3 of 24 Pages ~ Fee Structure The annual fee for Portfolio Management Services will be based on a percentage of assets under management, according to the schedule below: Portfolio Value Maximum Fee ≤ $1,000,000 1.25%/year ≥ $1,000,001 to $5,000,000 1.00%/year > $5,000,000 0.90%/year General Information on Services and Fees In certain circumstances, fees may be negotiable. GWM may charge different clients receiving the same services different fees. The above are the firm's standard fee schedules. Fees may be negotiable based on the amount of assets under management or the length or scope of the client relationship. The annual fee for portfolios will be determined on a sliding scale and based on the amount of assets under management and the level of client services. Depending on the custodial platform, either GWM or the custodian will calculate the advisory fee based on the value of the assets held in the client's account and the annual rate. GWM generally uses Interactive Brokers, LLC (IB) as custodian for client assets. For clients who utilize IB the advisory fee will be calculated and deducted by Interactive Brokers based on the value of the assets held in the client's account at the end of each business day. The daily fee will be equal to the annual fee divided by the number of business days in the calendar year. Fees for Retirement Plan (401(k) and similar) Investment Advisory Services: Plan Assets Annual Fee $0 - $1,000,000 0.75% of Plan Assets $1,000,001-$10,000,000 0.55% of Plan Assets $10,000,000+ 0.50% of Plan Assets The advisory fees charged by Greenwich Wealth Management, LLC covers all the investment advisory services provided to the plan sponsor; including investment advice, educational materials, educational support and plan review services. Investment ~ Page 4 of 24 Pages ~ Advisory fees are included in the expense ratio of the funds selected by the Plan sponsor and are paid directly to Greenwich Wealth Management, LLC by the custodian. Unless otherwise negotiated, our fee is payable quarterly on all plan assets, in arrears and is exclusive of fund expenses, third party administration and execution costs. For purposes of calculating advisory fees, we request for plan custodians/TPA’s to bill on the quarter as defined by the plan and the custodian/TPA GWM does not perform the calculations or actual fee deductions on defined benefit/contribution plan assets. The fee billing information is believed to be valid and true with respect to fee billings as performed by the custodians utilized. Fees are negotiated by Greenwich Wealth Management, the Plan Sponsor and the Plan custodian/TPA. Other Custodial Platforms: For clients who direct the use of a custodial platform other than IB, the method by which the fee will be calculated and charged will depend on the platform and on client preference. GWM will endeavor to accommodate the billing preferences of the client within the options available on any such platform, and will afford the client the option of paying the advisory fee separately from the custodian. Schwab: Investment management fees will be automatically deducted from the client account by the custodian. The advisor shall send an invoice to the custodian indicating the amount of fees to be deducted. The following method will be used for invoicing: Monthly billing in arrears based on average daily balance of the account for corresponding month Client’s will be provided a statement directly from the custodian at least quarterly reflecting deduction of the management fee. Clients are also able to view their accounts daily online. Clients provide written authorization permitting GWM to be paid directly from their accounts held by the custodian as part of their client agreement and account opening documents provided by the custodian. Third Party Investment Manager and Monitoring Services: GWM may provide Third Party Investment Management and Monitoring Services. The client will be billed directly on an annual basis after services are rendered. The fee for this service is 0.25%, this fee is negotiable. Third party managers may charge a separate fee, which will be disclosed to the client in the third party managers ADV. ~ Page 5 of 24 Pages ~ Data Licensing Fees Received by Greenwich Wealth Management from Covestor Limited: Covestor has agreed to compensate the GWM portfolio manager under the Portfolio Manager License Agreement for licensing this trading data to Covestor. At this time, Covestor charges its clients wishing to invest in the GWM strategy 1% of