Firm Profile GVA was formed under the laws of the State of Delaware as a Registered Investment Adviser in 1986 with the goal of assisting our clients in every aspect of their financial lives. We are committed to helping clients build, manage, and preserve their wealth and to providing assistance to clients to help achieve their stated financial goals. We manage accounts on a discretionary and/or non-discretionary basis and manage investment advisory services on a wrap or non-wrap fee basis. The services included in a wrap fee agreement will depend upon each client’s need. Individuals associated with GVA will provide its investment advisory services. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on behalf of GVA. Such individuals are known as Investment Adviser Representatives (“IAR”). Years in Business Date of formation: August 27, 1986 Date of initial investment advisor registration: State of Delaware: May 14, 1985 SEC: April 8, 2011 Direct Principal Owners The firm was originally established by Alan Peters in 1986. Currently, GVA is owned by Ryan C. Todd* and James J. Spinelli*. In October of 2022, LPL Capital Partners Inc purchased a minority stake in Great Valley Advisor Group, LLC. GVA maintains a custody and clearing relationship with LPL Financial, in addition to utilizing certain of its Advisory products and services. This creates a conflict of interest in that we may be incentivized to trade through or use products and services offered by LPL Financial. We mitigate this risk through our best execution reviews, and our due diligence of the products and services offered. *The majority stake of Great Valley Advisor Group is now owned by GVA Management Holding Inc. Ryan C. Todd and James J. Spinelli are the owners of GVA Management Holding Inc.
Types of Investments We offer advice on many types of investments including but not limited to equity securities, corporate debt and US Government securities, certificates of deposit, municipal securities, life insurance, mutual fund and exchange traded fund (ETF) shares, United States government securities, options contracts on securities, options contracts on commodities, money market funds, Real Estate Investment Trusts (REITs), and derivatives. Additionally, GVA offers Alternative Investments through certain advisory accounts offered through LPL Financial. Where we offer advice on structured products, interests in partnerships investing in real estate, alternative investments interests in partnerships investing in oil and gas interests, or private funds (including hedge funds and private equity funds to accredited or qualified investors only). Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities, industries or certain types of securities. You must provide these restrictions to our firm in writing. Investment Management and Supervision Services We offer discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. These services include investment analysis, allocation of investments, quarterly portfolio statements and ongoing monitoring services for the portfolio. GVA determines your portfolio composition based on your needs, portfolio restrictions, if any, financial goals and risk tolerances. We will work with you to obtain necessary information regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This enables us to determine the portfolio best suited for your investment objective and needs. In performing our services, we may be required to verify certain information received from you or from other professionals. If you request, we may recommend and/or engage the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. Once we have determined the types of investments to be included in your portfolio and allocated them, we will provide ongoing portfolio review and management services. This approach requires us to review our portfolios on at least an annual basis. We will rebalance the portfolio, when appropriate, to meet your financial objectives. For accounts over which we have discretion we will trade these portfolios and rebalance them on a discretionary basis. Our advisory services are tailored to meet your individual needs. While our advisory services are tailored to you as an individual, when using open-end mutual funds or Exchange Traded Funds (“ETF”) this multi-fund manager approach makes it difficult for us to ensure that your portfolio will not invest in a particular industry or security. However, we are happy to discuss your preferences regarding socially conscious investment requests and will try to accommodate them to the extent possible. In all cases with the exception of mutual funds, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do not and will not have custody of your funds or securities. The Custodian will deduct investment advisory fees, only with the appropriate authorization from you. IARs of GVA may also be registered representatives of LPL Financial (“LPL”), a full-service securities broker/dealer and investment adviser licensed under federal and state securities laws, located in San Diego, California. LPL is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation (“SIPC”). Securities transactions for LPL's brokerage clients are executed through LPL, a self-clearing firm. