A. Firm Description GBM Wealth Management Inc. (“GBM Wealth” or “the Firm”) was formed as a Delaware Corporation on May 19, 2006 and is 100% owned by Portfolio Investments, Inc. The Firm is registered with the Securities Exchange Commission (“SEC”) effective Match 29, 2024. GBM Wealth and its affiliates, Illac Advisors, LLC and GBM International, are also under common indirect ownership with GBM Casa de Bolsa, a Mexican registered securities broker/dealer; ultimate beneficial owner for all is Corporativo GBM SAB de CV, a publicly traded company. B. Types of Advisory Services GBM Wealth provides investment advisory and consulting services to individuals, investment companies, trusts, estates, corporations and charitable organizations. Investment advice and portfolio management services are provided on a continuing basis which includes the appropriate allocation of managed assets among cash, stocks, mutual funds and bonds. This selection of specific securities will seek to provide proper diversification and help meet the client’s stated investment objectives. These services include discretionary management services. GBM Wealth maintains a Limited Power of Attorney for all discretionary accounts for the purposes of directing and or otherwise effecting investments on behalf of the managed account, for the direct payment of the Firm’s fees and/or the payment of commissions, custodial fees and or other charges incurred by the managed account. The Firm also maintains non-discretionary accounts. The Firm, may also oversee client accounts that contain private funds or private investments, purchased by the client separately and, based upon the respective advisory agreement, become subject to the Firm’s oversight. The relationship between the parties may be terminated by either party upon 30 days written notice. Notwithstanding the above, if the appropriate disclosure statement was not delivered to the client at least 48 hours prior to the client entering into any written or oral advisory contract with this investment adviser, then the client has the right to terminate the relationship without penalty, within five business days after entering into the contract. GBM Wealth's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Advisor Representatives (“Advisor Representatives”). Each advisory relationship at GBM Wealth is managed by one or more Advisor Representatives registered with the firm, who serve as the primary point of contact between GBM Wealth and the client. Advisor Representatives collect financial profile information from clients and recommend specific advisory services or programs to clients as deemed appropriate for their individual situation, financial circumstances, goals and objectives. GBM maintains a custodial arrangement with Pershing, LLC whereby GBM clears securities transactions on a fully disclosed basis via GBM International as an introducing broker. The Firm also maintains custodial arrangements with JP Morgan, Morgan Stanley and Interactive Brokers via BCP Global. The Firm maintains non-discretionary accounts at Pershing, JP Morgan and Morgan Stanley. Discretionary accounts are maintained at Pershing and Interactive Brokers via BCP Global. Accounts opened through BCP Global can be opened online by the client. GBM offers the following proprietary model portfolios for U.S. and non-U.S. residents: Liquidity – 100% bonds Fixed Income – 100% bonds Preservation – 80% bonds, 20% stocks Moderate – 60% bonds, 40% stocks Appreciation – 40% bonds, 60% stocks Growth – 20% bonds, 80% stocks Speculative – 100% stocks The models are comprised of ETF’s and/or UCIT’s which are each similar to a number of common equity and bond indices. Accounts in which a model portfolio is selected are established

utilizing Pershing as the custodian. Smaller accounts are established through BCP and custodied at Interactive Brokers. High net worth clients are established with either Pershing, Morgan Stanley or JP Morgan. Sub-Advisors and Selling Agreements The Firm maintains selling agreements with Blackstone REIT, Blackstone Private Credit Fund, and a Model Portfolio Agreement with Blackrock. The Firm has not utilized any of the agreements to date. The Firm maintains a sub-advisory agreement with BCP Global. GBM uses the services of BCP Global to sub-advise client accounts in relation to the portfolios offered and managed by GBM Wealth. BCP is also managing GBM’s proprietary model portfolios for the accounts in which it is selected. The Firm also offers investment advisory services utilizing the services of third-party Portfolio Managers (“Sub-Advisors”). Upon consultation with the Client and the Firm, these Sub-Advisors will place clients in a model strategy that they believe best fits the client’s investment objectives. These Sub-Advisors will use discretion in managing the investment within each model portfolio (i.e., select which securities to purchase or sell), but cannot change the model portfolio utilized for the client without the client’s specific written authorization. Should a client decide to utilize the services of a Sub-Adviser, the client agrees to use the custodian recommended by the Sub-Advisor. If the client utilizes the services of a Sub-Advisor, the client will receive a copy of the Sub- Advisor’s ADV Part 2A. Client Responsibilities GBM Wealth's advisory services depend and rely upon the information received from clients. The adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation. GBM Wealth will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify GBM Wealth in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. GBM Wealth reserves the right to terminate any client engagement where a client has willfully concealed or has refused to provide pertinent information about information material to the advisory services to be provided or individual/financial situations when necessary and appropriate; in its judgment, provide proper financial advice. C. Client Tailored Services and Client Imposed Restrictions GBM Wealth tailors its advisory services to each individual client based upon the client’s financial and risk profile. Clients may impose guidelines or restrictions on certain types of securities or investments but such restrictions must be provided in writing. In addition, the firm obtains an “Investment Advisory Mandate” for each client, which outlines the acceptable parameters for each type of investment in the respective client account(s). D. Wrap Fee Programs GBM Wealth does not sponsor or manage a wrap fee program. E. Amounts of Assets Under Management As of December 31, 2023, the Firm had assets under managements of approximately $128 million.