GIBRALTAR WEALTH MANAGEMENT FORM ADV PART 2A

Item 1. Cover Page Gibraltar Wealth Management, LLC Form ADV Part 2A - Brochure 1117 Old York Road Abington, PA 19001 Main Phone Number: (215) 956-5154 https://www.gibraltarwealth.com October 30, 2026 This brochure provides information about the qualifications and business practices of Gibraltar Wealth Management, LLC. If you have any additional questions about the contents of this Brochure, please contact James E. Bickley at (215) 956-5154. 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. Gibraltar Wealth Management, LLC is an SEC registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. Additional information about Gibraltar Wealth Management, LLC is available on the SEC’s website at https://www.adviserinfo.sec.gov.  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Item 2. Material Changes This Brochure, dated October 30, 2026, is an interim amendment to our Brochure dated March 30, 2026, which was filed with our most recent annual updating amendment. This amendment corrects Item 4 (Advisory Business), in which the regulatory assets under management managed on a discretionary and non-discretionary basis were transposed. As of December 31, 2025, GWM managed $49,330,951 on a discretionary basis and $163,324,502 on a non-discretionary basis, for total regulatory assets under management of $212,655,453. No other changes have been made to this Brochure. Our last annual update was dated March 30, 2026. As disclosed in that update, the following material changes were made since our prior annual update dated March 30, 2025: The brochure has been updated to add disclosure related to First Princeton Partners II, LP and GWM extending its investment advisory service offerings to pooled investment vehicles. You are encouraged to read this updated Brochure in its entirety. A summary of any material changes to this and subsequent Brochures will be made available to you within 120 days of the close of our business’ fiscal year. We will also provide you with additional updates or other disclosure information at other times during the year in the event of any material changes to our business as required by applicable regulation. You may request the most recent version of this brochure, free of charge, by contacting James E. Bickley at 215-956-5154. You may also obtain a copy by going to the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with GWM who are registered, or are required to be registered, as investment adviser representatives of GWM. ii  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Item 3. Table of Contents Item 1. Cover Page ...........................................................................................................................................1 Item 2. Material Changes ................................................................................................................................2 Item 3. Table of Contents ................................................................................................................................3 Item 4. Advisory Business ..............................................................................................................................1 Item 5. Fees and Compensation ......................................................................................................................6 Item 6. Performance-Based Fees and Side-by-Side Management ..................................................................9 Item 7. Types of Clients ..................................................................................................................................9 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ..........................................................10 Item 9. Disciplinary Information ..................................................................................................................20 Item 10. Other Financial Industry Activities and Affiliations ......................................................................20 Item 11. Code of Ethics ................................................................................................................................20 Item 12. Brokerage Practices ........................................................................................................................21 Item 13. Review of Accounts ........................................................................................................................23 Item 14. Client Referrals and Other Compensation ......................................................................................23 Item 15. Custody ...........................................................................................................................................23 Item 16. Investment Discretion .....................................................................................................................25 Item 17. Voting Client Securities ..................................................................................................................25 Item 18. Financial Information .....................................................................................................................26 iii  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Item 4. Advisory Business Founded by its president, managing member and principal owner, James E. Bickley, GWM provides financial counseling and consulting, investment management and wealth management services to its clients. At GWM, a keen awareness exists that the firm must limit the services available so it may provide the focus necessary to address specific areas of need for clients’ financial strategies. It is with this mission in mind that GWM offers advisory services that are tailored to realize goals for accumulation of wealth and its preservation. Accordingly, the firm intentionally offers a limited scope of services so it may concentrate directly on the client’s need rather than a corporate need for expansiveness. Gibraltar was established in March 2003. Prior to engaging GWM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with the firm setting forth the terms and conditions under which GWM renders its services (collectively the “Agreement”). When a copy of this Brochure Document and the Brochure Supplement for the client’s investment adviser representative is not provided to the client at least 48 hours prior to signing the contract(s), client has five business days from the time at which they receive the Disclosure Brochure in which to cancel the contract, without penalty. GWM provides continuous investment advisory services to clients on a discretionary or non‐ discretionary basis and as of December 31, 2025, provided services for clients with a cumulative total of $212,655,453 in assets under management, of which $163,324,502 were managed on a non‐discretionary basis and $49,330,951 were managed on a discretionary basis. In addition, GWM advises on additional assets of $100,502,741 bringing GWM’s total assets under management/advisement to $313,158,195. When engaged by clients on a discretionary basis, GWM may, with the authorization of the client, trade any securities or rebalance any client’s portfolio without the client’s explicit direction and/or consent. GWM may also assist clients in the selection of an appropriate qualified money manager who will provide discretionary investment management services to a client. The firm does not have the discretion to hire or fire these independent managers without client consent. For this reason, assets managed by these independent asset managers do not meet the regulatory definition of assets under management by the firm and are, therefore, only included in the total assets under management/advisement referenced above. This Disclosure Brochure describes the business of GWM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of GWM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees or any other person who provides investment advice on GWM’s behalf and is subject to GWM’s supervision or control. Financial Consulting and Investment Consulting Services GWM may provide its clients with a broad range of comprehensive financial consulting and investment consulting services. These services include retirement, education, insurance, estate planning, asset and liability review, investments and tax and cash flow needs of the client. These services may be provided on a standalone basis or may be provided as part of the firm’s 1  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE overall wealth management program (as set forth below). The services generally consist of the following, but may include other services as requested by the client: Financial Consulting • Implementation of the firm’s wealth management system. • Review of clients’ overall financial situation, including a written report of recommendations covering cash flow, tax planning, investment planning, estate planning and risk management. • Preparation