GALLAGHER FIDUCIARY ADVISORS, LLC

Item 1 – Cover Page Gallagher Fiduciary Advisors, LLC 2850 Golf Road Rolling Meadows, IL 60008 https://www.ajg.com/us/services/investments-fiduciary-consulting/ https://www.ajg.com/us/services/retirement-plan-consulting/ March 31, 2025 This Brochure provides information about the qualifications and business practices of Gallagher Fiduciary Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at 212-918-8629 or at gbs.frs.compliance@ajg.com. 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. Gallagher Fiduciary Advisors, LLC is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Gallagher Fiduciary Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. ©2025 Gallagher Fiduciary Advisors, LLC. All rights reserved. i  Item 2 – Material Changes There are no changes in this ADV Part 2A (or “Brochure”) that materially change any of the services to our clients. Any changes to the text herein were intended solely to better describe our business. Our assets under management have been updated and include balances from our recent acquisitions. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. ii  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................ i Item 2 – Material Changes ................................................................................................................... ii Item 3 – Table of Contents .................................................................................................................. iii Item 4 – Advisory Business .................................................................................................................. 1 Item 5 – Fees and Compensation ...................................................................................................... 4 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................... 6 Item 7 – Types of Clients ...................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................. 7 Item 9 – Disciplinary Information ...................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ................................................... 10 Item 11 – Code of Ethics ..................................................................................................................... 12 Item 12 – Brokerage Practices .......................................................................................................... 13 Item 13 – Review of Accounts ........................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ................................................................. 15 Item 15 – Custody ................................................................................................................................. 15 Item 16 – Investment Discretion ....................................................................................................... 16 Item 17 – Voting Client Securities .................................................................................................... 16 Item 18 – Financial Information ......................................................................................................... 19 Item 19 – Requirements for State-Registered Advisers ............................................................ 19 iii  Item 4 – Advisory Business Arthur J. Gallagher & Co. (“AJG”) and Gallagher Benefit Services, Inc. (“GBS”), established Gallagher Fiduciary Advisors, LLC, (“GFA”) in 2008. GFA is the registered investment adviser subsidiary of GBS, one of the world’s largest employee benefits consulting firms. GBS and GFA are owned by Arthur J. Gallagher & Co. (“AJG”), the New York Stock Exchange-listed insurance brokerage and risk management firm (trading under the symbol “AJG”). GFA provides retirement, investment advice/consulting and decision-making to institutional investors, which include public and private sector employee benefit plans (including multiemployer plans), charitable institutions, foundations, endowments, labor organizations, state or municipal government entities, hospitals, non-profit organizations, private trusts, and corporations or business entities, insurance companies and individuals. GFA is also the appointed investment manager of one Collective Investment Trust. GFA also provides personalized financial guidance, retirement planning, data-driven investment advice/consulting, and managed account solutions to individual investors, including participants in workplace plans to private clients. For more information regarding GFA’s individual client services, please see our separate ADV 2A Brochure for Individuals. This Brochure provides information regarding our institutional clients. Fiduciary Advisory/Consulting Practice Our investment advisory/consulting practice serves defined contribution and defined benefit pension and other funds regulated under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), not-for-profit endowments and foundations and other institutional investors, where we accept fiduciary responsibility for ongoing advice on asset allocation, portfolio structure, risk management, third-party investment manager selection and monitoring, trading and brokerage and other issues. Our work for consulting clients regularly includes supervising portfolio transitions when managers are engaged or terminated. This practice also provides investment review services, where we perform project-based evaluations of the investment programs, policies and investment-related organizational structures of institutional investors compared to best practices. We recognize that each client is different and our advice is customized accordingly. To that end, our professionals invest time helping clients define their investment objectives and needs and their tolerance for risk. We consider the nature of the client’s investment portfolio, client’s liabilities or spending requirements, funding objectives, cash flow needs and sensitivity to investment risks. After helping the client establish its investment policy, asset allocation, risk management strategy and portfolio structure, GFA performs investment due diligence on third-party investment managers and provides advice and recommendations to clients regarding manager selection. In some cases we assume discretionary authority regarding investment decisions such as how and on what terms a client’s assets should be invested 1  and/or managed by third-party investment managers unrelated to GFA. In doing so, we use our discretion to select, monitor and, if need be, terminate and replace the outside investment managers. In other cases, we assume responsibility for selecting particular investment vehicles suitable for a particular strategy or asset class identified by the client and thereafter managing the client’s investment in the vehicle. To support this aspect of our work, we use quantitative and qualitative methodologies, including conducting more than 250 due diligence meetings with investment managers each year, personally interfacing with key personnel both on-site and in our offices to gain insight into their processes, philosophies, resources and organizations1. Retirement Plan Consulting Within GFA, the Gallagher Retirement Plan Consulting Team works with plan sponsors and their employees to design and manage successful employer sponsored retirement plans. This includes defined contribution and defined benefit plans. We help organizations meet their fiduciary responsibilities by working with them to implement prudent, documented processes. Our services include investment advisory, plan governance support, plan design consulting, vendor management and employee education. We typically engage with our clients as the plan’s ongoing advisor but can also consult on a project basis. Our national service model, which is delivered through a local team and regional support offices, can include, but is not limited to:  Plan Design – Detailed analysis and consultation of program features and provisions, included industry best practices and benchmarking.  Fee Benchmarking – Fee Benchmarking reports compare the current provider’s hard dollar, soft dollar and transactional fees to other providers in the retirement plan marketplace.  Administrative Practices/Plan Consulting – We will provide ongoing administrative support to the plan administrator and HR team, allowing for full consulting support as it relates to plan design, plan provisions, best practices and fiduciary process management.  Vendor Management & RFP Services – We provide vendor management services to help our clients with day-to-day plan issues and work to ensure the services listed in the service agreement, and promised during the vendor search process, are honored by the service provider and provided in an acceptable manner. Periodically, Gallagher can help its clients complete a full request for proposal evaluation. 2   Regulatory Compliance – Our Fiduciary Risk Mitigation Model provides for initial fiduciary risk review, best practice documentation of committee formation and ongoing operations, committee process and meeting management, recording of meeting notes (Minutes), and compliance support as it relates to Merger & Acquisitions, Self-Corrections, Voluntary Compliance and/or IRS/DOL audits.  