GM Advisory Group LLC (“GMAG”, the “Adviser”, “we”, “us”, “our” or the “Firm”), organized in 2004 and converted to a limited liability company in 2023, is organized under the laws of the State of Delaware. GMAG succeeded to the business of GM Advisory Group, Inc. The firm is a subsidiary of Wealthspire Advisors LLC. On November 1, 2023, the firm was acquired by Wealthspire Advisors LLC, a SEC-registered investment advisor wholly owned by NFP Corp. (previously known as National Financial Partners Corp.) (“NFP”). NFP was acquired by Aon plc on April 25, 2024. Following the November 1, 2023 acquisition, the firm became a subsidiary of Wealthspire Advisors LLC. The firm intends to maintain a separate client brochure until such time as the operations of Wealthspire Advisors LLC and the firm are sufficiently integrated to merit a combined client brochure. Prior to rendering services to our clients (“clients”, “you” or “your”), clients must enter into an investment advisory agreement with GMAG. While this brochure generally describes the business of GMAG, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on GMAG’s behalf and is subject to the Firm’s supervision or control. GMAG provides the following investment advisory services: Investment Management Services We provide discretionary and non-discretionary investment management services through separately-managed accounts. Prior to rendering investment management services to clients, clients must execute an investment management agreement (“Investment Management Agreement”) with GMAG. We primarily provide discretionary investment management services to our clients, principally through a wrap fee program (the “Program”). Clients in the Program pay a single specified annual fee, inclusive of execution, custody, performance reporting, and investment management fees. GMAG also offers clients participation in a non- discretionary wrap fee program. GMAG also offers to its clients nondiscretionary investment advisory services, on a non-wrap fee basis, as well as financial planning and consulting services on a stand- alone basis. Fees for such services are primarily offered on a flat fee basis. To the extent offered, the Advisors flat fee will be based upon various subjective and objective factors. GMAG has personal discussions with its clients in which their investment objectives, based on their particular financial circumstances, are determined. We develop a client’s investment policy and create and manage a portfolio based on that policy, consisting of one or more of the following: individual equities, bonds, exchange traded funds (“ETFs”), no- load or load- waived mutual funds, third-party managed equity or bond strategies, or other investment vehicles (including private investment funds including hedge and private equity funds). Each client has the opportunity to place reasonable written restrictions on investing in certain securities or types of securities. These limitations or restrictions are required to be memorialized in writing. Restrictions do not have to be reflected in a client’s investment management agreement; restrictions are reflected in various forms, including but not limited to, investment policy statements, agreed to in writing by both parties, and by email. As part of an overall client asset allocation strategy, GMAG may recommend that eligible clients consider allocating a portion of their investment assets to private investment funds. If the client determines to invest in a private investment fund recommended by GMAG, GMAG may be compensated based upon the value of the assets placed in private investment funds in accordance with the Program fee schedule or other managed account agreement. The Program Fee or other advisory fees paid to GMAG are in addition to the fees paid to the private investment fund sponsors and managers, as described in the offering documents of any of those private investment funds. The decision whether to invest in a fund rest with each client after that client has received and reviewed the fund's offering documents (including, among others, a confidential private placement memorandum that details, among other items, the terms, risks and conflicts of interest pertaining to an investment in that fund). GMAG has previously recommended that certain of its advisory clients invest in one or more Funds (“Funds”) managed or sponsored by GMAG Management, an investment adviser previously under common control with GMAG’s predecessor, GM Advisory Group, Inc. In addition, certain affiliates of GMAG Management sponsor and serve as general partner or managing member of such Funds (“Sponsors”) and, as a result, receive compensation, depending on the Fund. Frank Marzano, a Managing Director of GMAG, has a controlling ownership interest in GMAG Management and its affiliates that serve as general partner of the Funds. A conflict of interest exists as Frank Marzano has a financial incentive to recommend an investment in a Fund where GMAG Management or its affiliates can earn compensation. Nonetheless, an investment in a Fund is only recommended to clients with consideration of numerous factors in mind, including but not limited to, the client’s investment objective and financial circumstances. The Funds shall continue to be operated separate and independent of Wealthspire and GMAG. The Funds will not be offered to Wealthspire or GMAG clients. Clients may continue to own one or more of the Funds, but neither the purchase of a new Fund or additional investment in a currently owned Fund will be permitted. Wealthspire and GMAG does not, and shall not,