of a written Estate Planning Summary and recommendations. • Preparation of a written Retirement Planning Report and recommendations. • Preparation or update to a client’s existing financial plan. Investment Consulting • An initial review and assessment of the past results of investment management services applied to investment portfolios. • Recommendation of potential investment managers based on refinement of client’s investment objectives/needs. • Ongoing monitoring and assessment of third-party adviser’s results relative to market indices and industry peers. • Participation in client meetings with third-party investment manager representatives. • Preparation of a written Asset Allocation Report and recommendation(s). • Preparation of a written analysis of clients’ current investment portfolio and recommendations for change where appropriate. In performing its services, GWM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such third-party information. The client retains absolute discretion over all implementation decisions and is free to accept or reject any of GWM’s recommendations. Clients are advised that it remains their responsibility to promptly notify GWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the firm’s previous recommendations and/or services. Relative Strength Advisory Services The Relative Strength Advisory Service is a service offered by GWM. All client assets are held in the client’s name at a custodian of the client’s choosing or in a separate account by means of an association with a company sponsored plan or account. No assets are held or will be held by GWM. GWM will provide advice regarding the mutual funds or exchange-traded funds (ETFs) offered to the individual client through the client’s 401(k) or retirement plan. In some instances, GWM may provide assistance to the client in developing or refining a menu of fund or ETF alternatives. The advice and guidance provided by GWM is based upon results from an individual matrix created and maintained for each client and/or plan. The fund or ETF 2  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE choices within the plan are compared to one another and those with the best Relative Strength measurements, as determined using the point & figure charts, are then provided as investment recommendations as determined by the model selected by the client. Each quarter GWM will communicate to the client the funds or ETFs in which investments are to be made. Depending on which Fund/ETF Model (3 Fund Model or 3- ETF Model; 4 Fund Model or 4-ETF Model; or 5 Fund Model or 5-ETF Model) is selected for use by the client, it will be the client’s responsibility to equally invest in the top 3, 4 or 5 Fund or ETF Model on the recommended listing. By way of example, with the 3 Fund Model or 3-ETF Model, 34% of the allocation would be invested in the first fund/ETF choice and 33% invested in the remaining second and third choices. All menu options are evaluated not less than quarterly for purposes of providing guidance on fund or ETF changes and re-balancing. Increased transaction costs may be incurred for mutual fund and ETF models that are re-balanced more frequently. A more frequent re-balancing schedule may or may not improve model performance when factoring in the increased cost of transactions incurred. Investment Management and Wealth Management Services (Discretionary and Non- Discretionary) In addition to earning fees for consulting personal and retirement investment accounts, GWM extends additional services to clients who are in need of special supervision of their financial assets and personal business matters through its offering of wealth management services. These services may include the financial counseling and consulting services described above as well as the non-discretionary management of investment portfolios. To implement a client’s plan and as detailed further in Item 8, GWM may allocate clients’ investment management assets among Independent Managers (defined below). The Independent Managers may utilize a variety of investments including, but not limited to, exchange-traded funds (“ETFs”), individual stocks, fixed income securities and mutual funds in accordance with the client’s investment objectives. GWM may also exercise discretionary authority over a client's account and implement trades for such clients itself through its relationship with a Financial Institution, as defined below. GWM tailors its advisory services to the individual needs of clients. The firm consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. GWM ensures that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. GWM is committed to know their clients and to understand and be aware of changes in circumstances that may require a realignment of investment parameters and priorities. Although the firm does not implement a standardized investment policy statement (“IPS”) for clients, it will work with clients to prepare an IPS or with Independent Managers who may prepare an IPS for the client, as n e e d e d. Clients may impose reasonable restrictions or mandates on the management of their account if, in GWM’s sole discretion, the conditions would not materially impact the performance of a portfolio strategy or prove overly burdensome to GWM’s management efforts. 3  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Use of Independent Managers As mentioned above, for clients who require investment management services GWM may recommend that clients authorize the active discretionary management of their assets by independent investment managers (“Independent Managers”). The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between GWM or the client and the designated Independent Managers. GWM renders services to the client relative to the non- discretionary recommendation of Independent Managers. GWM monitors and reviews the account performance and the client’s investment objectives. GWM receives an annual advisory fee which may be based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending an Independent Manager for a client, GWM reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that GWM considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, GWM’s investment advisory fee set forth above. In addition to GWM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Inter-Active Advisory Services For clients wishing to increase their investment knowledge, Gibraltar offers an interactive investment service. Inter-Active investing allows for an in-depth and collaborative approach for clients to gain insight from Gibraltar’s advisors on investment ideas and strategies. Our professionals work with and support the active investor looking to make independent investment decisions. The focus is on detailed analyses and explanations of specific strategies clients may wish to discuss in order to make more informed decisions about their personal investments. Interactive investing provides customized guidance that is a valuable resource for our clients seeking a more dynamic relationship with a focus on learning and mentoring as they make investment decisions. Sub-Advisory Services GWM serves in the capacity as a sub-adviser under a sub-advisory agreement with a general partner and investment manager to a designated amount of a private fund. As such, GWM may be compensated by a fixed or a percentage management fee and a portion of a performance fee equal to a percentage of net profits/net gains of the sub-advised assets of the private fund in accordance with the Fund formation, management and offering documents. Pooled Investment Vehicle GWM serves as the Investment Manager to First Princeton Partners II, LP (the “Fund”). This Offering is available only to suitable Accredited Investors as defined in Rule 501(a) of 4  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Regulation D promulgated under the Securities Act of 1933 and/or Qualified Clients as defined in Rule 205-3 (17 C.F.R. § 275.205-3). The Fund has an investment objective that we must follow. For this reason, we cannot tailor the investment advisory services we provide to the Fund to meet individual investor needs or restrictions. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. GWM does not participate in any wrap fee programs. ERISA Fiduciary Services Services are provided as a fiduciary of specifically designated ERISA plans based on applicable definitions (contained in ERISA Section 404(a), IRC §4972, the Investment Company Act of 1940 and state laws). In performing the following services, GWM acts as a fiduciary as defined by ERISA Section 3(21) or ERISA Section 3(38). The services provided could include: Investment Advice to the Plan Sponsor, Preparation of the Investment Policy Statement (IPS), Investment Menu Design, Selection of a Qualified Default Investment Alternative (QDIA), Performance Monitoring, Performance Reports and Participant Advice. When GWM provides investment advice to you regarding your retirement plan account, individual retirement account, or other qualified asset under ERISA, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Such provisions also extend to other qualified assets such as Education Savings Accounts and retirement annuities. Clients should fully understand all of the conflicts, risks, costs & expenses, as well as potential benefits associated with moving qualified retirement assets. Clients are under no obligation to accept or follow GWM’s recommendations. IRA Rollover Recommendations We may recommend the rollover of assets from retirement plans to individual retirement accounts (IRAs). This creates an inherent conflict of interest, as the rollover can result in increased fees and expenses for clients, which may result in higher compensation for our firm. However, we typically only provide general education to clients about the pros and cons of rollovers. We acknowledge and understand these conflicts of interest and strive to always act in the best interest of our clients. We adhere to a fiduciary standard of care, which means that we are legally and ethically obligated to put our clients' interests ahead of our own. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. 5  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Item 5. Fees and Compensation GWM offers its services under various fee arrangements, which may include hourly and/or fixed fees, variable fees applied (on a percentage basis) to assets under management or advisement, or a combination of both. Additionally, certain of the firm’s Supervised Persons, in their individual capacities, may offer insurance products under a commission arrangement. Financial Counseling and Consulting Fees GWM may charge a fixed fee and/or hourly fee for these services. These fees are negotiable, but generally range from $3,000 to $18,000 on a fixed fee basis and/or from $150 to $350 on an hourly rate basis, depending upon the level and scope of the services and the professional rendering the services. Prior to engaging GWM to provide these services, the client will generally be required to enter into a written agreement with the firm setting forth the terms and conditions of the engagement and describing the scope of the services to be provided and the portion of the fee that is due from the client prior to GWM commencing services. GWM may request that a portion of the fee (estimated hourly or fixed) be paid in advance upon entering the written agreement with the balance being due upon the completion of the agreed upon service(s). Relative Strength Investment Advisory Fees GWM provides its Relative Strength investment advisory services for an annual fee based upon a percentage of assets under the firm’s advisement. These fees are negotiable, but generally range from 0.50% to 1.25% annually, depending upon fund menu development and the size and value of a client’s plan assets. This fee is charged quarterly, in advance, as derived from the market value of a client’s plan assets on the last day of the previous quarter. Investment Management and Wealth Management Fee GWM provides its investment and wealth management services for an annual fee based upon a percentage of the market value of the assets being managed by GWM, a fixed fee arrangement, or a combination of both. GWM’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client. GWM’s annual fee is prorated and charged quarterly in advance, based upon the market value of the assets on the last day of the previous quarter. The annual fee varies (between 0.25% and 1.50%) depending upon the market value of the assets under management and the type of services to be rendered. Clients may pay a fixed, hourly, or asset-based fee (described above), or a combination thereof, based on the complexity of the services provided. Fixed fees range between $1,200 $60,000 annually. GWM, in its sole discretion, may charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). 6  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Inter-Active Advisory Services Fees for Inter-Active investment advisory services range between 0.40% - 0.75% annually and are billed quarterly, in advance, based on portfolio size and desired frequency of interaction. Fees for Inter-Active Advisory Services may be charged separately and are in addition to fees for other GWM services. Fees Charged by Financial Institutions As further discussed in response to Item 12 (below), GWM may recommend the use of certain custodians for custodial services of investment management accounts. GWM can only implement its investment management recommendations after the client has arranged for and furnished GWM with all information and authorization(s) regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, any other broker- dealer recommended by GWM, any broker-dealer directed by the client, trust companies, banks etc. (collectively referred to herein as the “Financial Institutions”). Clients may incur certain charges imposed by the Financial Institutions and other third parties such as fees charged by Independent Managers, custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed in each fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients will incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to GWM’s fee and GWM receives no portion of the fees charged by the independent managers or financial institutions other than GWM’s advisory as outlined under “Fee Debit” below. Fee Debit GWM’s Agreement and the separate agreement with any Financial Institutions may authorize GWM or Independent Managers to debit the client’s account for the amount of GWM’s fee and to directly remit that management fee to GWM or the Independent Managers. Any Financial Institutions recommended by GWM have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to GWM. Clients wishing to pay GWM’s advisory fee directly may, alternatively, request GWM to send an invoice for payment. Clients will, no less than quarterly, receive a copy of their account statement(s) directly from the custodian indicating all amounts disbursed from clients’ accounts, including the investment management fee. GWM sends clients copy of its fee statement, including the specific manner in which the investment management fee was calculated. Clients must authorize the fee debit in the Custodial Agreement. Fees for Management During Partial Months of Service For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement between GWM and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. GWM’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. 7  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Clients may make additions to and withdrawals from their account at any time, subject to GWM’s right to terminate an account. Additions may be in cash or securities provided that GWM reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to GWM, subject to the usual and customary securities settlement procedures. However, GWM designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a client’s investment objectives. GWM may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or may result in other tax implications (i.e. short term/long term capital gains). Fees paid in advance are based on the closing value of the account(s) for the prior period and are not adjusted for intra period deposits and/or withdrawals. Fees for Affiliated Private Fund The Investment Manager shall charge the Fund an annual management fee (the “Management Fee”). The Management Fee for Class A Partners shall be equal to two percent (2.00%) per annum of the net asset value of the Class A Partner’s Capital Account. The Management Fee for Class B Partners shall be equal to one percent (1.00%) per annum of the net asset value of the Class B Partner’s Capital Account. The Management Fee will be charged quarterly in advance. The Partnership Agreement calls for an Incentive Allocation to be made to the General Partner from Class B Partners’ Capital Accounts when the net profit of such Class B Partners’ Capital Accounts exceed the average return for the 30-day Treasury Bill (“Hurdle Rate”) calculated during the Performance Allocation Period. For the net profit in excess of the Hurdle Rate, ten percent (10%) of such net profit will be paid to the General Partner. Any separate arrangements with investors, such as separately negotiated fee arrangements, are subject to a written letter agreement between the private fund and the investor. Such arrangements will cause some underlying investors or groups of investors to have terms or to pay fees that are different from the basic fee schedules disclosed in fund offering materials. The fund’s offering materials contain further information regarding fees and other charges. Fees assessed on investments in the private fund by certain of our employees and related persons are reduced or waived entirely. Margin Accounts In limited instances, a margin account may be established at the direction of a GWM client. In these instances, all trading pertaining to the margin account will be directed by the client. A margin account may incur margin interest which will be charged by the custodian in addition to GWM’s advisory fee. As the advisory fees are generally based on total assets under management, the advisory fees could include securities purchased on margin held in a client’s account. This creates a potential conflict of interest because the use of margin can increase the total assets under management. There may be separate agreements with clients in regards to how their specific margin balance is treated based on specific circumstances. 