Andrew Garrett, Inc. began its Investment Advisory business in April 2007 as a State Registered firm and became SEC Registered in 2010. We offer investment advisory services either by managing client assets or as part of a program working with clients to find sub-advisors to manage the client’s assets. We utilize several platforms and programs so that we can meet the varied needs of our clients. The principal officers of the company are: Andrew G. Sycoff President and Chief Executive Officer James R. Mitchell Chief Administrative Officer Mark H. Maurer Chief Compliance Officer Andrew Garrett, Inc. (AGI) provides its Investment Advisor services through RBC Correspondent Services, Charles Schwab, and AssetMark Wealth Management platforms. Fees charged for these services are based on assets under management or a flat yearly fee (for AGI Advisory Service program) and are negotiable within the parameters established by the program sponsors. The fees can be assessed quarterly or can be assessed monthly in advance or in arrears. The client may terminate the service at any time and receive a pro-rated refund of any unearned fees charged in advance. The initial management fee is pro-rated for the remainder of the initial period. Below is a summary of the programs and services we offer. Program Sponsors charge Andrew Garrett, Inc. differing fees for their services. For this reason, your Investment Advisor Representative has a conflict of interest in the recommendation of the platform to use. If fees are charged in arrears all fees are considered earned and no refunds are needed. As of December 31,2023 Andrew Garrett, Inc. had discretionary assets undermanagement of $12,413,043 and non-discretionary assets under management of $ 457,723,096. RBC PLATFORM PROGRAMS ADVISOR PROGRAM provides an opportunity for the client and the Investment Adviser Representative (IAR) to work together on a non-discretionary or discretionary basis to manage the assets in the program. A portfolio is chosen based on the client’s established suitability profile and investment objectives. Fees are charged based on assets under management. This platform offers access to a variety of securities, investment strategies, account re-balancing, complimentary Investment Access Account (Visa Gold Debit Card/ Rewards Program) as well as free checking. The client can restrict the types of investments that are made. RBC Unified Portfolio (RBC UP) is a Wrap Fee Program that provides participants discretionary investment management services, which feature portfolio management provided by a select group of independent investment advisors, which RBC Correspondent Services has previously reviewed through a due diligence screening process, for inclusion as sub-advisers. AGI will review the client’s advisory needs, risk tolerance, investment objectives and assist the client in selecting the appropriate sub- advisers from the group. The client will receive one combined statement, even if they are using more than one sub-advisor. On occasion, either RBC Correspondent Services may remove sub-advisers from the program or AGI may suggest to a client that the existing sub-adviser be replaced with another sub-adviser. Any changes in sub-advisers must be approved by the client. Neither RBC nor AGI have the discretion to change sub-advisers chosen by the client. The client can choose an investment profile that considers Social, Environmental and Governance (ESG) issues in making investment decisions. Different programs have varying asset minimums. Consulting Solutions is a fee-based program that lets you offer your clients access to private account management from some of the top institutional money managers in the country. Different programs have varying asset minimums. ANDREW GARRETT ADVISORY SERVICES AGI offers this program through two separate custodians, RBC Correspondent Services and Charles Schwab. Under the RBC platform the client will pay an annual fee based on assets under management or a flat annual fee that can be assessed monthly or quarterly. Using Schwab as a custodian the client will be charged an annual fee; a percentage of assets under management or a flat annual fee and the client may pay a transaction fee on certain investments. Your Advisor Representative will inform you if a fee applies to the transaction. This diversity allows the advisor and client to choose the assets and strategies best suited to the client. By offering multiple custodians the client benefits from maximum flexibility. Andrew Garrett’s unbundled managed account offers a platform where the advisor manages the assets or features through an a la carte menu of sub-advisors. The account custodians will provide quarterly reporting and flexible billing options. Sub-advisers not in the RBC programs may be available for use. Andrew Garrett provides investment management services to clients on a discretionary or non-discretionary basis under this program. STATE STREET GLOBAL ADVISORS This program uses ETF model Portfolios that help tailor portfolios based on clients Investment Objective and Risk Tolerance. The minimum investment is $5,000.00 State Street Advisors will manage accounts on a discretionary basis. The ETFs in this program are limited to the State Street SPDRs sponsored by State Street. RBC will be the custodian for this platform. ASSETMARK WEALTH MANAGEMENT SOLUTIONS The AssetMark open architecture platform offers a wide variety of investment solutions. The platform includes strategists experienced in implementing investment strategies through rigorous asset allocation models. There is a diversified selection of sub-advisers capable of implementing investment solutions through No-load mutual funds, Exchange Traded Funds, Unified Managed Accounts and Privately Managed Accounts. AGI will review the client’s financial needs, risk tolerance, investment objectives and then assist the client in selecting the appropriate sub-advisers from the group. Mutual Fund Portfolios draw upon the expertise and institutional research capabilities of qualified Investment Managers and Portfolio Strategists. These specialists construct model asset allocations reflecting Risk/Return profiles, tactical or strategic asset allocation approaches and other considerations. The portfolios are then composed of no-load funds selected from hundreds