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect an account’s performance. This could result in capital losses in your account. Third Party Advisor Program GVA has entered into agreements or arrangements with various independent, third-party investment advisers (“TPAs”). Under these agreements or arrangements, GVA has the ability to refer clients to TPAs for investment in various types of programs sponsored by these TPAs. Under these programs, the TPA which you select will handle the day-to-day management of your account(s) on either a discretionary or non-discretionary basis, depending on the type of program. All TPAs to whom GVA will refer clients will be a registered investment adviser with the applicable State. GVA strives to maintain relationships with several high quality and recognizable TPAs. Among the criteria that GVA may consider in connection with establishing a relationship with a TPA are the TPA’s experience, assets under management, performance record, client retention, the level of client services provided, investment style, buy and sell disciplines, capitalization level, and general investment process. In addition, GVA does at least annual reviews that include reviews of SOC reports, ADV filings, cybersecurity policies, books and records retention policies among other things. GVA also considers the cost of the services provided to you by the TPA as well as any quantitative or qualitative criteria required by the TPA. Cost of TPA programs may vary depending on the type of program, services provided and other criteria, such as investment minimums. These costs will be disclosed in connection with formally establishing an arrangement with a TPA. Certain programs offered by TPAs may be “wrap fee” programs, in which clients are charged a single fee for a bundle of services, such as investment management and trading services. Clients should be aware that a part of the “wrap fee” they pay to a TPA in such programs may, in turn, be paid to GVA for introducing you to the TPA and for your GVA IAR providing ongoing supervision of the TPA’s management of your account. Please refer to additional important disclosures regarding “wrap fee” programs in Item 5 of this brochure. Your GVA IAR will work with you to ensure that your investment profile matches the stated objectives of the TPA program(s) in which you consider investing. Following recommendations by a GVA IAR, you will have final authority to select a TPA and TPA program. In some cases, the TPA may also assist in matching your investment objectives and personal and financial data with the programs available at the TPA. TPA programs generally have account minimum requirements that will vary from investment adviser to investment adviser, which are generally higher on fixed income accounts than on equity-based accounts. A complete description of the TPA’s services, fee schedules and account minimums will be disclosed in the TPA’s Form ADV or similar Disclosure Brochure which will be provided to clients at the time an agreement for services is executed and an account is established. Clients who select a TPA program will enter into an agreement directly with the TPA. In some cases, the agreement will be a joint agreement with both GVA and the TPA. The agreements will describe the services to be provided by the TPA (and GVA, if applicable), the cost of those services, as well as other important information such as when reports will be provided and how you can terminate the arrangement. Performance reporting will generally be the responsibility of the TPA. Such performance reports will be provided directly to you and GVA. In some cases, your GVA IAR will be available to answer your questions regarding your TPA account and act as the communication conduit between you and the TPA. Note, however, TPA accounts are managed by the selected TPA and GVA does not have any discretionary trading authority with respect to the day-to-day management of such accounts. Investors are advised and should understand that:
•A TPA’s past performance is no guarantee of future results;
•There is a certain market and/or interest rate risk which may adversely affect any TPA’s objectives and strategies, and could cause a loss in a Client's account(s);
•Client risk parameters or comparative index selections provided to GVA are guidelines only;
•No guarantees can be made that a client’s financial goals or objectives will be achieved; and
•Investments involve risk, including the possible loss of principal.