8  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Cash and Cash Equivalents As part of the investment process, GWM will routinely maintain and actively manage a percentage of each client’s portfolio in cash or cash equivalents. Such cash is generally used to meet short-term client cash needs or may be maintained to pay for additional investments in securities as needed. Clients will pay management fees on cash assets unless specifically excluded as agreed upon by GWM and the client. Item 6. Performance-Based Fees and Side-by-Side Management GWM may provide services for performance-based fees. Performance-based fees are those based on a share of capital gains on or capital appreciation of the assets of a client. Such arrangements are only available for Accredited Investors and made under separate agreement with GWM and the Client. We have entered into performance-based fee arrangements with pooled investment vehicle clients and certain separate account clients. These arrangements provide for an asset-based management fee plus a performance fee based on the portfolio’s gross or net return in excess of a specified benchmark during a designated period of time. A client with a performance fee arrangement should refer to its investment management agreement for details on the performance fee computation. It is possible that two client accounts in the same strategy may have different fee structures because one may have a performance- based fee. In this situation, the two clients could pay different amounts for the same service solely because of the performance-based fee. Performance-based fee arrangements will be charged only to “qualified clients”, in accordance with Rule 205-3 under the Investment Advisers Act of 1940 (“Advisers Act”). Performance-based fees may provide an incentive for GWM to make riskier or more speculative investments than would be the case in the absence of such an arrangement. GWM recognizes this potential conflict and works to ensure that actions taken by GWM are in the best interest of GWM clients. Item 7. Types of Clients GWM offers its services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, business entities, and private investment funds. Minimum Fee GWM, at its sole discretion, may impose a minimum annual fee of $1,200. This minimum fee, if imposed, may have the effect of making the firm’s service impractical for clients with less than $80,000 under GWM’s management. Additionally, GWM generally imposes a minimum annual fee of $500 to provide its Relative Strength investment advisory services. GWM’s sponsored pooled investment vehicle is generally subject to a $250,000 minimum initial investment, subject to the General Partner’s sole and absolute discretion to accept a lesser amount. Please refer to the offering documents for more information. 9  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE The firm, in its sole discretion, may waive its minimum fee requirements based upon certain criteria including anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing or related client relationships, account retention, and pro bono activities. Additionally, certain Independent Managers may impose separate and/or more restrictive account requirements and varying billing practices than GWM. In such instances, GWM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategies and Methods of Analysis GWM conducts an initial assessment with clients to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Independent Managers For clients who require investment management services, GWM may recommend allocating clients’ assets among Independent Managers for day-to-day trading. The GWM platform enables a client flexibility to choose from a broad range of Independent Managers and fund groups. Often a single third-party custodian is necessary to hold client funds and process transactions as directed by the Independent Managers. Clients may already have a custodial relationship or can establish new accounts with the help of GWM through its relationships with Schwab or other custodians. GWM is familiar with the evaluation of such organizations and as part of its program offers assistance in the evaluation of the numerous alternatives available, as requested by the client. Based in part on GWM’s recommendations, the Independent Managers may utilize a variety of investments including, but not limited to, ETFs, individual common and preferred stock, bonds and mutual funds in accordance with the client’s investment objectives. In limited circumstances, GWM may implement trades for clients on a non-discretionary basis through relationships with various account custodians. Additionally, mutual funds are considered as a cost-effective means for achieving appropriate asset allocations within 401(k) and other retirement programs. Funds selected are offered on a no-load or net asset value purchase arrangement. The firm conducts periodic reviews of Independent Managers and offers regular meetings with clients throughout the year to review their managers’ performance. GWM includes the Independent Managers in these meetings as/when appropriate. GWM is also extremely sensitive to changes in an Independent Manager’s performance or investment style as well as the construction of the individual management teams. One of the most difficult determinations to be made by an investor is when to terminate a manager relationship. GWM works with clients throughout the year to objectively monitor and make decisions about third party managers. 10  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Account performance is measured relative to market statistics, indices and other managers offering similar investment disciplines and strategies. GWM acknowledges that performance delivered to clients is often influenced by client-established constraints and risk tolerance. All such factors are considered when making an initial recommendation of an Independent Manager or during subsequent periods. Discretionary Authority GWM may provide Investment Management services to clients on a discretionary basis where such clients authorize GWM to exercise discretion over the client's portfolio. In such relationships, GWM will exercise such discretion using methods of investment analysis that may include Model Provider Analysis, Charting Analysis, Cyclical Analysis, Fundamental Analysis, Modern Portfolio Theory, Quantitative Analysis, and Technical Analysis. GWM, when determining it appropriate and/or necessary, may use a variety of research providers including investment banks, independent research firms and newsletters to perform these analyses. • Model Provider Analysis provides due diligence on the research provider’s investment philosophy, investment process, people and organization. • Charting Analysis involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which are used to predict future price movements based on price patterns and trends. • Cyclical Analysis analyzes business cycles to find favorable conditions. Cyclical Analysis is a type of technical analysis that involves evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. • Fundamental Analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. It involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company's industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. The risk in fundamental analysis is that information obtained is subject to change and may not provide an accurate estimate of earnings, which may have been a factor in determining the stock's value. Where securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in accurately assessing performance. • Modern Portfolio Theory offers a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher 11  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-adjusted return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. • Quantitative Analysis deals with measurable factors as distinguished from qualitative considerations, such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, or historical projections of sales, and other factors. Quantitative modeling consists of searching for repeating patterns— persistent occurrences of a phenomenon, correlations among liquid assets or price- movement patterns. • Technical Analysis involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. The risk of market timing based on technical analysis is that charts may not accurately predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. The risk of fundamental analysis is that information obtained may be inaccurate and, as a result, the analysis fails to provide an accurate estimate of earnings, which may be a significant factor impacting the stock's value. Where securities prices adjust rapidly to new information, utilizing fundamental analysis may not ultimately be a good indicator for evaluating a stock’s potential performance. In developing discretionary investment portfolios, GWM may identify strategies utilizing a multi- asset class style of portfolio management that employs the traditional two-dimensional asset class structure of equities and fixed income augmented by a third dimension of alternative investments. Examples of alternative investments include, but are not limited to, REITs, MLPs, Commodities and Hedge Funds. This strategy can be implemented primarily in two different ways or in combination: 1) Liquid – Use of publicly-traded securities such as ETFs, mutual funds and individual securities that are priced daily in client portfolios. This is generally GWM’s primary approach. 