Investments – This includes ERISA 3(21) or 3(38) advisory services, including helping the committee establish an Investment Policy Statement and providing Investment Monitoring Reports.  Employee Communication and Education Management – We will work with the plan sponsor to establish an education and communication strategy to support employees and the goals of the organization. We can help facilitate this through the provider or our own proprietary resources. Fiduciary Decision-making Practice Our fiduciary decision-making practice involves acting as a fiduciary decision-maker for ERISA- regulated benefit plans and other institutions when their regular fiduciaries have a conflict of interest or some other circumstance renders it appropriate – or legally necessary – for an independent, knowledgeable party to act in their stead with regard to a particular asset or transaction. Our fiduciary decision-making assignments have included, for example, acting as an independent fiduciary evaluating, valuing, acquiring and disposing of common stock and other securities issued by the employer/sponsor of ERISA-regulated defined contribution and defined benefit pension and other plans. Other assignments have included voting proxies with respect to reorganizations or other changes at mutual funds and other commingled vehicles for the benefit plan and other fiduciary clients of the financial institution that sponsors or manages the fund or vehicle, or corporate mergers involving such institutions. Other assignments have included assisting with pension risk transfer projects, including services relating to selecting annuity providers and assisting with annuity placement. On all of these assignments, we use our judgment as fiduciaries to make a decision about the transaction or asset at hand based on the client’s governing documents, the applicable legal standards and the specific facts about the transaction or asset and the client on whose behalf we are taking fiduciary responsibility. Tailored Advisory Services Advisory services are tailored to the unique needs of our clients. GFA provides customized discretionary and non-discretionary investment management services. GFA manages both pre-defined, or “model”, as well as fully customized investment strategies that differ by risk and potential return characteristics. Our investment strategies employ multiple underlying managers and investment strategies to provide the desired 3  diversification and risk characteristics. We are also a provider of structured equity and liability driven investments to institutional investors, offering a customized approach that endeavors to be affordable and transparent. . As of December 31, 2024, Gallagher Fiduciary Advisors, LLC, has the following assets under management: Discretionary Non-discretionary Total AUM $12,507,982,705.00 $168,106,299,814.00 $180,614,282,519.00 4  Item 5 – Fees and Compensation Fees for the investment advisory/consulting and retirement plan consulting practices are established through negotiation, based on the following factors, among others: the value of the assets subject to GFA’s services; the nature and scope of the services we provide to the client; the nature and degree of fiduciary and other risk assumed in connection with the services we provide to the client; and whether our role is expected to be temporary or ongoing. We typically charge a flat hard dollar fee or a fee based on assets under advisement. In a few limited cases, GFA charges on an hourly or project basis. Fees are generally paid quarterly in arrears or in advance as agreed upon. Contracts between GFA and its investment advisory clients are generally terminable by either party upon thirty to ninety days’ notice. When GFA serves as a decision-maker for a particular transaction or asset, our fee is structured to reflect, among other possible factors, the size and complexity of the assignment, the degree of risk to which we are subject in connection with the assignment, the exact function to be performed by GFA and the type of investment asset(s) or transaction involved. The structure of the fee for this work has typically been a flat fee, plus reasonable expenses. In a few instances, the fee is asset-based or hourly. In addition, we may be paid on an hourly basis in connection with follow-up work performed for a client after a project is completed. Our receipt of an asset-based fee presents a conflict of interest. This is because the more assets there are in the client’s account, the more the client will pay in fees. Therefore, we have an incentive to encourage clients to increase the assets in their accounts. We address this conflict of interest by ensuring that any such recommendations are in the client’s best interest. GFA does not accept compensation from the sale of securities or other investment products, including asset-based charges or service fees from the sale of mutual funds. Accounts initiated or terminated during a calendar quarter are charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be refunded unless the parties agree to other terms, and any earned, unpaid fees will be due and payable. Certain of GFA’s supervised persons are registered representatives of Osaic Wealth Inc. (CRD No. 23131) (“Osaic”), a registered broker-dealer (member FINRA and SIPC). As registered representatives of Osaic, they will earn commissions for selling securities products in this separate capacity to clients of GFA. An affiliate of Gallagher, GBS Retirement Services, Inc. (“GBSRS”), also has an arrangement with Osaic in which it will receive commissions for brokerage services provided by GFA’s supervised persons who are also registered representatives of Osaic. These arrangements present a conflict of interest because our supervised persons who are registered representatives have an 5  incentive to recommend securities products to you for the purpose of generating commissions rather than solely based on your needs. To mitigate this conflict of interest, we or our delegate require all supervised persons to ensure that any such recommendations are in the client’s best interest. Certain of GFA’s supervised persons may refer clients to GBS Insurance and Financial Services, Inc. ("GBS Insurance”), an affiliated insurance agency. These persons will earn commissions for selling insurance products in this separate capacity to clients of GFA. This presents a conflict of interest because our supervised persons who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. To mitigate this conflict of interest, we require all supervised persons who are licensed to offer insurance products to our clients to assure that the recommendation to purchase insurance is in the client’s best interest. We require all supervised persons to seek prior approval of any outside employment activity so that we can ensure that any conflicts of interest in such activities are properly disclosed. Commissions earned by these persons are separate and in addition to our advisory fees. Securities and insurance products are available through other channels and as a client you are not obligated to purchase products recommended by our supervised persons. For more information, please see Item 10 of this Brochure. GFA’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment managers and other third parties, including for example asset management fees, custodial fees, 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. Mutual funds, exchange traded funds, collective investment trusts, limited partnerships and other commingled vehicles also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to GFA’s fee, and GFA does not receive any portion of those commissions, fees, and costs. Item 6 – Performance-Based Fees and Side-By-Side Management GFA does not currently charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). If in the future GFA is compensated by the use of an incentive fee arrangements, we will comply with Rule 205- 3, under the Investment Advisers Act of 1940 (the “Advisers Act”). 6  Item 7 – Types of Clients GFA provides retirement, investment advisory/consulting and decision-making services to institutional investors, which include public and private sector employee benefit plans (including multiemployer plans), charitable institutions, foundations, endowments, labor organizations, state or municipal government entities, hospitals, non-profit organizations, private trusts, pooled funds, insurance companies and corporations or business entities. