GRANITE FINANCIAL GROUP, LLC

W R A P F E E P R O G R A M B R O C H U R E ( P A R T 2 A A P P E N D I X O F F O R M A D V ) Office Address: 175 N. Patrick Blvd. Suite 170 Brookfield, WI 53045 Tel: 262-792-1111 Fax: 262-792-1110 Website: tom@granitefgllc.com www.GraniteFGLLC.com MARCH 19, 2025 This wrap brochure provides information about the qualifications and business practices of Granite Financial Group, LLC. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 262-792-1111. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Granite Financial Group, LLC (CRD #168675) is available on the SEC’s website at www.adviserinfo.sec.gov i  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material Material Changes since the Last Update changes occur since the previous release of the Firm Brochure. This update is in accordance with the required annual update for Registered Investment Advisors. Since the last filing of this brochure on February 12, 2024, there have been no material changes. ii  Item 3: Table of Contents Form ADV – Part 2A Appendix 1 – Firm Brochure Item 1: Cover Page Item 2: Material Changes ...................................................................................................................... ii Annual Update ................................................................................................................................................ ii Item 3: Table of Contents ..................................................................................................................... 1 Material Changes since the Last Update ............................................................................................... ii Item 4: Services, Fees and Compensation ...................................................................................... 3 Firm Description ............................................................................................................................................ 3 Program Services ........................................................................................................................................... 3 Item 5: Account Requirements and Types of Clients.................................................................. 5 Program Fees .................................................................................................................................................. 4 Account Minimum ......................................................................................................................................... 5 Item 6: Portfolio Manager Selection and Evaluation .................................................................. 5 Types of Clients .............................................................................................................................................. 5 Portfolio Manager .......................................................................................................................................... 5 Conflicts of Interest ....................................................................................................................................... 5 Advisory Business ......................................................................................................................................... 6 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest 6 Sharing of Capital Gains .............................................................................................................................. 7 Client Tailored Services and Client Imposed Restrictions ............................................................. 7 Methods of Analysis ...................................................................................................................................... 7 General Investment Strategy ..................................................................................................................... 7 Security Specific Material Risks ............................................................................................................. 10 Item 7: Client Information Provided to Portfolio Managers.................................................. 13 Proxy Voting .................................................................................................................................................. 12 Item 8: Client Contact with Portfolio Managers ......................................................................... 13 Description ..................................................................................................................................................... 13 Item 9: Additional Information ........................................................................................................ 13 Restrictions .................................................................................................................................................... 13 Disciplinary Information .......................................................................................................................... 13 Criminal or Civil Actions ........................................................................................................................... 13 Administrative Enforcement Proceedings ......................................................................................... 14 1  Self-Regulatory Organization Enforcement Proceedings ............................................................ 14 Other Financial Industry Activities and Affiliations ....................................................................... 14 Broker-Dealer or Representative Registration ................................................................................ 14 Futures or Commodity Registration .................................................................................................... 14 Material Relationships Maintained by this Advisory Business and Conflicts of Interest 14 Code of Ethics Description ....................................................................................................................... 14 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest ............................................................................................................................................................ 15 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ............................................................................................................................................................ 15 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest ................................................................................................. 15 Review of Accounts ..................................................................................................................................... 15 Schedule for Periodic Review of Client Accounts and Advisory Persons Involved ........... 15 Review of Client Accounts on Non-Periodic Basis .......................................................................... 15 Content of Client Provided Reports and Frequency ....................................................................... 16 Client Referrals and Other Compensation ......................................................................................... 16 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................ 16 Advisory Firm Payments for Client Referrals ................................................................................... 16 Financial Information ................................................................................................................................ 16 Balance Sheet ................................................................................................................................................ 16 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................ 16 Bankruptcy Petitions during the Past Ten Years ............................................................................ 