2) Illiquid – For accredited investors, GWM may use certain illiquid alternative investments like private equity, private debt, hedge funds, and real assets as provided in private partnerships and/or private placements. GWM may use one or more of the following investment strategies when providing discretionary investment advice to clients: • Research Model Implementation: o Strategic Asset Allocation – Asset allocation is a long-term investing strategy that does not involve active trading, but is subject to periodic rebalancing (e.g., quarterly, annually or some other determined interval). Changes to asset class 12  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE selections and/or portfolio weights are communicated to, and implemented by, GWM by the research provider or GWM’s Investment Committee. Then GWM buys or sells ETFs, mutual funds and or individual securities (within a week of receiving asset class portfolio weights from the research provider) in client accounts to reflect the research provider’s recommendations. o Tactical Asset Allocation – Asset allocation is a short-to-intermediate term investing strategy that involves more frequent trading (e.g., weekly, monthly or some other determined interval). Changes to asset class selections and/or portfolio weights are communicated to, and implemented by, GWM by the research provider or GWM’s Investment Committee. Then GWM buys or sells ETFs, mutual funds and or individual securities in client accounts to reflect the research provider’s recommendations. o Equity Portfolios – Usually, equity portfolios are composed almost entirely of individual equities and some cash equivalent. The research provider communicates the weights of the individual stocks in the portfolio. Then GWM buys or sells the stocks to match the recommended weights. It should be noted that with Research Model Implementation, client tax considerations may impact how frequently GWM rebalances the portfolio. Consequently, the performance of individual client portfolios may differ from the research provider’s model allocation. • Proprietary Asset Allocation and Security Selection: o Strategic Asset Allocation – Strategic asset allocation is a long-term investing strategy that relies on consistent periodic rebalancing (e.g., quarterly, annually or some other pre-determined interval). Utilizing a combination ETFs, mutual funds, and individual securities, GWM’s team builds each client’s portfolio and then periodically rebalances client accounts to reflect and maintain the desired asset allocation. o Tactical Asset Allocation – Tactical asset allocation is a short-to-intermediate term investing strategy that involves more frequent trading (e.g., weekly, monthly or some other pre-determined interval). Initially, GWM’s team builds the asset allocation and then buys and sells ETFs, mutual funds and or individual securities in client accounts to reflect any change in the asset allocation. o Equity Portfolios –are generally composed of individual equities with some cash equivalents. GWM’s team builds the equity portfolio. Then GWM buys and sells the stocks to match the proprietary model. Client tax considerations may impact how frequently a portfolio is rebalanced. Consequently, the performance of client portfolios may differ from benchmark indexes. Clients participating in GWM’s Strategic Asset Allocation, Tactical Asset allocation, or Equity Portfolios programs understand that client portfolios are managed independently and that tax considerations may impact how frequently GWM rebalances the portfolio. As a result, the performance of individual client portfolios will likely differ from the 13  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE research provider’s model allocation. Risks of Loss General Risk of Loss Investing in securities always involves risk of loss that the client should be prepared to accept. GWM does not represent or guarantee that the investment management services, or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. GWM cannot offer any guarantees or promises that a client’s financial goals and objectives can or will be satisfied. Past performance is not indicative of future performance. GWM also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. Common Stock/Equity Securities The portfolios and strategies offered by GWM generally invest in mutual funds and ETFs, which will fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. As a result, the value of common stocks may decline, which, in turn, would result in losses for any strategy investing in such securities. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the open market. Generally, ETF shares trade at or near their most recent NAV, However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. Market Risks The profitability of a portion of GWM’s recommendations may depend to a great extent upon correctly assessing the future course of price movements of stocks and bonds. There can be no assurance that GWM will be able to predict those price movements accurately. Model Risk Financial models are based upon assumptions that may prove invalid or incorrect under certain market environments and conditions. There is no guarantee that any particular model will work under all market conditions. For this reason, GWM includes model-related results as part of 14  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE certain investment decision processes, but also relies on professional judgment in making trades and allocating assets. Inflation, Currency, and Interest Rates Security prices and portfolio returns vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by GWM will be affected by the risk that currency devaluations affect client purchasing power. Use of Independent Managers GWM may recommend the use of Independent Managers for investment management accounts. GWM provides ongoing due diligence of such managers, but GWM’s recommendations rely, to a great extent, on the Independent Managers’ ability to successfully implement their investment strategy. As GWM does not have the ability to supervise the Independent Managers on a day-to-day basis, there is a risk that the independent manager(s) fail to meet GWM and their client’s expectations or intended objectives. Mutual Funds, ETFs and ETNs An investment in a mutual fund, ETF or ETN involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Mutual Funds: Investing in mutual funds (open or closed-end) carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned below). The per-share net asset value (NAV) of a mutual fund is calculated at the end of each business day. Unlike individual equities, clients, and GWM, are restricted in their ability to exit such securities intraday to limit potential losses. Exchange-Traded Funds (ETFs): These securities are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent net asset value. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Exchange-Traded Notes (ETNs): ETNs are a type of debt security that trade on exchanges and seek a return linked to a market index or other benchmark. Unlike ETFs, ETNs do not buy or hold assets to replicate or approximate the performance of the underlying index. An ETN is a promise from the issuer to pay the return of an index, a promise that is not guaranteed by any underlying collateral. Thus, the ETN issuer has an unsecured debt obligation, which it often attempts to hedge by holding long positions in the assets underlying 15  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE the ETN index. When the ETN grows, the issuer may find it difficult to hedge its obligations, and therefore may decide to cap the issuance of additional shares of ETNs. Given the complexity and associated risks, ETNs may not be suitable for all investors. The return on an ETN generally depends on price changes if the ETN is sold prior to maturity (as with stocks or ETFs)—or on the payment, if any, of a distribution if the ETN is held to maturity (as with some other structured products). An ETN's indicative value is computed by the issuer and is distinct from an ETN's market price, which is the price at which an ETN trades in the secondary market. Investors should understand that an ETN's market price can deviate, sometimes significantly, from its intrinsic value. Equity Equity investments generally refers to buying shares of stocks or acquiring interests in non- corporate entities in return for receiving a future payment of dividends or distributions and capital gains if the value of the investment increases. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Fixed Income Investments in securities, such as bonds, notes or other instruments that generally pay a return on a fixed schedule, though the amount of the payments can vary and include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer- term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing. Real Estate funds (including REITs) Real estate investments face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Short Term Trading Short term trading, or purchasing and selling securities within short-term intervals, raises risks of timing, liquidity, excessive costs, economic stability and inflation. 16  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Short Sales Selling securities short, which means borrowing securities for sale with the obligation to repurchase them in the future, raises the risk of loss if the value of the short security increases. As a result, the possibility of losses incurred from a Short Sale can be unlimited. Options Writing A securities transaction that involves selling the right, but not the obligation, to buy or sell a stock at a specific price (the strike price) is called an option. When an investor buys the right to purchase a stock at a specific price is it identified as a Call Option. When an investor buys the right to sell a stock at a specific price it is identified as a Put Option. The option to either buy or sell a stock at a specific price is purchased or sold and the amount paid for the privilege is referred to as the Option Premium. All options, whether Calls or Puts, have a time frame in which they may be exercised and the transaction may occur at any time before the Expiration Date which is predetermined when the option is purchased or sold. When an investor uses a call option strategy the investor may be entitled to buy shares of stock if they bought a call option or deliver shares of stock if they have sold a Call. Conversely, if the investor purchases a Put option, they have the right to sell shares of stock and if they have sold a Put they may be required to purchase shares of stock. The execution price of the purchase or sale of the underlying stock is at the Strike Price. Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, the investor’s risk can be unlimited and therefore employing options strategies should be closely evaluated and understood. Political Risks/Legislative Changes Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for Mutual Funds, Real Estate Investment Trust and Exchange Traded Products/Funds/Securities. GWM does not engage in tax planning, and in certain circumstances a client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for understanding how the transactions in their account will be reported to the Internal Revenue Service or any other taxing authority. Cybersecurity Risk As the use of technology increases, all financial firms are subject to increasing operational, information security and cyber-related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber incidents include, but are not limited to, unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Such incidents can cause disruptions and impact business operations and could result in an inability for GWM to transact business and/or financial loss. While GWM has processes and plans in place in attempt to identify and mitigate cyber incidents, there are limitations in such plans the possibility that certain risks have not yet been identified. Additionally, GWM cannot control the cybersecurity plans and systems put in place by third-party service providers; clients could be impacted by a cyber incident related to such third- party service provider. 17  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Impact of Disease Epidemics The outbreak of an infectious disease in the United States or elsewhere, such as the novel coronavirus (e.g., “COVID-19”), together with any resulting travel restrictions or quarantines, could result in disruptions to the adviser and/or third-party service providers on which the adviser relies. Given that the nature, timing, and severity of an outbreak is unknown, the extent to which an epidemic might impact the adviser, its investments, or its advisory operations is uncertain. In addition to impacting the adviser and the adviser’s third-party providers, a pandemic may, and most likely will, have a negative impact on the economy and business activity in the United States and worldwide leading to potential significant disruption, volatility, and potential losses across financial markets. Clients of the adviser must be prepared for such potential losses and while the adviser has processes in place to ensure business continuity and to monitor the performance of its vendors and underlying investments, the uncertainty around the nature, type, breadth, and duration of an epidemic and the overall potential impact to the adviser’s operations and client investments is unclear. Risks Associated with Investments in Private Companies The below risks are specific to investments of GWM’s sponsored pooled investment vehicle, which is referred to within this section as the “Partnership”. Investments by the Partnership in the debt or equity of private companies may expose the Partnership to a wide number of risks, including market risk, credit risk, liquidity risk, operational risk and litigation risk. “Blind Pool” Offering. The offering is a “blind pool” offering because the Partnership has not yet identified any or all of the investments that it will make. Therefore, investors will not have the opportunity to review Partnership investments prior to the General Partner’s investment. The Partnership may not have control over an investment. In general, the Partnership will acquire only a minority interest in a private company or other asset in which it invests, or rely on independent third party management or strategic partners with respect to the management of a private company. The Partnership may also co-invest with third parties through partnerships, joint ventures or other entities, thereby acquiring non-controlling interests in certain investments. Therefore, the Partnership may not be able to exercise control over the investment. A third-party partner or co-venturer may have financial difficulties resulting in a negative impact on such asset, may have economic or business interests or goals which are inconsistent with those of the Partnership, or may be in a position to take action contrary to the Partnership’s investment objectives. The Partnership may not achieve its targeted rate of return on its investments. The Partnership expects to make investments based on its estimates or projections of overall rates of return on such investments, which in turn are based upon, among other considerations, assumptions regarding the performance of private companies, the amount and terms of available financing, marketability and viability of and the manner and timing of dispositions, all of which are subject to significant uncertainty. In addition, events or conditions that the Partnership has not anticipated may occur and may have a significant effect on the actual rate of return received 18  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE on an investment. Lack of Liquidity and Need for Additional Capital. In some cases, private companies will become successful only if additional capital is raised, which may dilute the holdings of previous investors. The inability of such private companies to attract other capital may have the effect of halting the development of that private company and cause the Partnership to lose its investment therein. Also, if such private company is ultimately unsuccessful in going public and developing a public market or merging with or being acquired by another company, the Partnership’s holdings of that company’s securities may become worthless. Competition for Investments. The Partnership operates in a highly competitive market for investment opportunities and competition may limit the Partnership’s ability to acquire desirable investments in the Partnership’s target assets and could also affect the pricing of these securities. The Partnership’s performance depends, in large part, on the Partnership’s ability to acquire its target assets at attractive prices. In acquiring the Partnership’s target assets, the Partnership will compete with a variety of institutional investors. Many of the Partnership’s competitors are substantially larger and have considerably greater