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Our asset allocation and investment manager evaluation work spans quantitative as well as qualitative considerations, including traditional modeling, economic conditions and scenarios, and an interrelated set of cash flow, operational, and other considerations. We work with clients to establish a long-term, strategic asset allocation at the “total portfolio level” that is based on a deliberate and evaluative review of the client’s investment objectives, risk tolerance and other relevant information to form a sound foundation for the overall investment program and a road map for implementing investment strategies. We discuss with clients the risks associated with equities, fixed income, and alternative strategies (such as hedge funds of funds, real estate, commodities, certain derivative transactions and private equity/debt) as well as the relative merits of each. As capital markets evolve over time and certain asset classes present compelling investment opportunities, we re-review our clients’ strategic asset allocation to make sure it remains efficient and appropriate. GFA has invested considerable resources in developing and utilizing robust asset allocation modeling software which enables us to model severe market dislocations and how client portfolios would likely react under stressed market conditions. The software enables the team to stress test portfolios and model how different asset allocations would likely react to interest rate changes, severe market swings and dislocations which cause a high degree of correlation across typically non- correlated asset classes. the client’s Communication is a key factor in assessing a client’s needs with respect to investment strategies and portfolio structures and may, from time to time, prove imperfect, although we maintain ongoing communications with our clients regarding those needs. Ascertaining a client’s tolerance for risk requires considerable judgment based on an assessment of the Committee/Board and financial position, and management’s attitudes toward risk. It is often difficult to assess attitudes toward risk because of diverse views among individuals. Our assessment of the organization’s financial position and capacity for risk (and thus, certain investment strategies) might differ from the organization’s own assessment. These needs and conversations will vary depending on plan type or investment pool. Our manager search and recommendation/selection process is designed to provide the foundation for insightful recommendations by our team and to support or, as the case 7  may be, implement prudent decision-making by or for our clients. We start by working with clients to fully define the prospective investment mandate given the overall structure of the client’s assets and liabilities and the client’s investment objectives and risk tolerance. GFA maintains a Focus List of high conviction managers that have been thoroughly vetted and evaluated by our asset class teams and Research Committee. We also recognize, however, that our clients have unique circumstances that cannot all be met by a single list. In such situations, our client teams employ a rigorous process to ensure that every manager meets our extremely high standards. We view investment manager searches as a critical function, recognizing that the cost of a “poor” decision can be extremely high. Our consulting team utilizes a number of quantitative and qualitative resources firm-wide in order to perform the search, whereby prospective investment managers compete with their peer universe of managers on a number of predetermined factors. And as discussed above, we meet in-person with key representatives of literally hundreds of investment management organizations each year. We take extensive steps to adequately evaluate prospective and current investment managers for our clients, including seeking prudently to detect shortcomings such as organizational instability, financial weakness and lack of rigor in the investment process. However, our evaluation may not detect all of the nuances of certain functions that the managers perform or fail to perform. We recognize that “non-traditional” asset classes such as hedge fund of funds strategies or other alternative investments may entail risks different from those presented by traditional asset classes. Members of the research team hold numerous in person meetings with portfolio managers responsible for alternative strategies, and at least one member of the team conducts on-site due diligence at the managers’ offices in advance of recommending such strategies to clients. In addition to meeting with the lead portfolio manager, GFA meets with numerous members of the investment team and frequently views demonstrations of proprietary investment analytics used in the management of alternative investment portfolios. We also regularly monitor the portfolio decisions and performance of such funds, and in some cases may participate on a fund’s advisory committee comprised of fund investors. Alternative asset investments may have potential for extreme loss and are not suitable for all clients. For example, real estate may expose an investor to the risk of economic downturn, as well as overbuilding (leading to declines in rental income), inadequate leasing of properties, poor management of properties, inability to sell properties quickly, and political risks (zoning issues). Hedge funds pose several key risks: limited information regarding the managers’ holdings, restrictions as to when investors can withdraw their money, investments in certain complex securities with limited liquidity (difficult to sell), use of leverage (investing borrowed money), difficulty in obtaining prices for certain investments, and high fees. Commodities may be highly volatile. Although commodities offer the potential to perform relatively well in a period of rising inflation, they 8  may sustain large losses when the economy declines. Private equity investments may pose the following risks: lack of access to invested assets for a decade or longer, dependence on good performance of public equity markets to sell investments, dependence on the manager to perform difficult functions – buying high-potential companies on favorable terms and improving their operating performance of the companies, and high fees. Investing through a commingled investment vehicle such as a limited partnership, as opposed to a separate account that holds the individual securities or a readily tradable vehicle such as a mutual fund or exchange-traded fund, can present risks distinct from the investment risks associated with the underlying investment strategy. Examples include restrictions on withdrawals from the vehicle and contractual limitations on the liability of the general partner or other entity responsible for management. The investment vehicle’s prospectus or other offering document and other governing instruments generally disclose those risks. Clients should obtain advice from competent legal counsel before investing in such vehicles. While GFA will assist clients’ counsel in their analysis, we do not provide legal advice to our clients. If we have been given investment discretion to select a particular investment vehicle for a client, we use internal and external legal resources (including, if appropriate, the client’s counsel) to analyze and, if appropriate, negotiate modifications to the documentation. Investment Discretion: GFA also manages securities for clients pursuant to agreements that identify specifically the security being managed. The client is typically an employee benefit plan, and the security typically is one that has been issued by the employer/plan sponsor of the plan or an affiliate. If our assignment includes deciding whether and on what terms to acquire the security on behalf of the plan, we engage in fundamental analysis of the issuer and the security. We also consider whether the addition of the security is consistent with the client’s Investment Policy Statement and other governing documents, and how the addition of the security affects the overall financial and, if applicable, actuarial condition of the plan. As ongoing manager of such a security, we conduct continuing fundamental analysis of the company and the security against the backdrop of the Investment Policy Statement and the client’s needs for liquidity and other individualized concerns. If the client is a participant-directed defined contribution plan subject to ERISA, and the plan explicitly provides that the investment options offered to participants must include stock or other securities issued by the employer/plan sponsor, our responsibility in these cases typically is to determine, as an independent fiduciary and “investment manager” under ERISA, whether and when, if ever, it has a duty under ERISA to sell the plan’s holdings of the security notwithstanding the provisions of the plan and participant elections to invest their plan accounts in the security. 