16 2  Item 4: Services, Fees and Compensation Firm Description Granite Financial Group, LLC dba Granite Financial Group (“GFG”) is an investment advisor registered with the Securities Exchange Commission (SEC). GFG offers investment advice to Clients through the Wrap Fee Program (“Program”) based on the individual needs of the Client. GFG is the sponsor of the Program. The firm is owned by Thomas J. Dornoff – 100%. GFG is responsible for management of the Program accounts. This disclosure brochure is limited to describing the Program and other information that Client should consider prior to establishing an account in the Program. For a complete description of other programs and services offered by GFG, Clients should refer to GFG’s Form Program Services ADV Part 2A, a copy of which will be provided by GFG to the Client upon request. GFG provides continuous and regular supervisory services on a discretionary basis. GFG will offer Clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, assets allocation, portfolio monitoring and the overall investment Discretionary: program will be based on the above factors. When the Client provides GFG Financial discretionary authority the Client will sign a limited trading authorization or equivalent. GFG Financial will have the authority to execute transactions in the account without seeking Client approval on each transaction. Through a multiple step discovery process, GFG obtains the necessary financial data from the Client and assists the Client in setting appropriate investment objectives for the Program account. GFG obtains updated information from the Client during regularly scheduled Client performance reviews, as necessary in order to provide personalized investment advice to the Client. The Client will be required to enter into a written agreement with GFG in order to establish a Program account. The Client will also be required to complete an application with the broker/dealer that will act as custodian for Program account assets. A Wrap Fee Program is an investment advisory program in which Clients pay one fee for both investment advisory services and the transaction costs in the account(s). The fee is bundled with GFG’ costs for executing transactions in the account(s). This may result in a higher advisory fee to the Client. GFG does not charge Clients higher advisory fees based on the trading activity, but Clients should be aware that GFG may have an incentive to limit the trading activities in the account(s) because GFG is charged for executed trades. By participating in a wrap fee program, Clients may end up paying more or less than they would through a non-wrap fee program where a lower advisory fee may be charged, but trade execution costs are passed directly through to the Client by the executing broker. The Program Fee is not based directly upon the actual transaction or execution costs for the transactions within the account(s). Depending on the underlying investments in the Program and how much trading activity occurs, Clients may pay more or less than if they chose another advisory program that does not have a wrap fee, or if Clients chose to pay separately for all of the transaction costs (e.g., pay the advisory fee plus all transaction charges). GFG offers both a Wrap Fee Program and a Non-Wrap Fee Program, therefore GFG will review your 3 investment options with Clients to determine the best offering for Clients. Similar services to  those offered in the Program may be purchased from another unaffiliated financial services Program Fees provider. The annual investment advisory fee (“Annual Fee”) schedule for the Program is described ETF Portfolios, ESG Portfolios, Active Management Portfolio Strategy (AMPS), Managed below: Dividend, & Multi Strategy * Assets Under Management $0 - $500,000 The next $500,001 - $1, 000,000 The next $1,000,001 - $2,500,000 The next $2,500,001 - $5,000,000 Amounts over $5,000,000 Annual Fee 1.00% 0.85% 0.55% 0.45% 0.35% Quarterly Fee 0.2500% 0.2125% 0.1375% 0.1125% 0.0875% *When multiple strategies are used. These are blended fee schedules, the asset management fee is calculated by applying different rates to different portions of the portfolio. GFG may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example, a Client with $1,000,000 under management in an ETF Portfolio would pay $9,250 on an annual basis. First $500,000 x .01= $5,000 Next $500,000 x .0085= $4,250 The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30) days written notice. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to GFG. Additionally, all unearned fees will be refunded to the Client. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Lower fees for comparable services may be available from other sources. In addition to the Annual Fee, Clients may also incur certain charges imposed by third parties in connection with investments made through Program accounts, including those imposed by the custodian. These may include, but are not limited to, the following: mutual fund or money market 12b-1 fees, sub-transfer agent fees, certain deferred sales charges on previously purchased mutual funds transferred into the account, other transaction charges and service fees, IRA and qualified retirement plan fees, alternative investment administrative fees, 4  administrative servicing fees for trust accounts, creation and development fees or similar fees imposed by unit investment trust sponsors, managed futures investor servicing fees, and other charges required by law. GFG does not receive any portion of these fees. Further information regarding charges and fees assessed by a mutual fund or variable annuity are available in the appropriate prospectus. Mutual funds may also charge a redemption fee if a redemption is made within a specific time period following the investment. The terms of any redemption fee are disclosed in the fund’s prospectus. Transactions in mutual fund shares (e.g., for rebalancing, liquidations, deposits or tax harvesting) may be subject to a fund’s frequent trading policy. Since GFG will receive 100% of the fees paid for management of the wrap program, this may create an incentive to recommend that Clients participate in a wrap fee program rather than a non-wrap fee program (where Clients would pay for trade execution costs) or brokerage account where commissions are charged. This is because, in some cases, GFG may stand to earn more compensation from advisory fees paid through a wrap fee program arrangement if Clients’ accounts are not actively traded. As an investment philosophy, GFG practices a nimble trading strategy that seeks to grow Client assets in up trends and protect principal during down trends. Item 5: Account Requirements and Types of Clients Account Minimum GFG requires a minimum of $25,000 to open a Managed ETF Portfolio account and $100,000 to open a Managed Dividend Portfolio account. In certain instances, the minimum account Types of Clients size may be lowered or waived. GFG generally provides investment advice to individuals, high net worth individuals, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Item 6: Portfolio Manager Selection and Evaluation Portfolio Manager Thomas Dornoff will manage all Program accounts. Since no other persons, affiliated or unaffiliated will manage the wrap program, there are no additional processes for selection or review of managers. Clients make the decision to select GFG as their portfolio manager. Since all programs are managed by Thomas Dornoff, there is no conflict of interest regarding Conflicts of Interest portfolio managers. The Program may cost the Client more or less than purchasing Program services separately. Factors that bear upon the cost of the Program account in relation to the cost of the same services purchased separately include: the type and size of the account, the historical and/or expected size or number of trades for the account, and the number and range of supplementary advisory and Client related services provided to the account. 5  The Annual Fee is an ongoing fee for investment advisory services and may cost the Client more than if the assets were held in a traditional brokerage account. In a brokerage account, a Client is charged a commission for each transaction and the representative has no duty to provide ongoing advice with respect to the account. If the Client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the Client should consider opening a brokerage account rather than a Program account. GFG receives compensation as a result of the Client’s participation in the Program. The amount of this compensation may be more or less than what GFG would receive if the Client participated in other programs or paid separately for investment advice, brokerage and other Client services. Therefore, GFG may have a financial incentive to recommend the Program account over other programs and services. GFG acts as the portfolio manager for the Program and retains the management fee less execution costs. This may create a conflict of interest because GFG may have a disincentive to trade securities in the account to keep the execution Advisory Business costs low therefore retaining a larger portion of the management fee. GFG offers Clients an asset management account through the Program in which GFG directs and manages Program assets for Client. Client provided goals and objectives are documented in individual Client files. Investment strategies are created that reflect the stated goals and objective. A Client may impose restrictions on a minimum level of cash they want in their account, as well as from which account they want their withdrawals to come. Also, a Client may issue restrictions on what specific securities or security types they do not want GFG to buy or sell Recommendations or Selections of Other Investment Advisors and Conflicts of in their account. Interest GFG does not select or recommend other investment advisors. 