gross market value of assets invested in the strategy. In accordance with the Portfolio Manager Licensing Agreement, Covestor will retain 0.25% of this fee and remit the remaining 0.75% to GWM. GWM does not receive any compensation based on the performance or capital gains of any client account. C. Describe any other types of fees or expenses clients may pay in connection with firm’s advisory services, such as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage and other transaction costs, and direct clients to the section(s) of your brochure that discuss brokerage. Interactive Brokers – In addition to the advisory fee, client accounts at Interactive Brokers will pay a transaction charge to IB for each trade affected in their account. The exact cost of the transaction charge will be directly debited from the client's account by the custodian without a markup. GWM does not receive commission from IB for client transactions Pricing for common asset classes is below. For a full detailed description of pricing and a list of charges for other investment products please visit https://www.interactivebrokers.com/en/index.php?f=commission&p=stocks and select the Tiered Pricing Structure Tab. United States – Equities ETF expense ratios will be incurred by the client. GWM uses no load mutual funds. GWM does not receive 12b-1 fees. It should be noted that ETF expense ratios paid to the managers will result in GWM clients incurring two layers of fees. Volume (per month) IB Commission per Share US Stocks, ETFs, ETPs and Warrants Minimum per Order Maximum per Order <= 300,000 Shares USD 0.0035 USD 0.35 1.0% of trade value 300,001 - 3,000,000 Shares USD 0.002 USD 0.35 1.0% of trade value 3,000,001

- 20,000,000 Shares USD 0.0015 USD 0.35 1.0% of trade value 20,000,001 - 100,000,000 Shares USD 0.001 USD 0.35 1.0% of trade value > 100,000,000 Shares USD 0.0005 USD 0.35 1.0% of trade value Volume tiers are applied based on monthly cumulative trade volume summed across all US and Canadian stock and ETF shares at the time of the trade. Only shares that are traded while under the Tiered pricing structure will count towards the monthly volume. Share volumes for advisor, institutions, and broker accounts are summed across all accounts for the purpose of determining volume breaks. These fees are applied on a marginal basis for a given calendar month. If for example, you execute 500,000 US shares in a month, your IB Tiered fees would be:
• 300,000 shares at USD 0.0035
• 200,000 shares at USD 0.002 ~ Page 6 of 24 Pages ~
• Orders where the commission cap is applied do not count towards the monthly volume tiers. United States - Bonds For bond trades the fee is based on a percentage of the trade value. Face value of a trade of $10,000 or less = .001 X face value. For face value greater than $10,000 = same as above on initial $10,000 and .00025 X face amount over $10,000. United States - Corporate Bonds & CDs: Commissions Minimum Maximum USD <= 10,000 Face Value 0.1%* Face Value (10 bps) 1, 2 USD 1.00 per Order The smaller of $250 and 1% of Trade Value USD > 10,000 Face Value 0.025%* Face Value (2.5 bps) 1, 2 None The smaller of $250 and 1% of Trade Value 1 basis point=$0.0001 Commissions are tiered. For example, for US corporate and muni bonds, the first 10K in face value is charged @ 0.1% and any remaining principal over 10K is charged at 0.025% United States - Municipal Bonds Commissions Minimum per Order Maximum per Order USD <= 10,000 Face Value 0.1%* Face Value (10 bps) 1, 2 $1 The smaller of $125 or 1% of Trade Value USD > 10,000 Face Value 0.0125%* Face Value (2.5 bps) 1, 2 None The smaller of $125 or 1% of Trade Value 1 basis point=$0.0001 Commissions are tiered. For example, for US corporate and muni bonds, the first 10K in face value is charged @ 0.1% and any remaining principal over 10K is charged at 0.0125%. United States – Treasuries (Bills. Notes, Bonds) Commissions Minimum per Order Maximum per Order USD <= 1,000,000 Face Value 0.002%* Face Value (2.0 bps) 1 USD 5.00 None USD > 1,000,000 Face Value 0.0001%* Face Value (0.01 bps) 1 USD 5.00 None 1 basis point=$0.0001 Commissions are tiered. For example, for US corporate and muni bonds, the first 10K in face value is charged @ 0.002% and any remaining principal over 10K is charged at 0.0001%. United States – Futures For treasury futures there is a non-member exchange fee of .80, an IB fee of .85 (which is comprised of execution, clearing and carrying fees) and a non -member regulatory fee of $0.02. For E-mini futures there