GR Financial Group, LLC (“GR Financial”) is a SEC-registered investment adviser with its principal place of business located in Tucson, AZ. GR Financial began conducting business in 2014. On January 1, 2023, certain corporate transactions occurred to allow for our management structure to undergo a strategic transition. After the transition, GR Financial’s Managing Member and Owner, Scott D. Genzman, transitioned to Senior Vice President and stepped down as President of the firm. Lynsey M. Richter now serves as the President. Listed below are the firm’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of GR Financial).
• Lynsey M. Richter, Managing Member, President/Owner
• Scott D. Genzman, Managing Member, Senior Vice President/Owner GR Financial Group, LLC offers the following advisory services to our clients:
• Individual Portfolio Management
• Financial Planning
• Complimentary Educational Seminars Individual Portfolio Management Investment management services are provided on a discretionary basis, which means the firm makes investment decisions and implements trades in clients’ accounts without first obtaining permission from clients. Our firm provides continuous discretionary advice to clients regarding the investment of their managed assets based on the individual needs of each client. During our initial meetings and data-gathering process, we determine the client’s individual goals and objectives, time horizons, risk tolerance, and liquidity needs, which is compiled and shared with the client. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. The firm provides continuous advice on a discretionary basis and from time-to-time offers complimentary educational seminars. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. In general, our investment recommendations and portfolios are largely built around various open-end mutual funds and exchange traded funds (“ETFs”); however, clients should be aware that we will also utilize multiple asset classes such as equities, fixed income, money market, and sector specific (such as but not limited to gold and energy ETFs), based on technical triggers of the marketplace and GR Financial’s rotation strategies. This can cause a client’s managed account(s) assets to shift heavily into one of these particular asset classes at any given time (including a money market fund) resulting in a more concentrated position. At times, it is possible for clients’ accounts to hold an all-cash position despite the style of management or risk objective (e.g., growth) of a client’s portfolio. Holdings in client accounts may also differ based on various fundamental and technical triggers and GR Financial’s analysis. Please refer to Item 8 for additional

information. Because some types of investments involve varying degrees of risk, they will only be implemented/recommended when consistent with a client's stated investment objectives, tolerance for risk, liquidity, and suitability. Prior to rendering Individual Portfolio Management services to a client, GR Financial and the client will enter into an investment advisory agreement. Please refer to Item 5 below for information on agreement termination. Financial Planning We provide a complimentary general financial plan based upon an analysis of the individual client’s needs. Our firm’s financial planning analysis is designed to provide clients with a summary of their financial needs and an analysis of steps they may wish to consider within their investment portfolio and financial situation in order to help achieve specified financial goals and objectives. We begin this process by reviewing a client’s current, and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients receive a report which provides the client with a financial plan designed to assist in achieving their financial goals and objectives. Generally, our financial planning process addresses some or all of the following areas, depending on client needs:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, and liability.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review cash needs at death, income needs of surviving dependents, estate planning, and disability income. The client has full discretion to accept or reject our firm’s recommendations outlined in the client’s financial plan. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with their attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. GR Financial will not be held responsible for the clients’ implementation of advice through third parties (such as attorneys, accountants, and/or insurance agents), or advice received from third parties in connection with a financial plan. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Amount of Managed Assets GR Financial Group, LLC actively manages as of December 31, 2023, $ 814,799,726 of clients’ assets on a discretionary basis.