6  Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. GFG does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for GFG to recommend an Client Tailored Services and Client Imposed Restrictions investment that may carry a higher degree of risk to the Client. The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Methods of Analysis Agreements may not be assigned without written Client consent. Security analysis methods may include fundamental analysis, technical analysis, charting, and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. The main sources of information include financial newspapers and magazines, annual General Investment Strategy reports, prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time. Each Client executes an Investment Policy Statement, Risk Tolerance or similar form that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases, short-term purchases, and trading. 7  Managed ETF Portfolios GFG Portfolios include the following options: By combining an objective portfolio construction discipline with a sophisticated risk management process, GFG selects each investment product specifically to balance the risk and the return profiles of Exchange Traded Funds (ETFs) in the model portfolios. The ETFs chosen are reviewed on an ongoing basis to ensure that they continue to meet our rigorous research and evaluation standards and to confirm that they remain appropriate for the portfolio. The firm has established tactical asset allocation models with global perspectives ranging from conservative to aggressive. Portfolio construction of these models is a six (6) step • process: • Investment option research – All ETFs must be researched by Morningstar and approved by LPL Financial for use in client accounts. • Identify “Best Fit” Managers – GFG seeks to combine core asset class investment options with complimentary satellite asset class ETF options. • Tactical Manager Evaluation – ETF style characteristics are evaluated in context of current investment trends. • Evaluate Individual Investment and Portfolio Risk – Evaluate ETF risk characteristics independently and when combined together in a single portfolio. • Evaluate Portfolio for “Unintended Consequences” – review portfolio for unintended risks that come up when combining multiple ETFs. Ongoing Manager and Portfolio Evaluation – Portfolio construction and risk evaluation are continually monitored. Determining asset allocation model and choosing complimentary investment products across a range of product types with varying fees, risk-return profiles, investment disciplines and holdings can be a complex process. To help investors navigate these issues, GFG leverages LPL Financial’s intellectual capital in asset allocation advice, investment advisor research and portfolio construction to deliver a discretionary suite of model portfolios for the Client’s convenience. Active Management Portfolio Strategy (AMPS) The minimum account size for the Managed ETF Portfolios is $25,000. GFG’s investment management philosophy is to build and manage portfolios with a focus on risk management and competitive performance. GFG has established four (4) asset allocation models. The models can be used as a complete program or added to an existing portfolio. All models are managed with a long term strategy that adjusts for short term tactical opportunities. We believe this approach will provide better overall results. The management of these models is separated into several components. The first two, asset allocation and position weighting, are determined by several investment committees. Each position in the model carries a recommended weighting and may be adjusted or liquidated at any time. As the share prices of individual mutual funds fluctuate, weightings within the portfolio will naturally change. GFG trims or adds to the position preserving portfolio balance and maintaining diversification. These two components are reviewed monthly. 8  • GFG’s fund selection, which is the third component of the process, begins with the screening of more than 5000 mutual funds that have met prior stringent LPL Financial standards. GFG reviews all funds in the category or sector using GFG’s initial criteria: • Fit in a specific asset class according to Morningstar • Five (5) years of performance history* • A positive three (3) year Alpha rating Performed in the top 40% of peer group on a three (3) & five (5) year basis according to Morningstar *Specialty funds only need three (3) years of performance history Once the fund choices have been filtered additional judgments are made using, but not limited to: Beta R squared ration Duration Manager Tenure Correlation Credit quality Capture ratio Alpha Sharpe ratio As part of GFG’s fiduciary responsibility GFG monitors all holdings daily. A fund may be replaced at any time, and must be replaced if it fails to meet GFG’s initial criteria for two (2) consecutive quarters. This evaluation is performed on a quarterly basis and completes GFG’s process. Managed ESG Portfolio The portfolio is managed the same as AMPS with the additional overlay of environmental, Managed Dividend Portfolio social and governance. The Managed Dividend Portfolio was established for conservative equity investors with a relatively low tolerance for risk. The portfolio is composed of high-quality, dividend paying stocks which over time provide investors a higher total return with lower risk than the S&P 500. The portfolio consists of 17 to 20 equities with a maximum initial weighting of 5% per position. GFG attempts to further diversify the portfolio by purchasing equities in nine (9) sectors to reflect the current weighting of the S&P 500. GFG also diversifies within each sector by holding more than one equity in each of six (6) sectors. Each month GFG reviews the portfolio weightings and diversification and rebalances as necessary. • When selecting securities for GFG’s portfolios, GFG starts with three (3) primary “hard and fast” criteria: • Overweight and Equal-weight rated stocks by Credit Suisse • Minimum dividend yield equal to the lesser of the S&P 500 Index average dividend or the stock’s average Sector yield S&P Investment grade credit rating of “A” or better for the portfolio, with a maximum of 10% of the portfolio below investment grade 9  • • Other key metrics considered: • • Dividend history ROE performance • • Ability to grow the dividend EPS growth Free cash flow Leverage The equities in this portfolio may be replaced at any time. If a stock underperforms its benchmark by 25% or more on a Beta-adjusted basis, we will conduct a special review. Security Specific Material Risks The minimum account size for the Managed Dividend Portfolios is $100,000. • Market Risk All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with GFG: • : The prices of securities held by mutual funds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to Interest-rate Risk tolerate potentially sharp declines in market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less Inflation Risk attractive, causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than • Currency Risk a dollar next year, because purchasing power is eroding at the rate of inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. 10 Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small and mid- cap companies are subject to additional risks. Smaller companies may experience  • Fixed Income Risk: greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal Investment Companies Risk: interest rate is the sum of a real interest rate and an expected inflation rate. • Foreign Securities Risk: When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Long-term purchases Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Short-term purchases : Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. 