GGS is a registered investment adviser. Since 2010, the Firm has been providing its clients with a variety of advisory services, which include financial planning, pension consulting, and the management of investments. Prior to the rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with GGS setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). The Firm is owned by intermediate subsidiaries, MP Stein, LLC, Stephen R Galvin Asset Management, LLC, and SLG 82, LLC, each of which is owned by Mark P. Stein, Stephen R. Galvin, and Stephen L. Gaustad. As of December 31, 2023, GGS had $1,191,853,438 of assets under management, $1,175,822,777 of which was managed on a discretionary basis and $16,030,661 of which was managed on a non-discretionary basis. While this brochure generally describes the business of GGS, 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 GGS’ behalf and is subject to the Firm’s supervision or control. Financial Planning Services GGS offers clients a range of financial planning services, which may include any or all of the following functions:  Business Planning  Cash Flow Forecasting  Asset Allocation  Retirement Planning  Estate Planning  Financial Reporting  Investment Consulting  Insurance Needs Analysis  Retirement Plan Analysis  Charitable Giving  Risk Management  Distribution Planning In performing these services, GGS is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. Clients are advised that a conflict of interest exists if clients engage GGS to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by GGS under a financial planning engagement or to engage the services of any such recommended professionals, including GGS itself. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising GGS’ previous recommendations and/or services. Retirement Plan Consulting Services GGS provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the following services:  Plan Design and Strategy  Plan Review and Evaluation  Executive Planning and Benefits  Investment Management and Review  Plan Fee and Cost Analysis  Retirement Plan Committee Consultation  Fiduciary and Compliance  Participant Education As disclosed in the Agreement, certain of the foregoing services are provided by GGS as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of GGS’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Investment Management Services GGS manages client investment portfolios on a discretionary or non-discretionary basis. GGS primarily allocates client assets among individual debt and equity securities and exchange-traded funds (“ETFs”), in accordance with the investment objectives of its individual clients. On a more limited basis, the Firm allocates client assets among independent investment managers (“Independent Managers”) and options, as well as the securities components of variable annuities and variable life insurance contracts. In addition, GGS may also recommend that clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios, however, clients

should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients may also engage GGS to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, GGS directs or recommends the allocation of client assets among the various investment options available with the product. These assets are maintained at the underwriting insurance company or the custodian designated by the product’s provider. GGS tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. GGS consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify GGS if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if GGS determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Sponsor / Manager of Wrap Program GGS is the sponsor and manager of the Galvin, Gaustad & Stein Wrap Fee Program (the “Program”), which is an arrangement where investment advisory services, brokerage execution services and custody are provided by GGS as the sponsor for a single predetermined “wrap” fee regardless of the number of trades completed by a client. Generally, clients participating in the Program (“Wrap Program Clients”) pay this single, all-inclusive fee that includes money management fees, certain transaction costs, and custodial and administrative costs. If you participate in our Program, you will pay a single fee to us, quarterly in advance, based on the net assets under management. GGS receives a portion of the wrap fee for its services as the portfolio management to the Program as well as the sponsor of the Program. Transactions for your account are executed by a securities broker-dealer via the Program. The overall cost you will incur if you participate in our Program may be higher or lower than you might incur by separately purchasing the types of securities available in the Program. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by broker-dealers, and the advisory fees charged by investment advisers. Accounts managed through the Program are done so in substantially the same manner as those managed under a non-wrap arrangement. Additional information about the Program is available in GGS’ Wrap Brochure, please see Part 2A Appendix 1 of the Firm’s Form ADV. Use of Independent Managers As mentioned above, GGS may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement between the designated Independent Manager and either GGS or the client. GGS evaluates various information about the Independent Managers it chooses to manage client portfolios, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. GGS also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. GGS continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. GGS seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. 2 8