A. The Firm and its Owners. Kevin M. Gibney and Company, LLC (“Gibney”), is a New Jersey limited liability company that was formed in September 2009, and initially registered as an investment adviser with the United States Securities and Exchange Commission on October 20, 2009. Gibney’s majority owner is Kevin M. Gibney who also serves as the firm’s Chief Compliance Officer and Managing Member, and its minority owner is Vanessa B. Curran. B. The Firm’s Services. As discussed below in this Disclosure Brochure, Gibney offers discretionary and non- discretionary investment management services, and financial planning and consulting services. 1. Discretionary Investment Management Services. Gibney’s investment management services are defined as giving ongoing and continuous investment advice to a client based on the client’s investment objectives and financial situation. Each client will complete a profile questionnaire that contains questions about the client’s investment experience, investment time horizon, financial objective, income needs, and risk attitude. Gibney and the client will collectively use this form and their personal discussions to establish the client’s financial situation, risk tolerance, and investment objectives. Based on this information, the firm will then provide investment advice with respect to various equity securities (such as exchange-listed and securities traded over-the-counter), investment company securities (such as variable life insurance contracts, variable annuities, and mutual fund shares), United States government securities, and options contracts on securities.
Although Gibney’s investment advice is typically limited to those investment categories, Gibney may provide advice with respect to other investment opportunities in response to a client request, where such a security is held in a client’s portfolio at the beginning of the advisory relationship, or where Gibney determines that it would be in the interests of the client to pursue those other investment opportunities. In addition to the above securities, Gibney recommends that its clients allocate investment assets, on a discretionary basis, among various mutual fund asset allocation models, underlying mutual funds, exchange-traded funds, and/or independent investment manager programs offered through one or more independent managers (the “Independent Manager(s)”). The client may be required to execute a separate written agreement with the Independent Manager(s) and may incur fees imposed directly by the Independent Manager(s). Each client must specifically authorize the Independent Manager(s) to effect rebalancing and reallocation decisions of such client’s investment assets. Otherwise, all such rebalancing and/or reallocation decisions shall be determined by Gibney pursuant to its grant of discretionary authority. Neither Gibney, nor its principal and/or associated persons, will receive any portion of the fees charged by the Independent Manager(s) or any broker-dealer/custodian. The fees charged by such parties are exclusive of, and in addition to, Gibney’s investment management fee. In addition to Gibney’s investment management fee, the client, relative to all mutual fund purchases, shall also incur charges imposed at the mutual fund level (e.g., advisory fees and 5 of 16 other fund expenses) (see the additional disclosure within

Item 5 of this Disclosure Brochure concerning additional fees that a client’s account may incur). 2. Non-Discretionary Investment Management. Gibney’s non-discretionary investment management services consists of Gibney directing or recommending the allocation of client assets among the various mutual fund subdivisions that comprise a client’s variable life/annuity product or individual employer-sponsored retirement plans. The client’s assets shall be maintained at either the specific insurance company that issued the variable life/annuity product which is owned by the client, or at the custodian designated by the sponsor of the client’s retirement plan. 3. Financial Planning and Consulting. Gibney’s financial planning and consulting services are comprised of ongoing financial counseling services for client accounts which incorporate estate planning, investment planning, cash flow planning, income tax planning, retirement planning, and risk management, including property and casualty, and life insurance and annuities. Gibney will gather relevant information about its financial planning client through interviews with the client and a review of various documents that the client will produce to Gibney. Depending upon the client’s request, Gibney may (a) develop a financial plan for a client that presents Gibney’s conclusions and recommendations, (b) present written conclusions in a less formal format, or (c) not provide any written conclusion or financial plan to a client, instead orally discuss financial planning issues and conclusion with such a client. If requested by the client, Gibney will assist the client with the implementation of the financial plan while working with the client’s attorney, accountant, and/or insurance agent. Gibney may also recommend the services of other professionals if asked by the client. The client is under no obligation to engage the services of any such recommended professional, and retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Gibney. C. Miscellaneous Information About the Firm’s Services. In connection with the provision of Gibney’s services, (1) Gibney tailors its advisory services to the client’s individual needs, (2) clients may impose reasonable restrictions on Gibney’s services, which may include restrictions on investing in certain securities or types of securities, (3) the client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from Gibney, (4) Gibney is authorized to rely on any and all information that is provided to Gibney by the client or any of the client’s other professionals (such as the client’s attorney or accountant), and shall not be required to independently verify any such information, and (5) each client is responsible to promptly notify Gibney if there is ever any change in their financial situation or investment objectives so that Gibney is positioned to review, evaluate and possibly revise its previous recommendations and/or services. 6 of 16 D. The Firm’s Assets Under Management. The firm’s investment management services include both discretionary and non-discretionary asset management. As of December 31, 2023, Gibney’s total amount of discretionary and non- discretionary assets under management was $260,938,861 and $8,826,249, respectively.