11 : Short-term investments are typically held for one year or less. Generally there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be  • Trading risk subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. : Investing involves risk, including possible loss of principal. There is no Proxy Voting assurance that the investment objective of any fund or investment will be achieved. Granite Financial Group, LLC dba Granite Financial Group (“GFG”) will vote proxies on behalf of a client if, in its investment advisory agreement (“IAA”) with GFG, the client has delegated to GFG the authority to vote proxies on its behalf. GFG has adopted and implemented these policies and procedures (“Proxy Voting Procedures”) to ensure that, where it has voting authority, proxy matters are handled in the best interest of clients, in accordance with GFG’s fiduciary duties and SEC rule 206(4)-6 under the Investment Advisers Act of 1940. In addition to SEC requirements governing advisers, its Proxy Voting Procedures reflect the long- standing fiduciary standards and responsibilities for ERISA accounts set out in Department of Labor Bulletin 94-2, 29 C.F.R. 2509.94-2 (July 29, 1994). GFG utilizes the services of a third party Proxy Voting Service to administer the vote on proxies for those accounts for which GFG has voting authority. The Proxy Voting Service has a copy of GFG’s Proxy Voting Guidelines and votes on each proxy based on GFG’s Proxy Voting Guidelines. GFG generally follows its Proxy Voting Guidelines unless GFG determines that the client’s best interests are served by voting otherwise. The following policies will apply when voting proxies on behalf of accounts for which GFG has voting authority. Client’s Best Interest. GFG’s Proxy Voting Procedures are designed and implemented in a way that is reasonably expected to ensure that proxy matters are conducted in the best interest of clients. When considering the best interest of clients, GFG has determined that this means the best investment interest of its clients as shareholders of the issuer. GFG has established its Procedures to assist it in making its proxy voting decisions with a view to enhancing the value of its clients’ interests in an issuer over the period during which it expects its clients to hold their investments. GFG will vote against proposals that it believes could adversely impact the current or potential market value of the issuer’s securities during the expected holding period. Client Proxy Voting Policies. Rather than delegating proxy voting authority to GFG, a client may (1) retain the authority to vote proxies on securities in its account, (2) delegate voting authority to another party or (3) instruct GFG to vote proxies according to a policy that differs from that of GFG. GFG will honor any of these instructions if the client includes the instruction in writing in its IAA or in a written instruction from a person authorized under the IAA to give such instructions. If GFG incurs additional costs or expenses in following any such instruction, GFG may request payment of such additional costs or expenses from the client. Stated Policies. These policies identify issues where GFG will (1) generally vote in favor of a proposal – FOR; (2) generally vote against a proposal – AGAINST; (3) specifically consider its vote for or against a proposal – Case By Case (CBC). However, these policies are guidelines and each vote may be cast differently than the stated policy, taking into consideration all relevant facts and circumstances at the time of the vote. Abstain from Voting. Our policy is to vote on issues and not to abstain from voting on issues 12 presented unless the client’s best interest requires abstention. This may occur from time to  time, for example, where the impact of the expected costs involved in voting exceeds the expected benefits of the vote such as where foreign corporations follow share blocking practices or where proxy material is not available in English. Oversight. All issues presented for shareholder vote will be considered under the oversight of GFG’s Proxy Voting Designee. All non-routine issues will be directly considered by the Proxy Voting Designee and, when necessary, the equity analyst following the company and/or the portfolio manager of an account holding the security, and will be voted in the best investment interests of the client. All routine for and against issues will be voted according to GFG’s policy approved by GFG’s Proxy Voting Designee unless special factors require that they be considered by GFG’s CCO and, when necessary, the equity analyst following the company and/or the portfolio manager of an account holding the security. GFG’s Proxy Voting Designee has established these routine policies in what it believes are the client’s best interests. Availability of Procedures. Upon request, GFG provides clients with a copy of its Proxy Voting Guidelines, as updated from time to time. Disclosure of Vote. Upon request, a client can obtain information from GFG on how its proxies were voted. Any client interested in obtaining this information can request a copy from their GFG representative. GFG has established several policies to ensure that proxy votes are voted in its clients’ best interest and are not affected by any conflicts of interest. All conflicts are mitigated by the fact that GFG has a fiduciary responsibility to act in the best interest of its clients. Clients are not required to authorize GFG to vote proxies on their behalf. Item 7: Client Information Provided to Portfolio Managers Description GFG obtains the necessary financial data from the Client and assists the Client in setting appropriate investment objectives for the Program account. GFG obtains updated information from the Client as necessary in order to provide personalized investment advice to the Client. It is the Client’s responsibility to inform GFG of any changes in their stated objectives, financial situation, life circumstances or risk tolerance. Client will be required to enter into a written agreement with GFG in order to establish a Program account. Client will also be required to complete an application with the broker/dealer that will act as custodian for Program account assets. Item 8: Client Contact with Portfolio Managers Restrictions There are no restrictions placed on Clients’ ability to contact and consult with the portfolio manager. Thomas Dornoff is the portfolio managers. Item 9: Additional Information Disciplinary Information 13 Criminal or Civil Actions GFG and its management have not been involved in any criminal or civil action.  Administrative Enforcement Proceedings GFG and its management have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings GFG and its management have not been involved in legal or disciplinary events related to Other Financial Industry Activities and Affiliations past or present investment Clients. Broker-Dealer or Representative Registration GFG is not registered as a broker-dealer, however Mr. Dornoff is a registered representative of LPL Financial, a FINRA/SIPC broker-dealer. Futures or Commodity Registration GFG does not have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Mr. Dornoff has a financial affiliated business as both a registered representative and insurance agent with LPL Financial. Approximately 15% of his time is spent on these activities. He will offer Clients services from those activities. As a registered representative and/or insurance agent, he may receive separate yet typical compensation. These practices represent conflicts of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another registered representative or insurance agent of their Code of Ethics Description choosing. The employees of GFG have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of GFG employees and addresses conflicts that may arise. The Code defines acceptable behavior for employees of GFG. The Code reflects GFG and its supervised persons’ responsibility to act in the best interest of their Client. One area the Code addresses is when employees buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. GFG’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of GFG may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. GFG’s Code is based on the guiding principle that the interests of the Client are our top priority. GFG’s officers, directors, advisors, and other employees have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either employees or the company. 