9  Investing in securities involves risk of loss that clients should be prepared to bear. If the client is a defined contribution plan under ERISA, the client should educate the plan’s participants about the risk of loss associated with investment in securities subject to management by GFA since losses on the securities are effectively borne by the participants. Participants should be advised to give careful consideration to the benefits of a well-balanced and diversified investment portfolio. This is particularly true if the plan assets managed by GFA consists of the securities of a single issuer presented as a separate investment option to plan participants, rendering it significantly riskier than a diversified portfolio. If the securities are “qualifying employer securities” held in an employer stock fund investment option in a participant-directed plan, the plan’s holdings of the stock are not subject to the diversification requirements of ERISA’s fiduciary responsibility rules. In addition, we may have limited or no discretion to sell the plan’s holdings of the stock, depending on the terms of the plan, the agreement between GFA and the plan and applicable law. Accordingly officials or representatives of the client plan should tell participants that the value of investment in such a fund depends entirely on the investment performance of a single security (and, if the employer stock fund also includes a small amount of cash for liquidity purposes, the investment return on the cash), and the participants are therefore subject to the significant risk associated with investing in a single security as opposed to a portfolio of diversified investments. Plan fiduciaries should afford the plan and its participants the opportunity to mitigate that risk by making available to participants the opportunity to invest in a variety of different kinds of investments through an array of diversified investment options. We do not recommend primarily any particular type of security. The client bears the risk of loss on its investments. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of GFA or the integrity of our firm. Since its creation in 2008, GFA has had no involvement in any legal or disciplinary proceeding that would have been material to any client or potential client evaluating us or the integrity of our management. Item 10 – Other Financial Industry Activities and Affiliations GFA is not a registered broker-dealer and does not have an application pending to register as a broker-dealer. Certain of our employees are registered representatives of a broker-dealer, as further described below. Neither the firm nor any of its management 10  employees are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. Lastly, other than as described below or in our ADV or a consultant’s ADV 2B Brochure, neither GFA nor any of its management employees have any material relationships or arrangements with any related broker- dealer, municipal securities dealer, government securities dealer or broker, investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), other investment adviser or financial planner, futures commission merchant, commodity pool operator, commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer, or sponsor or syndicator of limited partnerships. GFA is a single-member, limited-liability company, with GBS as its single member. Itself a wholly- owned subsidiary of AJG. GBS offers expertise and guidance in all areas of benefits planning, delivery and administration for a broad range of employee benefit plans and services, including executive benefits and financial planning, actuarial, data analysis and benchmarking, retirement consulting, benefits outsourcing, and human resources services for its clients. Some consultants for GFA provide fiduciary consulting services to small, mid, and large retirement plans, including 401k, 403b, 457, pooled, multi-employer, defined benefit, and nonqualified plans. A plan sponsor client of these consultants may choose to pay such fees for services rendered to a defined contribution plan with revenue generated within the plan or with hard dollars. The client chooses the method of payment; GFA is indifferent to which method the client selects. To accommodate clients that choose to pay within the plan (via commissions), a separate wholly-owned subsidiary called GBS Retirement Services, Inc. (“GBSRS”), a limited purpose, constructive receipt, registered broker-dealer was established whose primary function is to receive those plan-generated fees arising from transactions executed by Osaic Wealth Inc. (CRD No. 23131) (“Osaic”), a registered broker-dealer (member FINRA and SIPC), an unaffiliated broker-dealer firm. GFA does not receive any of those fees. While GBSRS is registered with FINRA and is registered in Illinois, New York and Texas as an investment adviser, GBSRS cannot and does not execute or clear securities transactions and cannot and does not receive commissions from any investment manager; it receives monies only from Osaic arising from transactions the latter executes. GFA believes this structure prevents the conflicts that other broker-dealer affiliates may pose. We may have a conflict of interest in that we have an incentive to recommend commissionable securities based on the receipt of commissions, rather than based on the client’s needs. We address this conflict of interest by ensuring any such recommendations are in the client’s best interest. 11  Certain of GFA’s supervised persons are registered representatives of Osaic. As registered representatives of Osaic, they will earn commissions for selling securities products in this separate capacity to clients of Gallagher. GBSRS also has an arrangement with Osaic in which it will receive commissions for brokerage services provided by GFA’s supervised persons who are also registered representatives of Osaic. Furthermore, the percentage of commissions paid to GBSRS is based on the aggregate commissions generated by our supervised persons who are registered representatives of Osaic each calendar year and will increase when certain negotiated thresholds are reached. These arrangements present a conflict of interest because we have an incentive for supervised persons to recommend securities products to you for the purpose of generating commissions rather than solely based on your needs. We have an additional incentive for our supervised persons to recommend commissionable products to you in order to increase the percentage of commissions retained by our affiliate GBSRS. To mitigate these conflicts of interest, we require all supervised persons to ensure that any such recommendations are in the client’s best interest. Certain of GFA’s supervised persons may refer clients to GBS Insurance. These persons will earn commissions for selling insurance products in this separate capacity to clients of Gallagher. This presents a conflict of interest because our supervised persons who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. To mitigate this conflict of interest, we require all supervised persons who are licensed to offer insurance products to our clients to assure that the recommendation to purchase insurance is in the client’s best interest. We require all supervised persons to seek prior approval of any outside employment activity so that we can ensure that any conflicts of interest in such activities are properly disclosed. GFA has structured its relationship with all affiliates of GBS and AJG to prevent conflicts of interest and to preserve the objectivity and independence of Gallagher’s investment consulting and fiduciary decision-making teams and their advice, decisions and operations. Information barrier procedures have been adopted to safeguard the independence of GFA. A copy of these information barrier procedures is available in their entirety to any client or prospective client upon request. Item 11 – Code of Ethics AJG, GBS, and GFA have adopted a Code of Ethics to restrict or prohibit transactions by its employees and their family members that could create actual conflicts of interest, the potential for conflicts or the appearance of conflicts. The Code also established reporting requirements and enforcement procedures. GFA will provide a copy of the Code of Ethics to any client or prospective client upon request. 