monitor or supervise any of the Funds, nor will it supervise Mr. Marzano relative to his role with the Funds. Wealthspire and GMAG does not, and shall not, receive compensation from any of the Funds. Financial Planning and Consulting Services From time to time, GMAG provides certain financial planning and consulting services to its clients on non- investment related matters. Although GMAG generally considers these services incidental to the services it provides under its managed account services, including the Program, GMAG may determine to provide these services on a fixed fee basis, separate and apart from its managed account services including the Program. In that event, GMAG will describe these services and fees in a separate financial planning agreement or limited consulting agreement between GMAG and the applicable client. These services cover financial planning for a variety of client needs, including but not limited to, cash flow planning, business planning, risk management, retirement and wealth preservation planning, tax planning and analysis, charitable giving, and bill pay. Fees will be determined on a case-by-case basis depending on the needs of the client. The agreements will also include a description of the fees to be charged and when they are to be paid. If GMAG agrees to provide these services, GMAG's obligations are expressly limited to the planning and consulting services specifically requested by the client. We may recommend the services of other professionals, nonetheless, clients are under no obligation to engage the professionals we recommend. GMAG does not guarantee the services of any recommended professional, and we are not liable for any action, omission, recommendation, decision, or loss as a result of a Client’s use of one of these recommended professionals. Customized Services GMAG provides customized advisory services to its managed account clients based upon each client’s unique needs, objectives, and concerns. We review client investment goals and financial circumstances with clients. Following such review, we develop an investment strategy and investment guidelines for each client. Each client has the opportunity to place reasonable written restrictions on investing in certain securities or types of securities. Unless a client has advised GMAG in writing to the contrary, GMAG is not subject to restrictions on the discretionary management of a particular client’s managed account assets. Wrap Fee Programs As described herein, we offer our managed account clients the option to participate in our Program. The services offered under, and the corresponding terms and conditions pertaining to, the Program are discussed in GMAG’s Wrap Fee Program Brochure, a copy of which is presented to all prospective Program participants. Under the Wrap Fee Program, GMAG offers participants discretionary and non-discretionary investment management services for a single specified annual fee, inclusive of execution, custody, performance reporting, and investment management fees. GMAG receives a portion of the Program fee for its services. Execution, reporting, and custodial services for the Program are generally provided by a Pershing Advisor Solutions, LLC (“Pershing”), Fidelity Investments (“Fidelity”) and/or Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”). Additionally, Program accounts are generally maintained at Pershing, Fidelity and/or Schwab. Prior to engaging GMAG to provide investment management services under the Program, each client will be required to enter into an Investment Management Agreement with GMAG setting forth the terms and conditions under which GMAG manages each such client’s assets, and a separate custodial/clearing agreement with the Program broker-dealer and custodian. GMAG has a potential disincentive to trade securities as a result of the transaction/execution costs that it is required to pay its broker-dealer and custodian for securities transactions. When beneficial to the client, as determined by GMAG in its sole discretion, individual equity and fixed income transactions may be effected through broker-dealers with whom GMAG has entered into arrangements for prime brokerage clearing services. Participation in the Program may cost more or less than purchasing such services separately. Depending upon the wrap fee charged by GMAG, the amount of portfolio activity in a client’s account, and the value of custodial and other services provided with respect to such client’s account, the wrap fee charged to such client may or may not exceed the aggregate cost of the services provided to such client if such services were provided separately or if GMAG were to negotiate transaction fees and seek best price and execution of transactions for such client’s account. In addition, the fees charged by GMAG for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. There is no substantive difference between how we manage wrap fee accounts and how we manage other accounts. Client Assets We Manage Assets Under Management As of December 31, 2023, the Firm managed approximately $2,059,339,329 in discretionary and $986,748,240 in non- discretionary assets totaling $3,046,087,569 in assets under management. Assets Under Advisement As of December 31, 2023, the Firm pursuant to its financial planning and consulting services which cover financial planning for a variety of client needs, including but not limited to, cash flow planning, business planning, risk management, retirement and wealth preservation planning, tax planning and analysis, charitable giving, and bill pay advised through the activities of planning and consulting $3,905,093,406 in assets under advisement.