Clients are advised that certain TPAs may agree to pay a portion of their advisory fees to GVA. In these cases, GVA IARs may have a conflict of interest to offer those TPAs that have agreed to pay such a fee to GVA. GVA attempts to mitigate this conflict by reviewing that the TPAs and TPA programs selected by clients are consistent with the client’s stated investment profile, in addition to its initial and ongoing due diligence. You should know that GVA does not seek relationships with all possible TPAs and there may be TPAs that GVA has not vetted or decided not to include on its list of TPAs to recommend to clients that may charge lower fees for providing similar services. Financial Planning Services Comprehensive personal financial planning is provided to clients pursuant to a written agreement and fee schedule. To determine a suitable course of action for an individual client, the IAR will perform a review of the variables presented. This review may include but would not necessarily be limited to: investment objectives, consideration of your overall financial condition, income and tax status, personal and business assets, risk profile and other factors unique to your particular circumstances. The IAR will prepare a written plan with specific or general investment and/or planning recommendations based on the information provided by the client. This plan will describe the current situation, identify needs and opportunities and make recommendations with the aid of financial projections which are designed to help the client work toward his or her stated goals. Our primary focus will be to coordinate all areas of the client’s total planning picture, to help achieve the highest possible level of outcome for all concerned. This process is designed to help you, the client, articulate and quantify goals, organize financial data, identify needs and opportunities and evaluate alternative courses of action. It includes an analysis of client goals and objectives, assets, liabilities, current net worth, income taxes, cash flow, investments, employee benefits, estate and gift tax planning, education planning and risk management. GVA cannot offer any promises or guarantees that client financial goals and objectives will be met. As the client’s financial situation, goals, objectives or needs change, the client must notify GVA promptly. Financial Planning may include estate analysis and development of strategies and techniques for working towards minimizing estate taxes and other estate costs. Recommendations are also made to help assure that your estate is distributed according to your wishes. While comprehensive financial planning includes investment advice concerning securities, it also includes investment advice with respect to products that may not constitute “securities,” such as certificates of deposit, life insurance and fixed annuities. GVA does not offer legal or tax advice and so we encourage you to consult your attorney or accountant for guidance specific to your circumstances. GVA, though, may take into consideration tax and estate planning issues to help in its formulation of “investment advice.” In preparing your financial plan, we may address any or all of the six areas of financial planning established by the National Endowment for Financial Education and endorsed by the Certified Financial Planner Board of Standards, depending on your specific needs. These include: financial position, protection planning, investment planning, income tax planning, retirement planning, and estate planning. Our specific services in preparing your plan may include:
• Determining appropriate income planning strategies for both pre- and post-retirement timeframes;
• Reviewing existing and proposed investment asset mixes to help you meet your overall financial objectives. This would include reviewing risk/return issues and a suggested plan of action consistent with your risk tolerance and overall financial objectives;
•Calculating your pre-retirement savings and investing needs;
•Assessing your overall financial position including net worth, cash flow, and debt;
•Proving a comprehensive analysis of IRA-related issues including rollover, distribution, and inheritance planning options;
•Evaluating strategies designed to maximize the utilization and protection of your IRA assets;
•Estimating your federal estate taxes and suggesting a plan of action to help meet estate planning objectives;
•Reviewing and determining your life and disability insurance needs;
•Providing investment recommendations, both in terms of purchasing or selling holdings, that are geared towards minimizing tax consequences; and
•Developing investment strategies consistent with your business ownership succession and transition planning, if applicable.
Unless engaged separately to do so, GVA will not be responsible for the implementation of the plan. The client will assume full responsibility for the implementation of the plan. Retirement Plan Advisory and Consulting Services GVA IARs may assist clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee- based consulting and/or advisory services. IAR’s perform one or more of the following services, as selected by the client in the client agreement.
•Service Provider Liaison. IAR may assist the Plan by acting as a liaison between the Plan and service providers, product sponsors and/or vendors. In such cases, IAR shall act only in accordance with instructions from the Client on investment or Plan administration matters and shall not exercise judgment or discretion.