14  The Code applies to “access” persons. “Access” persons are employees who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. Investment Recommendations Involving a Material Financial Interest and Conflict of GFG will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Interest GFG and its employees do not recommend to Clients securities in which we have a material Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of financial interest. Interest GFG and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide GFG with copies of their brokerage statements. The Chief Compliance Officer of GFG is Thomas J. Dornoff. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive Client Securities Recommendations or Trades and Concurrent Advisory Firm preferential treatment over associated persons’ transactions. Securities Transactions and Conflicts of Interest GFG does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide GFG with copies of their brokerage statements. The Chief Compliance Officer of GFG is Thomas J. Dornoff. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive Review of Accounts preferential treatment over associated persons’ transactions. Schedule for Periodic Review of Client Accounts and Advisory Persons Involved Account reviews are performed at least quarterly depending on the nature of the account and Client relationship. All reviews are conducted by Thomas Dornoff. Account reviews are performed more frequently when market conditions dictate. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. 15  Content of Client Provided Reports and Frequency Clients receive written account statements usually on a monthly basis, but no less than quarterly for managed accounts. GFG through LPL Financial will also provide Clients with Client Referrals and Other Compensation quarterly performance reports. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Mr. Dornoff receive external compensation for the sale of securities to Clients as a registered representatives of LPL Financial, a broker-dealer. Advisory Firm Payments for Client Referrals Financial Information GFG does not compensate for Client referrals. Balance Sheet A balance sheet is not required to be provided because GFG does not serve as a custodian for Client funds or securities and GFG does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients GFG has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years GFG has not had any bankruptcy petitions in the last ten years. 16 

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Office Address: 175 N. Patrick Blvd. Suite 170 Brookfield, WI 53045 Tel: 262-792-1111 Fax: 262-792-1110 Email: Website: tom@granitefgllc.com www.GraniteFGLLC.com M A R C H 1 9 , 2 0 2 5 This brochure provides information about the qualifications and business practices of Granite Financial Group, LLC. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 262-792-1111. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Granite Financial Group, LLC (CRD #168675) is available on the SEC’s website at www.adviserinfo.sec.gov  Item 2: Material Changes Annual Update Material Changes since the Last Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. • This update is in accordance with the required annual update for Registered Investment Advisors. Since the last filing of this brochure on February 12, 2024, the following material changes have been made: • Item 4 has been updated to reflect a current assets under management calculation. Full Brochure Available Item 5 has had an update to the fee schedule. This Firm Brochure being delivered is the complete brochure for the Firm.  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available .................................................................................................................................................. ii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 4 Wrap Fee Programs ......................................................................................................................................................... 4 Item 5: Fees and Compensation ....................................................................................................... 4 Client Assets under Management .............................................................................................................................. 4 Method of Compensation and Fee Schedule .......................................................................................................... 4 Client Payment of Fees ................................................................................................................................................... 6 Additional Client Fees Charged ................................................................................................................................... 6 Prepayment of Client Fees ............................................................................................................................................ 6 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 7 External Compensation for the Sale of Securities to Clients ........................................................................... 7 Item 7: Types of Clients ....................................................................................................................... 7 Sharing of Capital Gains ................................................................................................................................................. 7 Description .......................................................................................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7 Account Minimums .......................................................................................................................................................... 7 Methods of Analysis ......................................................................................................................................................... 7 Investment Strategy ........................................................................................................................................................ 8 Item 9: Disciplinary Information ................................................................................................... 10 Security Specific Material Risks .................................................................................................................................. 8 Criminal or Civil Actions ............................................................................................................................................. 10 Administrative Enforcement Proceedings .......................................................................................................... 10 Self- Regulatory Organization Enforcement Proceedings ............................................................................ 10  Item 10: Other Financial Industry Activities and Affiliations ............................................. 11 Broker-Dealer or Representative Registration ................................................................................................. 11 Futures or Commodity Registration ...................................................................................................................... 11 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 11 Trading ................................................................................................................................................... 11 Code of Ethics Description ......................................................................................................................................... 11 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 12 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 12 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ......................................................................................................... 13 Transactions and Conflicts of Interest .................................................................................................................. 12 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 13 Item 13: Review of Accounts ........................................................................................................... 13 Aggregating Securities Transactions for Client Accounts ............................................................................. 13 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 13 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 14 Item 14: Client Referrals and Other Compensation ................................................................ 