12  GFA does not typically recommend to its advisory clients that they purchase or sell individual securities other than interests in commingled investment vehicles such as mutual funds, exchange traded funds, collective trusts, limited partnerships and limited liability companies. As an independent fiduciary decision-maker or adviser, GFA does have authority to purchase or sell, or to recommend the purchase and sale of a particular security. Accordingly, the Code of Ethics includes policies and procedures that limit the ability of employees to purchase or sell certain securities. Those procedures include maintenance and distribution to all Gallagher employees of a list of companies whose securities may not be traded by a Gallagher employee or an immediate family member without advance permission from the Chief Compliance Officer or the appropriate delegated representative, as well as other restrictions. The Code of Ethics also requires that employees report all securities transactions (with narrowly-crafted exceptions related to instruments such as shares in registered open-end mutual funds, bank certificates of deposits and U.S. government securities) to the Chief Compliance Officer or the appropriate delegated representative, who uses the reports to monitor compliance with the Code of Ethics and other internal procedures. The Code of Ethics requires that each employee certify in writing that he or she has fully and accurately reported to and provided the Chief Compliance Officer or the appropriate delegated representative with statements for all personal securities accounts in which the employee holds a direct or indirect beneficial interest. GFA also has in place written procedures, as required by Section 204A of the Investment Advisers Act of 1940 to prevent the misuse by employees or other access persons of confidential or material non-public information concerning clients or potential clients. Item 12 – Brokerage Practices GFA has the authority to determine whether, when and on what terms to sell or buy specific securities only in connection with certain of its decision-making engagements. For those engagements, Gallagher and client negotiate the scope and limitations, if any, that apply to purchasing or selling specific securities. In engagements where GFA determines to buy or sell specific securities, we select the broker and negotiate the commission to be paid unless the client requests that we utilize the services of another broker. GFA suggests brokers to clients for whom we act as an investment consultant only in the following, narrow senses. First, when clients terminate one investment manager and hire a replacement, they sometimes wish to utilize a portfolio transition agent to assist in transferring and to some extent, modifying the account securities. Based on analysis of competing brokerage firms that perform that type of transition service, GFA may recommend one or more such firms to the client. Second, clients sometimes wish to utilize commission recapture, discount brokerage, soft dollar converter programs or 13  similar brokerage arrangements. Based on analysis of competing brokerage firms that offer such arrangements, GFA may recommend one or more such firms. GFA bases its recommendations on various factors and judgments, including the net commission cost to the client, the candidates' ability to provide the precise services desired, the candidates' experience with the category of securities and the relevant market, the exact terms on which such services are provided and a host of other considerations it has developed and documented over the years. Products, research and services given to GFA are not factors in making the determination. GFA does not receive compensation from whichever broker it recommends to the client, in order to preserve our objectivity. GFA does not receive client referrals or compensation of any kind from broker-dealers or other third parties in exchange for using any particular broker-dealer. investments, ongoing GFA receives research or other products or services from Osaic in connection with client securities transactions. These services can include, but are not limited to: research regarding program review, evaluation and continued recommendation of program investments, quarterly reports outlining the client’s program investment performance, services to facilitate payment of our fees from client accounts, website and associated technology to assist us with the selection of program investments and generation of investment strategy proposals and other associated documents, transition assistance, trading and model management, performance reporting, consultation with compliance, marketing and brokerage services, and discounts on financial planning and business marketing programs. Osaic may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. We do not have to pay the broker-dealer for these services and no client is charged for these services. Therefore, we receive a benefit. This presents a conflict of interest, as we have an incentive to recommend Osaic because of our existing relationship and the benefits we receive, rather than on your interest in receiving most favorable execution. We mitigate this conflict by conducting best execution reviews and through the application of our policies and procedures. We may cause clients to pay commissions that are higher than those charged by another broker-dealer to effect the same transaction. We have determined that the transaction charges incurred are reasonable in relation to the value of the services received. These products or services received may benefit all of our clients, not just those whose assets are custodied at the broker-dealer who provides the products or services. Except as explained above in herein and in Item 10, GFA does not direct trades to any affiliate of GFA , AJG or GBS and GFA does not accept or receive brokerage commissions or “soft dollars.” 14  Item 13 – Review of Accounts The frequency, type and level of reviews and factors triggering reviews depend on the specific nature of the client, the portfolio and the engagement. When an investment review is undertaken, GFA generally will focus on systems and practices regarding investment-related matters, rather than on periodically evaluating specific portfolio holdings. When overseeing investment-related matters on an ongoing basis, GFA periodically reviews reports from the custodian/master trustee. Investment performance and related reviews generally are conducted on a periodic basis. GFA meets with clients and typically issues oral or written reports on a periodic basis. These meetings and reports may address any matters subject to the supervision of GFA, pursuant to contract, including for example, asset allocation; adherence of managers to investment objectives, guidelines and policies; investment performance (on both an absolute basis and relative to relevant peers and agreed benchmarks), activities of the master trustee/custodian, such as cash management, reporting, settlement of securities transactions; new investment opportunities and strategies; brokerage practices, including “soft dollar” arrangements; and other matters. GFA generally conducts investment manager searches and evaluations as circumstances require. Item 14 – Client Referrals and Other Compensation GFA may directly compensate persons who refer clients to it. However, if applicable, we pay such compensation only through “hard dollars” and do not pay such compensation through directed brokerage involving transactions effectuated on behalf of its clients. In addition, full disclosure is made to clients, if applicable. The only compensation GFA receives comes directly from our clients for the investment services provided. We do not provide investment advice or recommendations to investment managers regarding their proprietary businesses and do not receive compensation from investment managers for doing so. However, GFA does provide performance measurement service in a non-advisory capacity to a single entity organized as a federally chartered savings bank and which is a registered investment adviser. No actual or potential conflicts are created as a result of this relationship as GFA neither recommends the use of any investment offerings from this entity to its clients nor advises any of its clients regarding this entity. Item 15 – Custody GFA does not hold physical custody of client funds or securities. We require that qualified custodians hold client assets, as fully described in Item 12 – Brokerage Practices. GFA has custody because we are granted authority, upon written consent from our clients in our agreements, to make certain third-party transfers on behalf of our clients who have 15  granted us this authority. This authority is granted to us by the client through the use of a standing letter of authorization (“LOA”) established by the client with his or her qualified custodian. The standing LOA authorizes our Firm to take specific actions pursuant to the terms of the LOA and can be changed or revoked by the client at any time. We have implemented the safeguard requirements of SEC regulations by requiring safekeeping of client funds and securities by a qualified custodian. We have further implemented procedures to comply with the requirements outlined by the SEC in its February 1, 2017 No- Action Letter to the Investment Adviser Association. GFA does have “custody’, as that term is defined by the SEC, only with respect to accounts which hold securities used as collateral for certain derivative transactions. Because it is necessary for GFA to move the collateral assets when and where they are needed, without obtaining written client instructions in every case, GFA must have a level of authority which constitutes “custody” of the assets. Under Investment Adviser’s Act Rule 206(4)-2, firms are required to hire a qualified independent accounting firm to conduct a surprise audit of these accounts on a yearly basis. Item 16 – Investment Discretion GFA accepts discretionary authority to manage securities accounts on behalf of clients pursuant to an investment management agreement that specifically describes the scope and limits on that authority. Clients may limit the authority to a particular category of investment or even to a particular security, such