financial, technical, marketing and other resources than the Partnership does. In addition, some of the Partnership’s competitors may have higher risk tolerances or different risk assessments, which could allow them to consider a wider variety of investments and establish more relationships than the Partnership. Furthermore, competition for investments in the Partnership’s target assets may lead to the price of such assets increasing, which may further limit the Partnership’s ability to generate desired returns. The Partnership cannot assure Limited Partners that the competitive pressures the Partnership faces will not have a material adverse effect on the Partnership’s results. Also, as a result of this competition, desirable investments in the Partnership’s target assets may be limited in the future and the Partnership may not be able to take advantage of attractive investment opportunities from time to time, as the Partnership can provide no assurance that the Partnership will be able to identify and make investments that are consistent with the Partnership’s investment objective. Start-up Risks. The Partnership may make investments in companies at the start-up or incubation stage of their development. Particularly in early-stage enterprises, a major risk exists that a proposed service or product cannot be developed successfully with the resources available to the private company. There is no assurance that the development efforts of any private company will be successful or, if successful, will be completed within the budget or time period originally estimated. The services and products may also be subject to a high degree of technical obsolescence. There is no assurance that any company in which the Partnership invests can successfully develop future generations of its services or products. Additional funds may be necessary to complete such development, and there is no assurance that such fund will be available from any particular source. Risk Inherent In Private Company Acquisitions. Acquisitions of equity and debt securities issued by private companies involve a high degree of risk, including that private companies may (I) have limited financial resources; (II) have shorter operating histories, smaller market shares than larger businesses, and limited inventory; (III) be more likely to depend on the management talents and efforts of a small group of persons; (IV) have less predictable operating results, may from time to time be parties to litigation, may be engaged in rapidly changing businesses, and may require substantial additional capital to support their operations, finance expansion or maintain their competitive position; (V) be particularly susceptible to economic slowdowns or recessions and may be unable to repay its loans or meet other 19  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE obligations during these periods; and (VI) experience unexpected problems in the areas of business development, financing, marketing, and general management. Item 9. Disciplinary Information Neither GWM nor any of its employees have any disciplinary history to report. Item 10. Other Financial Industry Activities and Affiliations GWM is required to disclose any relationship or arrangement that is material to its advisory business or to its clients with certain related persons. Receipt of Insurance Commission Certain of GWM’s Supervised Persons, in their individual capacities, are also licensed insurance agents with various insurance companies, and in such capacity, may recommend, on a fully-disclosed commission basis, the purchase of certain insurance products at the request of the client. While GWM does not sell such insurance products to its investment advisory clients, GWM does permit its Supervised Persons, in their individual capacities as licensed insurance agents, to sell insurance products to its investment advisory clients. A conflict of interest exists to the extent that GWM recommends the purchase of insurance products where GWM’s Supervised Persons receive insurance commissions or other additional compensation. Affiliated Private Funds and Sponsors GWM acts as investment adviser to a private fund whereby affiliated entities of GWM are the sponsor and General Partner of the private fund. The affiliated General Partner of the private fund as well as the related conflicts of interest will be disclosed to underlying investors before they invest. Management persons of the affiliated general partners will have conflicts of interest in allocating their time and service among such funds and other clients of ours. The private funds’ offering materials should be reviewed for further information regarding such conflict. Item 11. Code of Ethics GWM and persons associated with GWM (“Associated Persons”) are permitted to buy or sell securities that it also recommends to clients consistent with GWM’s policies and procedures. GWM has adopted a code of ethics that sets forth the standards of conduct expected of its associated persons and requires compliance with applicable securities laws (“Code of Ethics”). GWM’s Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public information by GWM or any of its associated persons. The Code of Ethics also requires that certain of GWM’s personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain pre-approval of certain investments 20  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE such as initial public offerings and limited offerings. When GWM is engaging in or considering a transaction in any security on behalf of a client, no Access Person may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household as the Access Person) a transaction in that security unless: • • • the client’s transaction(s) has (have) been completed; the transaction for the Access Person is completed as part of a batch trade (as defined below in Item 12) with clients; or a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by unaffiliated mutual funds or money market funds; (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds; and (v) equities or other publicly traded securities where such securities are, on a given day, not being considered for purchase or sale in GWM client accounts. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets and in such volume to permit transactions by Access Persons to be completed given that the Access Person’s purchase or sale of such security would have no appreciable impact on the markets of such securities. Under certain limited circumstances, exceptions may be made to the policies stated above. Clients and prospective clients may contact GWM to request a copy of its Code of Ethics. Item 12. Brokerage Practices As discussed above, GWM may recommend custodial services of investment management accounts. For those clients who may have existing custodial relationships at firms other than those mentioned, GWM is able to work with these clients to maintain that already established relationship. Factors which GWM considers in recommending a broker-dealer to clients include the broker- dealer's financial strength, reputation, execution, pricing, research and service. The commissions and/or transaction fees charged by recommended broker-dealers may be higher or lower than those charged by other Financial Institutions. Transaction fees paid by GWM’s clients comply with GWM’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where GWM determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, 21  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE execution capability, commission rates, and responsiveness. GWM seeks competitive rates but may not necessarily obtain the lowest possible transaction fees for client transactions. GWM periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. The client may direct GWM in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution, and GWM will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by GWM (as described below). As a result, the client may pay higher commissions or other transaction costs or greater spreads or receive less favorable net pricing, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, GWM may decline a client’s request to direct brokerage if, in GWM’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). Transactions for each client are effected independently as GWM generally does not combine or “batch” such orders based on its business model and trading strategies. Consistent with obtaining best execution, brokerage transactions may be directed to certain broker- dealers in return for investment research products and/or services which assist GWM in its investment decision-making process. Such research generally will be used to service all of GWM’s clients but may be used to obtain research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because GWM does not have to produce or pay for the products or services. Soft Dollars GWM does not receive “soft dollar benefits” so any such benefits are not a factor in recommending a broker-dealer or custodian to clients. Other