is $0.55 exchange fee and an IB fee of .85 (which is comprised of execution, clearing and carrying fees) and a .02 non-member fee per contract. For NYMEX crude oil there is an exchange fee of $1.50 and an IB fee of .85 (comprised of execution, clearing and carrying fees) and a non-member fee of .02 per contract. United States – Cost Plus Tiered Commission per Contract ~ Page 7 of 24 Pages ~ Volume (per month) USD <= 1,000 Contracts 0.85 1,001 - 10,000 Contracts 0.65 10,001 - 20,000 Contracts 0.45 > 20,000 Contracts 0.25 United States – Options For options transactions using the smart router there will be a fee of .70 per share with a $1.00 minimum per order. The maximum fee charged on any exchange for canceling an option order = $2.10. Fees will be disclosed immediately upon GWM trading any other products. Effective June 1, 2011, IB will begin passing on to customers the SEC fee associated with U.S. listed option transactions. This fee, currently assessed at a rate of $0.0000207 per $1.00 of sales proceeds, serves to recover costs associated with the SEC’s supervision and regulation of the U.S. securities markets. Other Options Trading Fees: Options Regulatory Fee (“ORF”) $0.0388 per contract FINRA Trading Activity Fee $0.002 * Quantity Sold OCC Clearing Fees: Trades of 1-999 contracts $.055 per contract Trades of > 999 contracts $55.00 per trade If other products are traded by GWM on behalf of clients the transaction costs associated with those products will be disclosed United States - Smart Routed: <=10,000 Monthly Contract Commissions Minimum Per Order Premium => USD 0.05 USD 0.25 per contract USD 1.00 USD 0.05 => Premium < USD 0.10 USD 0.50 per contract USD 1.00 Premium > USD 0.10 USD 0.65 per contract USD 1.00 United States – Mutual Funds No Transaction Fee Funds $0.00 IBKR Transaction Fee Lesser of 3%* Trade Value in USD or $14.95 per transaction. Mutual fund expense ratios will be incurred by the client. GWM uses no load mutual funds. GWM does not receive 12b-1 fees. It should be noted that mutual funds expense ratios paid to the managers will result in GWM clients incurring two layers of fees. ~ Page 8 of 24 Pages ~ Withdrawals After the first withdrawal (of any kind) in a month, IB will charge the following withdrawal fees for any subsequent withdrawal: $10 for a wire; $4 for checks and $1 for ACH/EFT. Low Balance Account Activity Fees IB also charges clients with account balances less than $100,000 a minimum activity requirement fee of $10.00 per month. In regards to the minimum activity requirement the GWM client’s fees are considered on a consolidated basis. The number of accounts under an Adviser multiplied by the $10 minimum, and compared to the total commissions for all accounts. If the total commissions are greater than the minimum calculation, no minimum activity fee will be applied. If the total commissions are greater than the minimum calculation, the minimum fee calculation will be applied to each individual account that had not met the minimum require activity. Standard activity fee calculation Monthly Activity Fee = 0 if monthly commissions are equal to at least USD 10. If monthly commissions in a client account are less than USD 10, Standard Activity Fee = USD 10 – commissions. Example: Monthly commissions = USD 6 Standard Activity Fee = USD 10 – USD 6 Standard Activity Fee = USD 4 Advisor Accounts Monthly Activity Fee = 0 if consolidated monthly commissions are at least equal to (number of accounts6 x USD 10). Example: Advisor has 12 sub accounts, number of Accounts = 12 Monthly consolidated commissions minimum requirement is 12 x USD 10 = USD 120 If the monthly consolidated commissions are less than the required minimum, an activity fee is charged on an account-by-account basis using the Standard Activity Fee calculation described above. Client is age 25 or under Monthly Activity Fee = $0 if monthly commissions are equal to at least $3. If monthly commissions are less than USD 3, Activity Fee = $3 – commissions. Example: Monthly commissions = $1.25 ~ Page 9 of 24 Pages ~ Activity Fee = $3 –$ 1.25 Activity Fee = $1.75 UGMA/UTMA Accounts Monthly Activity Fee = $0 if monthly commissions are equal to at least USD 10. If monthly commissions are less than USD 10, Standard Activity Fee = $3 These activity fees are only applicable to client accounts with a balance of < 100K Note: there is no Activity Fee for the Master Account. Effective September 1, 2016 IB will pass through FINRA’s Trade Activity Fee, (“TAF”) on all U.S. stock executions. The