•Education Services to Plan Committee. IAR may provide education, training, and/or guidance for the members of the Plan Committee with regard to plan features, retirement readiness matters, or duties and responsibilities of the Committee, including education with respect to fiduciary responsibilities.

•Participant Enrollment. IAR may assist Client in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, IAR will provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre- retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan.

•Participant Education. IAR may assist with participant education, which may include preparation of education materials and/or conducting investment education seminars and meetings for Plan participants. Such meetings may be on a group or individual basis and may include information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine investment time horizons and assess risk tolerance. Such meeting shall not include specific investment advice about investment options under the Plan as being appropriate for a particular participant but may include use of educational investment models.

•Plan Search Support/Vendor Analysis. IAR may assist with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support.

•Benchmarking Services. IAR may provide Client with comparisons of Plan data (e.g., regarding fees, services, participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans.

•Assistance Identifying Plan Fees. IAR may assist client in identifying the fees and other costs borne by the Plan for, as specified by client, investment management, recordkeeping, participant education, participant communication and/or other services provided with respect to the Plan.

•Investment Policy Statement. IAR may assist the Plan in the preparation or review of an investment policy statement (“IPS”) for the Plan based upon consultation with Client.

•Ongoing Investment Recommendations. IAR may recommend, for consideration and selection by Client, specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan. IAR will recommend, for consideration and selection by Client, investment replacements if an existing investment is determined by the Client to no longer be suitable as an investment option.

•Ongoing Investment Monitoring. IAR will perform ongoing monitoring of investment options in relation to the criteria provided by the Client to the IAR.

•Qualified Default Investment Alternative Assistance. IAR may assist Client in identifying an investment product or model portfolio in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA (for Plans subject to ERISA excluding ERISA Plans where the IAR or GVA is classified as an “Investment Management” per Section 3(38) of ERISA).

•Non-Discretionary Model Portfolios. IAR will recommend, for consideration and approval by Client, (i) asset allocation target-date

or risk-based model portfolios for the Plan to make available to Plan participants, and (ii) funds from the line-up of investment options chosen by the Client to include in such model portfolios.