14 Content of Client Provided Reports and Frequency ........................................................................................ 14 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 14 Item 15: Custody .................................................................................................................................. 14 Advisory Firm Payments for Client Referrals .................................................................................................... 14 Item 16: Investment Discretion ..................................................................................................... 15 Account Statements ...................................................................................................................................................... 14 Item 17: Voting Client Securities ................................................................................................... 15 Discretionary Authority for Trading...................................................................................................................... 15 Item 18: Financial Information ...................................................................................................... 17 Proxy Votes ...................................................................................................................................................................... 15 Balance Sheet .................................................................................................................................................................. 17 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 17 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 17  Item 4: Advisory Business Firm Description Types of Advisory Services Granite Financial Group, LLC dba Granite Financial Group (“GFG”) was founded in 2013. The firm is owned by Thomas J. Dornoff – 100%. ASSET MANAGEMENT GFG offers discretionary asset management services to advisory Clients on the following platforms as described below and in Item 5. GFG will offer Clients ongoing asset management services after determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize GFG discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. GFG also offers discretionary asset management services through the Granite Financial Group Wrap Program. For more information on this program please see Appendix 1 of this brochure. LPL Platform GFG offers advisory services through certain programs sponsored by LPL Financial (LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory program available to GFG. For more information regarding the LPL 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 program documents. GFG receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the size of the account, changes in its value over time, the ability to negotiate fees or commissions, and the number of transactions, the amount of this compensation may be more or less than what GFG would receive if the client participated in other programs, whether through LPL or another sponsor, or paid Optimum Market Portfolios Program (OMP) separately for investment advice, brokerage and other services. OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, the client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. GFG will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. GFG will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. - 1 -  Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. GFG will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. GFG will also have discretion for selecting third party money managers (PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL 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 Model Wealth Portfolios Program (MWP) fixed income securities. MWP offers clients a professionally managed mutual fund asset allocation program. GFG 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. GFG will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s 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 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 to effect rebalancing for MWP accounts. MWP makes available model portfolios designed by strategists other than LPL’s Research Department. As a result, GFG will have discretion to Manager Access Select Program (MAS) choose among the available models designed by LPL and outside strategists. MAS provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. We 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. We will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. ERISA PLAN SERVICES GFG provides service to qualified retirement plans including 401(k) plans, 403(b) plans, Limited Scope ERISA 3(21) Fiduciary. pension and profit-sharing plans, cash balance plans, and deferred compensation plans. GFG may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor GFG has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using GFG can help the plan sponsor delegate liability by following a diligent process. 1. • Fiduciary Services are: Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, - 2 -  • retention, removal and addition of investment options. GFG acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. • Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. • Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. • Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands GFG’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, GFG is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. GFG may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. 3. GFG has no responsibility to provide services related to the following types of assets • (“Excluded Assets”): • • • • • • Employer securities; Real estate (except for real estate funds or publicly traded REITs); Stock brokerage accounts or mutual fund windows; Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or Other hard-to-value or illiquid securities or property. - 3 -  not Excluded Assets will be included in calculation of Fees paid to GFG on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Client Tailored Services and Client Imposed Restrictions FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, a thorough review of all applicable topics including but not limited to, Wills, Estate Plans and Trusts, Investments, Taxes, Qualified Plans, Insurance, Retirement Income, Social Security, Legacy Planning and College Planning will be reviewed. If a conflict of interest exists between the interests of GFG and the interests of the Client, the Client is under no obligation to act upon GFG’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through GFG. Financial plans will be completed and delivered inside of sixty (60) days contingent upon timely delivery of all required documentation. The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Wrap Fee Programs Agreements may not be assigned without written Client consent. Client Assets under Management GFG sponsors the Granite Financial Group Wrap Fee Program. For more information on this program please see Appendix 1 of this brochure. GFG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $170,600,000 $0 Date Calculated: December 31, 2024 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT GFG offers discretionary direct asset management services to advisory Clients on the following platforms as described below. GFG also offers discretionary asset management services through the Granite Financial Group Wrap Program. For more information on this program please see Appendix 1 of this brochure. Optimum Market Portfolios Program, Personal Wealth Portfolios Program, Model Wealth LPL Platform Portfolios Program (MWP), and Manager Asset Select Program (MAS). Assets Under Management $0 - $500,000 The next $500,001 - $1, 000,000 The next $1,000,001 - $2,500,000 The next $2,500,001 - $5,000,000 Amounts over $5,000,000 Annual Fee 1.00% 0.85% 0.55% 0.45% 0.35% Quarterly Fee 0.25% 0.2125% 0.1375% 0.1125% 0.0875% - 4 -  These are blended fee schedules; the asset management fee is calculated by applying different rates to different portions of the portfolio. GFG may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example, a Client with $1,000,000 under management in Manager Asset Select Program would pay $9,250 on an annual basis. First $500,000 x .010= $5,000 Next $500,000 x .0085= $4,250 The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account on the last day of the previous quarter. Management fees will be deducted from the client’s managed account, upon a signed Account Application Form. The ultimate management fee is