TAF fee is currently charged at a rate of 0.00019 USD per share the fee is capped at $5.95 USD per trade and 0.0000207 aggregate sales proceeds on stock. Fidelity – In addition to the advisory fee, client accounts at Fidelity will pay a transaction charge to Fidelity for each trade affected in their account. The exact cost of the transaction charge will be directly debited from the client's account by the custodian without a markup. For more specific on fees and minimums please visit: www.fidelity.com. All online U.S. equity/ETF trades $0.00 All online options trades $0.65 per contract Buy to close orders of $0.65 or less $0.00 Bonds and CDs New Issues $0.00 Bonds and CDs Secondary Issues $1.00 per bond3 U.S. Treasury Auctions online $0.00 U.S. Treasury Auctions representative assisted Flat fee of $19.95 Fidelity Mutual Funds $0.00 No Transaction Fee (NTF) non-Fidelity funds: $0.00 on purchase. $49.95 on redemption if held less than 60 days Transaction Fee non-Fidelity funds: $49.95 per purchase.** $0 on redemption Electronic statements $0.00 Monthly statements $0.00 ~ Page 10 of 25 Trade confirms $0.00 Replacement statement $0.00 Replacement confirm $0.00 Early IRA withdrawals $0.00 Roth IRA conversion $0.00 Recharacterizations $0.00 SIMPLE IRA annual fee $0.00 Account closeout fee (Note: Excludes SIMPLE IRAs.) $0.00 Electronic funds transfer (EFT) $0.00 Fidelity BillPay® $0.00 Check copies $0.00 Returned Check $0.00 Stop Payment $0.00 Check Ordering $0.00 HSA check ordering $0.00 Overnight check delivery $0.00 Cashier’s check $10.00 Debit card annual fee $0.00 Fidelity® Cash Management Account ATM fee $0.00 Fidelity® Cash Management Account ATM bank surcharge Reimbursed The Fidelity Account® ATM fee The Fidelity Account® ATM bank surcharge $0.00 for first 5 transactions per month $1.00 per transaction thereafter Varies Bank wire $0.00 Foreign exchange wire Up to 3% of principal Real-time quotes $0.00 Streaming quotes $0.00 Steaming Level II quotes $0.00 Streaming news $0.00 Transfer of assets $0.00 Mandatory corporate reorganization $0.00 Voluntary corporate reorganization $38.00 ~ Page 11 of 25 Depository Foreign Trust Company (DTC) foreign settlement fee Note: Fee is per trade for foreign ordinary stock that is not DTC eligible. $50.00 Stock certificate transfer and ship $100.00 per certificate Mutual fund annual low balance fee $0 per fund Foreign dividends and reorganizations 1% of principal Limited partnership transfer fee $0 Margin liquidation $32.95 Reg T extension $0.00 Schwab - In addition to the advisory fee, client accounts at Charles Schwab will pay a transaction charge to Charles Schwab for each trade affected in their account. The exact cost of the transaction charge will be directly debited from the client's account by the custodian without a markup. If the need should arise for automated phone assisted or brokers assisted trades commission prices could be different. For more specific on fees and minimums please visit: https://www.schwab.com/public/file/P-6374145/Pricing-Guide-AS-10072019- REG23060SI-23.pdf Stocks and ETFs Commissions per Executed Trade Security Type Online Trades Stocks $0.00 Stocks less than $1.00 each executed trade will not exceed Schwab ETF OneSource™ $0.00 $0.12 per share, or 10% of principal, or $50 minimum All other ETFs $0.00 Mutual Funds Transaction Fees per Executed Trade Security Type Online Trades OneSource® Funds $0 Short-Term Redemption Fee (90 days or less) $49.95 Transaction-Fee Funds $45 Certain transaction-fee funds are eligible for a $25 reduced transaction fee Options Commissions per Executed Trade Security Type Online Trades Options $0 base commission/$0.65 per contract fee Fixed Income Commissions per Executed Trade Security Type Online Trades US Treasuries $0 Agencies $0.20 per bond ($10 minimum/$250 maximum) Other Secondary F.I. $1.00 per bond ($10 minimum/$250 maximum) Specialty F.I. Contact Schwab for pricing ~ Page 12 of 25 Withdrawals Check Order Fee $0 Overnight Fee $8.50 Nonsufficient Funds/return item $25 per item Wire Transfer (outgoing) $25 per transfer D. If the firm’s clients either may or must pay your fees in advance, disclose this fact. Explain how a client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period. Explain how you will determine the amount of the refund. GWM does not bill or collect fees in advance. E. If the firm or any of its supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact. GWM does not accept compensation for the sale of securities or other investment products.