•Performance Reports. IAR will prepare periodic reports reviewing the performance of all Plan investment options, as well as comparing the performance thereof to benchmarks with Client. The information used to generate the reports will be derived directly from information such as statements provided by Client, investment providers and/or third parties.
We also provide clients investment advice on a more limited basis on one or more isolated areas of concern such as estate planning, real estate, retirement planning, or any other similar specific topic. Additionally, GVA may provide advice on non-securities matters in connection with the rendering of estate planning, insurance, real estate, maximizing social security benefits and/or annuity advice. SPECIFIC ADVISORY PROGRAMS The Registrant participates in advisory programs sponsored by broker-dealers that the Registrant uses as qualifying custodians. Specific details about each program are determined by the program sponsor and are subject to change. Clients should thoroughly review disclosure documents provided about the specific program they are participating in. The following is intended as a partial guide to the programs available. A. LPL Financial Sponsored Advisory Programs The Registrant may provide advisory services to clients through certain programs sponsored by LPL Financial, a registered investment advisor and broker dealer. Below is a brief description of each LPL Financial advisory program available through the Registrant. For more information regarding these programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the LPL Financial Part 2A Brochure or the applicable program’s Part 2A Brochure and the applicable client agreement. Because LPL has a financial interest in GVA, our recommendation to place you in an LPL-sponsored advisory program creates a conflict of interest in that we may be financially incentivized to use the LPS platform for your account. We seek to mitigate this conflict by our regular review of accounts to ensure clients are placed in a program that is best suited to their financial needs and analysis. GVA does not receive any additional form of compensation for recommending your account be held in the LPL sponsored advisory programs. i Optimum Market Portfolios Program (OMP) OMP is a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, client authorizes LPL Financial on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. The Registrant will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. The Registrant will have discretion to select a mutual fund asset allocation portfolio designed by LPL Financial consistent with the client’s investment objective. LPL Financial will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL Financial will also have authority to rebalance the account. LPL Financial sets a minimum account value for OMP and changing account balances and minimum requirements may affect whether this program is appropriate for a particular client and may affect the fee charged. ii. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL Financial. The Registrant will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. The Registrant will also have discretion for selecting third party money managers (PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL Financial will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds and equity and fixed income securities. LPL Financial sets a minimum account value for PWP and changing account balances and minimum requirements may affect whether this program is appropriate for a particular client and may affect the fee charged. iii. Model Wealth Portfolios Program (MWP) MWP is a professionally managed mutual fund asset allocation program. The Registrant will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Registrant will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL Financials’ Research Department consistent with the client’s stated investment objective. LPL Financials’ Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL Financial to act on a discretionary basis to purchase and sell mutual funds (including in certain circumstances exchange traded funds) and to liquidate previously purchased securities. The client will also authorize LPL Financial to effect rebalancing for MWP accounts. The MWP program also offers model portfolios designed by strategists other than LPL Financial’s Research Department. The Registrant can choose among the available models designed by LPL Financial and outside strategists. LPL Financial sets a minimum account value for MWP and changing account balances and minimum requirements may affect whether this program is appropriate for a particular client and may affect the fee charged. iv. Manager Access Select Program (MAS) MAS provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. The Registrant will assist client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL Financial. The Portfolio Manager manages client’s assets on a discretionary basis. The Registrant will provide initial and ongoing assistance regarding the Portfolio Manager selection process. LPL Financial and Portfolio Managers set minimum account values for MAS and changing account balances and minimum requirements may affect whether this program is appropriate for a particular client and may affect the fee charged. v. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although GVA will be available to discuss investment strategies, objectives, or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and GVA by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or GVA, do not enter into an advisory agreement with LPL, FutureAdvisor or GVA, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. FEES FOR LPL FINANCIAL ADVISORY PROGRAMS at LPL The account fee charged to the client for each LPL Financial advisory program is negotiable, and may be subject to maximum fees set by LPL Financial. Account fees are payable quarterly in advance. LPL Financial serves as program sponsor, investment advisor and broker dealer for the LPL Financial advisory programs. The Registrant and LPL Financial may share in the account fee and other fees associated with program accounts. The Registrant’s representatives may also be registered representatives of LPL Financial and may receive benefits from LPL Financial based in part on client participation in LPL Financial Advisory Programs. B. Fidelity Advisory Programs The registrant may also provide advisory services through Fidelity as the broker dealer custodian. Below is a brief description of each advisory program available at Fidelity. Fidelity Separate Account Network®(SAN) – Fidelity offers a Separate Account Network program (“SAN Program”), a unified platform for managed portfolios.
The SAN Program enables the Registrant and its representatives to build separately managed account portfolios from a vast network of managers to meet client needs which will be managed by designated SAN Managers on a discretionary basis. The minimum investment required by each individual SAN Manager must be met. Please refer to the SAN Manager’s Part 2A Brochure or comparable disclosure document provided to you by you’re the Registrant IAR. This is a wrap program, and the Registrant will deliver to client a copy of their Part 2A, Appendix 1.