as employer stock. Before GFA assumes this authority, we negotiate with the client the terms of the investment management agreement to ensure that the investment authority is properly delegated, and its scope and limitations are carefully defined. GFA also obtains from the client assurance that the delegation of authority is consistent with the client’s governing instruments such as, for example, the trust agreement establishing an employee benefit plan’s fund and the Investment Policy Statement governing the client’s investment portfolio. Item 17 – Voting Client Securities A. When GFA’s Fiduciary Decision-making team is voting the proxies on behalf of its client: As an independent fiduciary, GFA is required to act at all times in the interest of the plan’s participants and beneficiaries. When Gallagher’s fiduciary decision-making discretion extends to voting proxies, we do not apply a blanket guideline to any proxy issue but consider each particular issue on its merits. Even in situations where the scope of our assignment includes the acceptance of a client’s pre-established proxy voting guideline, 16  GFA generally has a fiduciary obligation to reach its own conclusion and to override the guideline if Gallagher determines adherence to the guideline is contrary to applicable law. Our procedure for reaching a conclusion on proxy issues generally consists of the following outline: • Review proxy statement and other public documents (annual report, SEC filings, etc.) for information relevant to the issues; • Solicit views on the issues from other investment professionals such as money managers who hold the stock (that we may deem “prudent persons in like circumstances,” consistent with the ERISA standard of prudence); • Review analyses by proxy voting advisory services such as Institutional Shareholder Services and Glass Lewis; • Identify pro and con considerations relative to the viewpoint of a shareholder; • Consider appropriate considerations unique to the perspective of an ERISA covered plan (as distinct from other shareholders), if any; • For more complex issues, generally consider information in the public sphere; for example, news reports or analysis in widely financial publications which may give us additional read perspective; in • Solicit view from other shareholders that own the share in like the ERISA standard of question (that we may deem “prudent persons circumstances,” consistent with prudence); • Provide a prudent assessment of the impact on risk-return to the plan for any issue that is raised, including a review of all facts and circumstances surrounding the issue – such factors may include the economic effects of climate change and other environmental, social, or governance factors (ESG factors) on the particular investment or investment course of action; • Discuss all inputs internally and reach a conclusion; • Document our process and conclusions in writing; and, 17  • Upon approval of our investment committee, exercise the proxy vote. Shareholder votes that involve a transaction materially affecting the ownership or assets of the company that sponsors the ERISA plan may require additional financial and/or legal analysis, such as: • The price offered for the shares relative to their price before the proposed transaction was announced (i.e., the “premium”); • Assessment of the consideration offered relative to the company’s financial condition and profitability and business trends impacting the company; • Comparison of the business and financial prospects of the company in the event the transaction is approved relative to its prospects on a “stand-alone” basis; • Prospects for additional offers from third parties; • The adequacy of financing necessary to complete the transaction; • Potential obstacles to closing, such as litigation or regulatory review; and • Assessment of the process applied by the company’s Board of Directors in reviewing the bid and soliciting and evaluating competing bids. B. When Gallagher Fiduciary Advisors, LLC’s Fiduciary Decision-making team is voting the proxies of a mutual fund reorganization on behalf of the fund’s benefit plan investors (“Clients”): GFA shall conduct an independent fiduciary analysis of the reasonableness from the investment perspective of the Clients collectively of the transactions with respect to each of the funds, and based on such fiduciary analysis, direct the Company in writing whether to vote the shares of each fund held by all relevant Clients either in favor of or against the transaction with respect to that particular fund (each such direction an “Instruction” and, collectively, the “Instructions,” it being understood that GFA may provide a separate Instruction with respect to each fund covering the shares in the particular fund held by the Clients in that fund). 18  GFA’s instructions shall be based on its independent determination. Our responsibility shall be limited to the delivery of the Instructions, and it shall have no responsibility, fiduciary or otherwise, with respect to any other aspect of the funds or the transactions. It is understood and agreed that the Company, and not GFA, is responsible for casting the Clients’ votes for or against the approval of each of the transactions in accordance with the Instructions. GFA shall act independently of the Company and its affiliates at all times and shall take such actions as it deems necessary and appropriate in its sole discretion to discharge fully its duties hereunder. GFA shall complete the services described above in a timely manner. C. When Gallagher Fiduciary Advisors, LLC’s Investments practice is monitoring the proxy voting policies of third-party investment managers on behalf of its client: When serving as an investment consultant, GFA’s fiduciary duty on behalf of its client is to select third-party investment managers, monitor their performance and their fees, and make any necessary changes (including replacing the manager) when either the performance of the manager is sub-par, or their fees are unreasonable. As part of the monitoring process, GFA is charged with monitoring the third-party investment manager’s activities with respect to its proxy voting of the underlying investments. GFA shall request a copy of the proxy voting policy that the third-party manager has adopted and monitor its actions in relation to the policy. Clients may obtain a copy of GFA’s proxy voting policies and procedures upon request. Clients may also obtain information from GFA about how we voted on any proxies on behalf of their account(s). Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about GFA’s financial condition. GFA, or any of its affiliates, has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Item 19 – Requirements for State-Registered Advisers Not applicable since GFA is registered with the SEC. 19 

Item 1 – Cover Page Gallagher Fiduciary Advisors, LLC 2850 Golf Road Rolling Meadows, IL 60008 https://www.ajg.com/us/services/retirement-plan-consulting/ March 31, 2025 This Brochure provides information about the qualifications and business practices of Gallagher Fiduciary Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at 212-918-8629 or at gbs.frs.compliance@ajg.com. 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. Gallagher Fiduciary Advisors, LLC is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Gallagher Fiduciary Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. ©2025 Arthur J. Gallagher & Co. All rights reserved. i  Item 2 – Material Changes There are no changes in this ADV Part 2A (or “Brochure”) that materially change any of the services to our clients. Any changes to the text herein were intended solely to better describe our business. Our assets under management has been updated and includes balances from our recent acquisitions. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. ii  Item 3 – Table of Contents Item 1 – Cover Page ......................................................................................................... i Item 2 – Material Changes ................................................................................................. ii Item 3 – Table of Contents ................................................................................................ iii Item 4 – Advisory Business ............................................................................................... 1 Item 5 – Fees and Compensation ..................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management .............................. 13 Item 7 – Types of Clients ................................................................................................ 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................... 13 Item 9 – Disciplinary Information ..................................................................................... 16 Item 10 – Other Financial Industry Activities and Affiliations .......................................... 17 Item 11 – Code of Ethics ................................................................................................. 