indicated on the Account Application Form. LPL serves as program sponsor, investment adviser and broker-dealer for the LPL advisory programs. Our firm and LPL may share in the account fee and other fees associated with program accounts. Our firm does not have the authority to instruct LPL Financial to change or deduct fees without written client consent. As a part of your regular monthly statement from LPL Financial the Activity Summary section shows all fees deducted from the clients’ accounts. ERISA PLAN SERVICES The annual fees are based on the market value of the Included Assets and will not exceed .75%. The annual fee is negotiable and is charged as a percentage of the Included Assets. Fees may be charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any time other than the first day of a quarter or month, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, GFG shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the billing cycle. The fee schedule, which includes compensation to GFG for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor may elect to pay the fees. Client will have fees deducted from Plan Assets. GFG does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, GFG will disclose this compensation, the services rendered, and the payer of compensation. GFG will offset the compensation against the fees agreed upon under the Agreement. - 5 -  FINANCIAL PLANNING AND CONSULTING GFG charges either an hourly fee or fixed fee for financial planning. Prior to the planning process the Client will be provided an estimated plan fee. Services are completed and delivered inside of sixty (60) days contingent upon timely delivery of all required documentation. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GFG. GFG reserves the right to waive the fee should the Client implement the plan through GFG. HOURLY FEES Financial Planning Services are offered based on an hourly fee of $350 per hour. FIXED FEES Financial Planning Services are offered based on a flat fee between $1,500 and $10,000. Fees for financial plans are: Client Payment of Fees Due upon delivery of the completed plan. Investment management fees are billed quarterly in advance, depending on the platform used, meaning that fees are charged to your account either before or after the billing period. Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans are: Due upon delivery of the completed plan. Additional Client Fees Charged GFG, in its sole discretion, charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling and miscellaneous fees. Prepayment of Client Fees For more details on the brokerage practices, see Item 12 of this brochure. GFG does not require any prepayment of fees of more than $1,200 per Client and six months or more in advance. Investment management fees are billed quarterly in advance. Fees for ERISA 3(21) services may be billed in advance. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GFG. - 6 -  External Compensation for the Sale of Securities to Clients Mr. Dornoff receives external compensation for the sale of securities to clients as registered representatives of LPL Financial, a broker-dealer. Approximately 15% of his time is spent in this practice and less than 20% of his total revenue is generated as registered representatives. He will offer clients products from this activity. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. As registered representatives, Mr. Dornoff does not charge advisory fees for the services offered through LPL Financial. This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another registered representative of their choosing. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. GFG does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for GFG to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description GFG generally provides investment advice to individuals, high net worth individuals, trusts, estates, or charitable organizations, corporations or business entities. Account Minimums Client relationships vary in scope and length of service. GFG may require a minimum to open an account in their wrap fee program for certain investment portfolios. In addition, some platforms used by GFG may require minimums to open accounts with them. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis, charting, and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. - 7 -  Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered, without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. In developing a financial plan for a Client, GFG’s analysis may include cash flow analysis, investment planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. Investment Strategy The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to GFG. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks Other strategies may include long-term purchases and short-term purchases. • Market Risk All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with GFG: • : The prices of securities held by mutual funds, ETFs, individual securities, or bonds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially Interest-rate Risk sharp declines in market value. : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. - 8 -  Inflation Risk • • Currency Risk : When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Fixed Income Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund, security or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A Investment Companies Risk: nominal interest rate is the sum of a real interest rate and an expected inflation rate. When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. Because the mutual fund or ETF manager is being compensated from the internal expenses to conduct research and monitor performance, the fee or a portion of the fee the clients pay may be redundant. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s - 9 -  • Foreign Securities Risk: officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Long-term purchases Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Short-term purchases : Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Trading risk : Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. : Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings GFG and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings GFG and its management have not been involved in administrative enforcement proceedings. GFG and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of GFG or the integrity of its management. - 10 -  Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Futures or Commodity Registration GFG is not registered as a broker- dealer, however Mr. Dornoff is a registered representative of LPL Financial, a FINRA/SIPC broker-dealer. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither GFG nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Mr. Dornoff has financial affiliated business as both a registered representative and insurance agent with LPL Financial. Approximately 15% of his time is spent on these activities. He will offer Clients services from those activities. As a registered representative and/or insurance agent, he may receive separate yet typical compensation. These practices represent conflicts of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another registered representative or insurance Recommendations or Selections of Other Investment Advisors and Conflicts of Interest agent of their choosing. GFG does not select or recommend other investment advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of GFG have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of GFG affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of GFG. The Code reflects GFG and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. GFG’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of GFG may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. - 11 -  GFG’s Code is based on the guiding principle that the interests of the Client are our top priority. GFG’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. GFG will provide a copy of the Code of Ethics to any Client or prospective Client upon Investment Recommendations Involving a Material Financial Interest and Conflict of request. Interest GFG and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest GFG and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide GFG with copies of their brokerage statements. The Chief Compliance Officer of GFG is Thomas J. Dornoff. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest GFG does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide GFG with copies of their brokerage statements. The Chief Compliance Officer of GFG is Thomas J. Dornoff. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. - 12 -  Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions • Directed Brokerage GFG does not have discretionary authority to determine the broker/dealer to be used or set commission rates for transactions. GFG may recommend the use of a particular broker- dealer . GFG will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. GFG relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by GFG. • Best Execution GFG does not allow directed brokerage accounts. • Soft Dollar Arrangements Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. Aggregating Securities Transactions for Client Accounts GFG does not receive soft dollar benefits. GFG is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of GFG. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Officer of GFG. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target bans of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, GFG suggests updating at least annually. - 13 -  Review of Client Accounts on Non-Periodic Basis Content of Client Provided Reports and Frequency Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by GFG’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisory Firm Payments for Client Referrals Mr. Dornoff receives external compensation for the sale of securities to Clients as a registered representatives of LPL Financial, a broker-dealer. GFG does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at a qualified custodian, which means the custodian provides account statements directly to Clients at their address of record or via electronic delivery with Client consent at least quarterly. Clients are urged to compare the account statements received directly from the custodian to the performance report prepared by GFG. Clients are urged to report any discrepancies to GFG. GFG is deemed to have constructive custody because advisory fees are directly deducted from Client’s account by the custodian on behalf of GFG and due to its third-party money movement authority. GFG and its qualified custodian meet the following seven (7) conditions in order to avoid maintaining full custody: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The Client authorizes GFG, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization, and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. - 14 -  5. GFG has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. GFG maintains records showing that the third party is not a related party of GFG or located at the same address as GFG. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by GFG. GFG is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of GFG. Item 16: Investment Discretion Discretionary Authority for Trading GFG requires discretionary authority to manage securities accounts on behalf of Clients. GFG has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. GFG allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to GFG in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. GFG does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes Granite Financial Group, LLC dba Granite Financial Group (“GFG”) will vote proxies on behalf of a client if, in its investment advisory agreement (“IAA”) with GFG, the client has delegated to GFG the authority to vote proxies on its behalf. GFG has adopted and implemented these policies and procedures (“Proxy Voting Procedures”) to ensure that, where it has voting authority, proxy matters are handled in the best interest of clients, in accordance with GFG’s fiduciary duties and SEC rule 206(4)-6 under the Investment Advisers Act of 1940. In addition to SEC requirements governing advisers, its Proxy Voting Procedures reflect the long-standing fiduciary standards and responsibilities for ERISA accounts set out in Department of Labor Bulletin 94-2, 29 C.F.R. 2509.94-2 (July 29, 1994). GFG utilizes the services of a third party Proxy Voting Service to administer the vote on proxies for those accounts for which GFG has voting authority. The Proxy Voting Service has a copy of GFG’s Proxy Voting Guidelines and votes on each proxy based on GFG’s Proxy - 15 -  Voting Guidelines. GFG generally follows its Proxy Voting Guidelines unless GFG determines that the client’s best interests are served by voting otherwise. The following policies will apply when voting proxies on behalf of accounts for which GFG has voting authority. Client’s Best Interest. GFG’s Proxy Voting Procedures are designed and implemented in a way that is reasonably expected to ensure that proxy matters are conducted in the best interest of clients. When considering the best interest of clients, GFG has determined that this means the best investment interest of its clients as shareholders of the issuer. GFG has established its Procedures to assist it in making its proxy voting decisions with a view to enhancing the value of its clients’ interests in an issuer over the period during which it expects its clients to hold their investments. GFG will vote against proposals that it believes could adversely impact the current or potential market value of the issuer’s securities during the expected holding period. Client Proxy Voting Policies. Rather than delegating proxy voting authority to GFG, a client may (1) retain the authority to vote proxies on securities in its account, (2) delegate voting authority to another party or (3) instruct GFG to vote proxies according to a policy that differs from that of GFG. GFG will honor any of these instructions if the client includes the instruction in writing in its IAA or in a written instruction from a person authorized under the IAA to give such instructions. If GFG incurs additional costs or expenses in following any such instruction, GFG may request payment of such additional costs or expenses from the client. Stated Policies. These policies identify issues where GFG will (1) generally vote in favor of a proposal – FOR; (2) generally vote against a proposal – AGAINST; (3) specifically consider its vote for or against a proposal – Case By Case (CBC). However, these policies are guidelines and each vote may be cast differently than the stated policy, taking into consideration all relevant facts and circumstances at the time of the vote. Abstain from Voting. Our policy is to vote on issues and not to abstain from voting on issues presented unless the client’s best interest requires abstention. This may occur from time to time, for example, where the impact of the expected costs involved in voting exceeds the expected benefits of the vote such as where foreign corporations follow share blocking practices or where proxy material is not available in English. Oversight. All issues presented for shareholder vote will be considered under the oversight of GFG’s Proxy Voting Designee. All non-routine issues will be directly considered by the Proxy Voting Designee and, when necessary, the equity analyst following the company and/or the portfolio manager of an account holding the security, and will be voted in the best investment interests of the client. All routine for and against issues will be voted according to GFG’s policy approved by GFG’s Proxy Voting Designee unless special factors require that they be considered by GFG’s CCO and, when necessary, the equity analyst following the company and/or the portfolio manager of an account holding the security. GFG’s Proxy Voting Designee has established these routine policies in what it believes are the client’s best interests. Availability of Procedures. Upon request, GFG provides clients with a copy of its Proxy Voting Guidelines, as updated from time to time. - 16 -  Disclosure of Vote. Upon request, a client can obtain information from GFG on how its proxies were voted. Any client interested in obtaining this information can request a copy from their GFG representative. GFG has established several policies to ensure that proxy votes are voted in its clients’ best interest and are not affected by any conflicts of interest. All conflicts are mitigated by the fact that GFG has a fiduciary responsibility to act in the best interest of its clients. Clients are not required to authorize GFG to vote proxies on their behalf. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because GFG does not serve as a custodian for Client funds or securities and GFG does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Bankruptcy Petitions during the Past Ten Years GFG has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. GFG has not had any bankruptcy petitions in the last ten years. - 17 -