of carefully screened funds representing some of the most respected fund families. The funds selected may include actively managed, indexed and fundamentally indexed objectives, and may include Asset Mark Funds or proprietary funds from the Portfolio Strategists’ own fund family. Exchange Traded Fund (ETF) Portfolios provide exposure to a range of global capital market indexes, making them an appropriate vehicle for constructing asset allocation portfolios. ETF Portfolio Strategists carefully research the broad universe of ETFs to select those that represent the best fit for their asset allocation strategies. The result is a well-diversified portfolio of assets, managed and monitored by an investment team assembled to bring great capability to the investment process. Unified Managed Accounts (UMAs) offer institutional investment management through a private portfolio consisting of stocks, fixed-income instruments, mutual funds, ETFs and more. The UMAs structure allows the Portfolio Strategist to distill the wide-ranging thinking of multiple experts, implementing their strongest investment ideas in a single simplified format. Individual accounts may gain exposure across dozens of asset classes through the most suitable means available, including individual securities selected by specialists or through other investments such as specialized mutual funds for greater efficiency and liquidity. Privately Managed Solutions meet the diverse needs of the client by providing two solutions. Each solution has unique features. FINANCIAL PLANNING SERVICES Financial Planning Services are offered for clients also. The extent of the services will be determined by the client’s needs. They include financial planning, budgeting, insurance planning, estate planning, and business succession. Fees for these services are independent of the asset management programs above. The fees are negotiable but generally range from $1000 to $15,000 as a flat fee or $100.00 to $400.00 on an hourly rate basis, depending on the scope of the services required and professionals rendering the service. Prior to providing any planning services the clients are generally required to enter into a written agreement setting forth the terms and conditions (including termination) describing the scope of the services to be provided. AGI or any of its representatives do not serve as an accountant or attorney and no portion of our service may be construed as same. If requested by the client, AGI may recommend the services of other professionals for the implementation of the service(s). The client is under no obligation to engage the service(s) of any recommended professional. The client obtains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation. If the client engages any recommended professional and a dispute arises relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Further, it is the client’s responsibility to promptly notify AGI if there are any changes in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising AGI’s previous recommendation or services. In implementing any plan, the client may also purchase non-investment products such as insurance through an AGI representative. The commissions earned on these products are in addition to any fees charged for the financial plan or ongoing investment management services. RETIREMENT PLAN ROLLOVERS-Potential Conflicts of Interest A client or prospective client leaving an employer typically has four options for handling any retirement plan they have through the employer. They can also choose a combination of these options.
• Leave the assets in the former employer’s plan, if permitted
• Roll the assets over a new employer’s plan, if available
• Roll the assets over to an Individual Retirement Account
• Take a lump sum distribution of the assets (which could result in tax consequences) If the Advisor recommends that the assets are rolled over to a program managed by the Advisor, the advisor agrees to act as a fiduciary under the Employment Retirement Income Security Act of 1974(ERISA) or the Internal Revenue Code or both. In making such a recommendation the Advisor has a conflict of interest in the fact that the rollover will create new or additional assets on which the Advisor will be compensated. The client or prospective client has no obligation to follow the advisor’s recommendation. ERISA/Internal Revenue Code If the client is: (1) a retirement plan organized under ERISA (2) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the IRC , with authority to direct assets in the Plan account or to take distributions (3) the beneficial owner of an IRA acting on behalf of the IRA or (4) Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the IRC: then the Advisor or it’s representative are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by the Advisor or it’s representatives or with respect to any investment recommendations regarding an ERISA plan or participant or beneficiary account. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.