19 Item 12 – Brokerage Practices ........................................................................................ 20 Item 13 – Review of Accounts ........................................................................................ 21 Item 14 – Client Referrals and Other Compensation ...................................................... 21 Item 15 – Custody ........................................................................................................... 22 Item 16 – Investment Discretion ..................................................................................... 22 Item 17 – Voting Client Securities ................................................................................... 23 Item 18 – Financial Information ....................................................................................... 23 Item 19 – Requirements for State-Registered Advisers .................................................. 23 iii  Item 4 – Advisory Business Arthur J. Gallagher & Co. (“AJG”) and Gallagher Benefit Services, Inc. (“GBS”), established Gallagher Fiduciary Advisors, LLC, (“GFA”) in 2008. GFA is the registered investment adviser subsidiary of GBS, one of the world’s largest employee benefits consulting firms. GBS and GFA are owned by Arthur J. Gallagher & Co. (“AJG”), the New York Stock Exchange-listed insurance brokerage and risk management firm (trading under the symbol “AJG”). GFA provides retirement, investment advice/consulting and decision-making to institutional investors, which include public and private sector employee benefit plans (including multiemployer plans), charitable institutions, foundations, endowments, labor organizations, state or municipal government entities, hospitals, non-profit organizations, private trusts, and corporations or business entities, insurance companies and individuals. For more information regarding Gallagher’s institutional investor services, please see our separate ADV 2A Brochure for institutional investors. This Brochure provides information regarding our investment services for individuals. Investment Services Investment services are provided on a non-discretionary and discretionary basis, at the direction of the client. Clients engaging us on either basis will be asked to grant such authority upon signing the Client Agreement. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for investment services, we will meet with you at the beginning of our advisory relationship to determine your investment objectives, time horizon, risk tolerance, and other relevant information. After we meet with you, we will develop a portfolio customized to your specific needs as we understand them based on our discussions with you. This portfolio may be comprised of, but is not limited to, equities, mutual funds, fixed income and exchange-traded funds. If the client selects a discretionary basis, the client grants GFA ongoing and continuous discretionary authority to make and to enter orders with a broker-dealer for the execution of its investment recommendations in accordance with the client’s suitability information without the client’s prior approval of each specific transaction. All transactions in the clients’ account shall be made in accordance with the directions and preferences provided to GFA by the client. As part of our investment management services, we may use one or more third-party money manager(s) to manage a portion of your account on a discretionary basis. While the chosen third-party money manager(s) will provide advice on specific securities and/or other investments in connection with this service, our firm has discretionary authority to hire and fire such managers and reallocate assets among them as deemed appropriate. 1  If the client selects a non-discretionary basis, the client grants GFA ongoing and continuous non-discretionary authority to make its investment recommendations in accordance with the suitability information provided by the client. However, GFA must obtain the client’s approval of each specific recommendation prior to entering orders with a broker-dealer for the execution of its investment recommendations. We will monitor your accounts on an ongoing basis to ensure that they are meeting your investment objectives and other requirements. If any changes are needed to your investments, we will either make the changes or recommend the changes to you. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Portfolio Management Services We also offer risk-adjusted model portfolios and strategies that are designed to meet the needs of our clients. The model/strategy fee is in addition to your advisory fee and may cost up to 85 basis points, depending on the model/strategy selected. The investment management services provided by us may cost more or less than obtaining the same or similar services through an unaffiliated investment manager. No Client or advisor is under any obligation to utilize our portfolio management services. The asset allocation within our models attempts to provide consistent, risk-adjusted performance, but we cannot make any guarantees that our model allocations will produce the desired results. Results depend upon a variety of factors and risks, some of which are outlined below and many of which are beyond our control. Although we continually monitor our models, client positions are rebalanced not less frequently than quarterly. We primarily allocate client assets among various mutual funds, exchange- traded funds (“ETFs”), and individual debt securities in accordance with each client’s stated investment objectives. ETF prices, like stocks, can fluctuate over a wide range in the short term or over extended periods of time. These price fluctuations result from factors affecting individual companies, sectors or the securities market as a whole. When buying or selling an ETF, you will pay or receive the current market price, which can be more or less than the underlying net asset value of its individual holdings. There is no guarantee that the stock or bond markets or any particular mutual fund, ETF, or other security will increase in value. We tailor our advisory services to meet the needs of our individual clients, and we seek to ensure, on a continuous basis, that our clients’ portfolios are managed in a manner consistent with those needs and objectives. We consult with clients initially, at the outset of our relationship, and continually in an ongoing manner to assess each of their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their portfolios as they change over time. Clients are instructed and encouraged to promptly notify us if there are changes to their financial situations or if they wish to place any reasonable restrictions or limitations on the 2  management of their portfolios (so long as we determine that the conditions would not materially affect the performance of a management strategy or prove overly burdensome to our ability to provide our services). In our model portfolios, we offer core risk-adjusted strategies to meet the needs of our clients, such as: 1. Capital Preservation 2. Moderate Conservative 3. Moderate 4. Moderate Growth 5. Growth 6. Maximum Growth The core strategies are offered through four programs that are listed below. Custom strategies may be available for any client who feels their objectives and needs cannot be met with the other strategies above. These custom portfolios will be guided by the client’s objectives, financial and tax status, risk tolerance and other factors. Please note, the fees listed are in addition to the fees discussed earlier in this disclosure document. Our fees can be individually negotiated between clients and our investment advisor representatives and could vary based upon certain criteria, such as related accounts and relationships, account composition, pre-existing/legacy client relationship, and account retention considerations, among other factors. We encourage all clients and potential clients to discuss fees with their investment advisor representative. 