Some managers under the SAN program may require an additional client advisory agreement with the client in addition to the agreement the client signs with the Registrant. For a complete description of the services offered, the programs, the fees charged and minimum account requirements, please refer to the separate disclosure brochure (such as Part 2A of Form ADV) maintained by the Money Manager as provided by your Financial Advisor. Clients should carefully review these additional disclosure brochures for important and specific details including, among other things, fees, experience, investment objectives and risk guidelines, and disclosure of the money manager’s potential conflicts of interest. The Registrant and Client together determine which program to engage. Clients will receive confirmations and statements reflecting all transactions in their account. However, in no circumstances shall the Registrant or its representative have the discretionary authority to close the account or withdraw funds or securities, with the exception of the Registrant’ advisory fees on a quarterly basis. Clients should refer to the Brochure, client agreement and other account paperwork for each investment program for more detailed information about the services available under the program. In addition, the Registrant may also refer advisory clients to other investment advisory programs not associated with any of the programs described above. The Registrant’s Chief Compliance Officer remains available to address any questions that a client or prospective may have regarding any conflict of interest associated with an investment advisory program. C. SEI Investments Management Corporation and it’s affiliates GVA (“we”/“our”) receives certain services and benefits from SEI Investments Management Corporation and its affiliates (“SEI”) to help conduct our advisory business through SEI’s Independent Advisor Solutions by SEI business unit (“IAS”). Investments we manage for our clients working with SEI are held in custodial accounts at SEI Private Trust Company (“SPTC”) pursuant to an agreement signed by each client with SPTC to receive custodial services. Accounts held at SPTC are supported through SEI’s proprietary platform known as the SEI Wealth Platforms, or the “Platform”. GVA uses the Platform and other technology provided by SEI or paid for by SEI to assist us in both the management of your assets and to support our business. D. Schwab Institutional Intelligent Portfolios The Registrant provides portfolio management services through Institutional Intelligent Portfolios™, an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Schwab IIP Program” and “SWIA,” respectively). Through the Schwab IIP Program, the Registrant offers clients a range of investment strategies the Registrant has constructed and manages, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash allocation. The client may instruct the Registrant to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at SWIA’s affiliate, Charles Schwab & Co., Inc. (“CS&Co”). The Registrant is independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, CS&Co or their affiliates (together, “Schwab”). The Schwab IIP Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios™ Disclosure Brochure (the “ Schwab IIP Program Disclosure Brochure”), which is delivered to clients by SWIA during the online enrollment process. The Registrant, and not Schwab, is the client’s investment advisor and primary point of contact with respect to the Schwab IIP Program. The Registrant is solely responsible, and Schwab is not responsible, for determining the appropriateness of the Schwab IIP Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. SWIA’s role is limited to delivering the Schwab IIP Program Disclosure Brochure to clients and administering the Schwab IIP Program so that it operates as described in the Schwab IIP Program Disclosure Brochure. The Registrant has contracted with SWIA to provide it with the technology platform and related trading and account management services for the Schwab IIP Program. This platform enables the Registrant to make the Schwab IIP Program available to clients online and includes a system that automates certain key parts of its investment process (the “Schwab System”). The Schwab System includes an online questionnaire that helps the Registrant determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that the Registrant will recommend a portfolio via the Schwab System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level more conservative or more aggressive than the recommended portfolio, but The Registrant then makes the final decision and selects a portfolio based on all the information The Registrant has about the client. The Schwab System also includes an automated investment engine through which The Registrant manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). The Registrant does not receive a portion of a wrap fee for its services to clients through the Schwab IIP Program. Clients do not pay fees to SWIA in connection with the Schwab IIP Program, but the Registrant charges clients a fee for its services as described below under Item 5. FEES AND COMPENSATION AT Charles Schwab & Co The Registrant’s fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part of the Schwab IIP Program. Schwab does receive other revenues in connection with the Schwab IIP Program, as described in the Schwab IIP Program Disclosure Brochure. The Registrant does not pay SWIA fees for its services in the Schwab IIP Program so long as the Registrant maintains $100 million in client assets in accounts at CS&Co that are not enrolled in the Schwab IIP Program. If the Registrant does not meet this condition, then the Registrant will be liable to pay SWIA an annual fee of 0.10% (10 basis points) on the value of the Registrant’s clients’ assets in the Schwab IIP Program. This fee arrangement gives the Registrant an incentive to recommend or require that the Registrant’s clients with accounts not enrolled in the Schwab IIP Program be maintained with CS&Co. E. Buckingham Strategic Partners GVA has contracted with Buckingham Strategic Partners, LLC, (“BSP”), for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. GVA has also contracted with BSP for certain sub-advisory services. In certain instances, GVA pays a fee for these BSP services based on management fees paid to GVA on accounts that use BSP services. The fee paid by GVA to BSP varies based on the total client assets administered and/or sub advised by BSP through GVA. These fees will not be separately charged to advisory clients are included within the advisory fees charged to clients. There may be other fees Advisor clients may pay to BSP directly under separate fee agreements. For investment management services, GVA will request authority from the client to delegate discretion to trade in the client’s account, and to receive quarterly payments directly from the client's account held by an independent custodian. Clients may provide written limited authorization to GVA or its designated service provider, BSP, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s). Certain third-party administrators will calculate and debit GVA’s fee and remit such fee to GVA. BSP may pay various forms of direct and indirect compensation to GVA or its representatives for reasonable business or educational purposes as described in BSP’s Form ADV Part 2A.” F. Pontera GVA uses Pontera as a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to affect trades without assuming custody of funds or assets, and specifically prohibits us from assuming such custody. GVA is not affiliated with the platform in any way and receives no compensation from Pontera for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is/are connected to the platform, Adviser will review the current account allocations. When deemed necessary, Advisor will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least annually and allocation changes will be made as deemed necessary. Assets Under Management As of December 31, 2022, GVA managed $7,343,187,108 in total regulatory assets under management, including a total of $5,762,238,125 in assets managed on a discretionary basis and an additional $1,580,948,983 in assets managed on a non-discretionary basis.