Economic Benefits GWM may receive from Schwab, without cost to GWM, computer software and related systems support, which allow GWM to better monitor client accounts maintained at Schwab. GWM may receive the software and related support without cost because GWM renders investment management services to clients that maintain assets at Schwab. The software and related systems support may benefit GWM, but not its clients directly. In fulfilling its duties to its clients, GWM endeavors at all times to put the interests of its clients first. Clients should be aware; however, that GWM’s receipt of other economic benefits from a broker-dealer creates a conflict of interest since these benefits may influence GWM’s choice of broker- dealer over another broker-dealer that does not furnish similar software, systems support, or services. Additionally, GWM may receive the following benefits from Schwab through its Schwab Institutional division: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services the Schwab Institutional 22  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts and access to an electronic communication network for client order entry and account information. Item 13. Review of Accounts For those clients to whom GWM provides investment management services, GWM monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least a quarterly basis. For those clients to whom GWM provides financial counseling and consulting services, reviews are conducted on an “as needed” basis. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with GWM and to keep GWM informed of any changes thereto. GWM contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account statements directly from the broker-dealer or custodian for the client accounts. Those clients to whom GWM provides investment advisory services will also receive a report from GWM that may include such relevant account and/or market-related information such as an inventory of account holdings and account performance on a quarterly basis. Clients should compare the account statements they receive from their custodian with those they receive from GWM and advise GWM of any discrepancies. Those clients to whom GWM provides financial counseling and consulting services will receive reports from GWM summarizing its analysis and conclusions as requested by the client or otherwise agreed to in writing by GWM. Item 14. Client Referrals and Other Compensation GWM may receive economic benefits from non-clients for providing advice or other advisory services to clients. This type of relationship poses a conflict of interest and any such relationship is disclosed in response to Item 12, above. GWM does not compensate anyone for client referrals. Item 15. Custody GWM’s Agreement and/or the separate agreement with any Financial Institution may authorize GWM through such Financial Institution to debit the client’s account for the amount of GWM’s fee and to directly remit that management fee to GWM in accordance with applicable custody rules. GWM is deemed to have limited custody solely because advisory fees are directly deducted from client’s account by the custodian on behalf of GWM. The Financial Institutions recommended by GWM have agreed to send a statement to the 23  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to GWM. In addition, as discussed in Item 13, GWM also sends periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from GWM. Certain of GWM’s supervised persons act as a trustee or act pursuant to a power of attorney for a client and therefore GWM would have actual, as opposed to deemed, custody of such client’s assets. Such accounts will be subject to a Surprise Verification Audit pursuant to paragraph (a)(1) of Rule 206(4)-2 of the Investment Advisers Act of 1940 by an outside independent certified public accountant. Standing Letters of Authorization GWM, or persons associated with GWM, may effect money transfers from a client's account to one or more third-parties designated by the client without obtaining consent for each individual transaction, as long as we have a written authorization from the client. This authorization is commonly referred to as a Standing Letter of Authorization. An adviser with the authority to conduct such transfers is deemed to have custody over the client's assets in the related accounts. However, such accounts will not be subject to a Surprise Verification Audit, which is otherwise necessary for custody, if we meet the following conditions: 1. You provide written instructions signed by you, including the name, address or account number of the third-party, to the qualified custodian. 2. You authorize us in writing to direct transfers to the third-party either on a specific schedule or from time to time. 3. Your qualified custodian confirms your authorization (e.g., by reviewing the signature) and notifies you promptly after each transfer. 4. You can terminate or change the instruction. 5. We have no authority or ability to change the identity of the third-party, the address, or any other information about the third-party. 6. We maintain records showing that the third-party is not related to us and is not located at the same address as us. 7. Your qualified custodian sends you an initial notice confirming the instruction and an annual notice reconfirming the instruction, both in writing. We confirm that we meet all the above conditions. Pooled Investment Vehicles Advisers who are deemed to have custody of the assets of clients formed as pooled investment vehicles may comply with the rule if the pool has audited financial statements that are prepared in accordance with generally accepted accounting principles and such statements are distributed to investors in the pool within 120 days of the end of the fiscal year. Where GWM advises a pooled investment vehicle, we intend to cause such pooled investment vehicle to receive and distribute audited financial statements to its investors. Accordingly, private funds will be audited annually and investors will be provided with audited financial statements within 120 days of the end of the fund’s fiscal year. A client will generally receive from its bank, broker-dealer or other qualified custodian an 24  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE account statement, at least quarterly, identifying the amount of funds and each security in the account at the end of the period and setting forth all transactions in the account during that period. Clients should review these statements carefully. Clients will also receive account statements separately from GWM. Clients are strongly urged to compare the account statements received from us with those that are received from the respective client qualified custodian. Item 16. Investment Discretion Clients may engage GWM on either a discretionary or non-discretionary basis. Non-discretionary relationship - GWM accepts a limited power of attorney that permits GWM to effect transactions on the client’s behalf only after the client has so directed or consented to the transaction(s). Discretionary relationship - Clients authorize GWM to initiate and execute trades at GWM’s discretion and without client consent. Clients are offered the opportunity to impose reasonable restrictions on investing in certain securities subject to GWM’s approval. Item 17. Voting Client Securities GWM does not accept authority to vote proxies on behalf of its separately managed account clients and, as a result, does not vote client securities for those accounts. Clients who hold securities in such accounts will receive their proxies or other solicitations directly from their custodian or the issuer and are responsible for making all voting decisions and executing proxies for those securities. Clients should direct further questions on facilitating proxy voting to the aforementioned custodian or issuer. For the private fund for which GWM serves as Investment Manager, the Adviser has been authorized under the governing fund documents and the investment management agreement to exercise proxy voting authority with respect to securities held by the fund. In exercising such authority, the Adviser will vote proxies in a manner it believes is in the best interests of the applicable fund and its investors, consistent with the fund’s investment objectives and applicable legal and fiduciary standards. However, in light of the types of securities and strategies utilized by the fund, the Adviser does not expect proxy voting opportunities to arise frequently and may, where it determines that the expected economic or other benefit to the fund is minimal, refrain from voting a particular proxy. 25  GIBRALTAR WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE Item 18. Financial Information GWM is not required to disclose any financial information pursuant to this item as GWM does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. Furthermore, GWM has never been the subject of a bankruptcy petition and does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 26