1. Name: Independence a. Description: Our suite of Independence Strategies provides a turn-key approach to investing catered to smaller account balances. These Strategies are designed to gain diversified exposure to core asset classes across U.S. Stocks, Bonds, and International Stocks. Investors in the Independence Strategies utilize a single account structure to deliver a fully diversified portfolio. This enables the Investment Management Team to utilize successful managers in predominantly the mutual fund space. b. Minimum: $3,000 c. Maximum Fee: 35bps 3  2. Name: Liberty a. Description: Our suite of Liberty Strategies provides a turn-key approach to investing. These Strategies are designed to gain diversified exposure to core asset classes across U.S. Stocks, Bonds, and International Stocks. Investors in the Liberty Strategies utilize a single account structure to deliver a fully diversified portfolio. This enables the Investment Management Team to utilize successful managers in both the mutual fund and exchange traded fund (ETF) space, as well as incorporate their own proprietary strategies. b. Minimum: $25,000 to $250,000 depending on model c. Maximum Fee: 35bps 3. Name: Freedom a. Description: Our suite of Freedom Strategies provides a turn-key approach to investing. These strategies are designed to gain diversified exposure to core asset classes across U.S. Stocks, Bonds, and International stocks. Investors in the Freedom Strategies have the largest universe of investments due to the unified managed account (UMA) structure. This enables the Investment Strategy Team to utilize successful managers in both funds (mutual funds and ETFs) and separately managed account space, as well as incorporate their own proprietary strategies. b. Minimum: $100,000 to $1,000,000 depending on model c. Maximum Fee: 85bps 4. Name: TRU a. Description: Our suite of TRU Strategies provides a retirement income focused approach to investing. They are designed to deliver diversified exposure to the TRU Method mean-reversion relative valuation weighted mix across U.S. equities, fixed income, and limited international developed and emerging equities. The asset allocations for these strategies seek to follow a disciplined process to define weightings optimized for supporting sustainable retirement income and is overseen by the TRU Method investment team. Investors in the TRU Method strategies draw from a large universe of investments due to breadth of offerings on the custodial advisory platform. This enables the TRU Method investment management 4  team to utilize a large universe of passive and active managers to align the sleeve weightings with the allocation targets in operating their proprietary strategies. b. Minimum: $25,000 to $500,000 depending on model c. Maximum Fee: 35bps Financial Planning and Consulting Services GFA may provide financial planning services to Clients as part of the investment advisory engagement or as a separate engagement, depending on the Client's financial situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client's financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings and other areas of a Client's financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. GFA may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, GFA will provide a written summary of Client's financial situation, observations, and recommendations. For consulting or ad-hoc engagements, GFA may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a potential conflict between the interests of GFA and the interests of the Client. Clients are not obligated to implement any recommendations made by GFA or maintain an ongoing relationship with GFA. If the Client elects to act on any of the recommendations made by GFA, the Client is under no obligation to implement the transaction through GFA. Ultimately the Client has the discretion to decide whether to implement the plan or recommendations and takes responsibility for this decision. You are responsible for promptly notifying GFA of any material changes in the 5  information furnished by you regarding your financial situation, investment objectives, time horizon, risk tolerance and other relevant information. You may at any time place reasonable restrictions on the management of your account by notifying us of such restrictions in writing. The Client Agreement outlines the responsibilities of both the client and GFA. 6  Osaic Wealth Management Platform We offer investment management services through various types of accounts established by Osaic Wealth, Inc (“Osaic”) on its Wealth Management Platform (“WMP”). The Osaic WMP - Advisor Managed Portfolios Program (“Advisor Managed Portfolios”) provides comprehensive investment management of your assets through the application of asset allocation planning software as well as the provision of execution, clearing and custodial services through National Financial Services, Inc. (“NFS”). Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting, fund profiling and performance data, and portfolio optimization and re-balancing tools. Utilizing these tools and based on your responses to a risk tolerance questionnaire (“Questionnaire”) and discussions that you and your investment adviser representative (“IAR”) have together regarding, among other things, your personal investment objectives and goals, time horizon, risk tolerance, account restrictions, needs, personal circumstances and overall financial situation, we construct a portfolio of investments for you. Your IAR has the option to allocate your portfolio amongst a mix of stocks, bonds, options, exchange-traded funds (“ETFS”), mutual funds and other securities (“Program Investments”) which are based on your investment goals, objectives, and risk tolerance. Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. The Osaic WMP - Unified Managed Account Program (“UMA”) provides you with the opportunity to invest your assets across multiple investment strategies and asset classes by implementing an asset allocation strategy. UMA is a Wrap Account program that offers these advisory services along with brokerage and custodial services for a single, annual, asset-based advisory fee. After you discuss your financial goals and objectives with your IAR, we will recommend an asset allocation model (“UMA Model”) to you which will consist of: a) Investment Strategies serviced and created by investment managers or your IAR that generally consist of a selection of mutual funds, exchange traded products, equities, and or bonds; b) Mutual funds and ETFs (“Funds”); c) or a combination of the preceding bundled together in an investment asset allocation model. We will recommend a UMA Model to you based on your responses to a Questionnaire and discussion that we have together regarding among other things, your personal 7  investment objectives and goals, time horizon, risk tolerance, account restrictions, needs, personal circumstances and overall financial situation. In addition, you can place reasonable restrictions on investments held within your UMA account. All recommendations in the UMA are made on a discretionary basis, which means your IAR can act without your prior approval. For further details regarding the Advisor Managed Portfolios or UMA, please refer to the Osaic Advisor Managed Portfolios Wrap Fee Program Brochure or the Osaic WMP - Unified Managed Account Wrap Fee Program Brochure. We provide the relevant brochure to you prior to or concurrent with your enrollment in these programs. Please read it thoroughly before investing. Retirement Plan Rollovers When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for our services; and  Give you basic information about conflicts of interest. A conflict of interest arises when we advise clients to roll over retirement assets to accounts under our management or oversight. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we recommend that a client roll over their retirement plan 8  assets into an account under our management or oversight by GFA, we have a conflict of interest as we will earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement plan assets to an account managed by us. Investment Advisor Representatives Our firm may offer services through our network of independent investment advisor representatives (“Reps”). Reps are not GFA employees and may have their own legal business entities whose trade names and logos may be used on separate marketing materials. The Client should understand that the businesses are legal entities of the Reps and not of our firm. The Reps are under the supervision of our firm and the advisory services of the Reps are provided through our firm. A complete listing of the entities is listed on our ADV Part 1. Wrap Fee Programs Some of our accounts are offered through Osaic’s wrap fee programs as described above. Other accounts are offered through our wrap fee program that we sponsor at fidelity. The advisory fee paid by the client includes advisory services, brokerage services and custodial services in a single asset-based fee. We believe the charges and fees offered within each wrap fee program are competitive and reasonable when compared to alternative programs available through other firms. However, we make no guarantee that the aggregate cost of a particular program is lower than that which may be available elsewhere or if you were to receive these services separately. If you participate in a wrap fee program, we will provide you with a separate Wrap Fee Program Brochure explaining the program and costs associated with the program. Assets Under Management As of December 31, 2024, with respect to retail clients, GFA managed, on a discretionary basis, $ 938,663,185 in assets. Item 5 – Fees and Compensation GFA may charge fees to investment clients as a flat fee or based on a percentage of assets under management or advisement. The specific fees charged by GFA for its services will be outlined in each client’s Client Agreement. GFA’s fee schedule is up to 2.00%. Fees for the initial period of investment services are pro-rated based on the portion of the quarter remaining and billed in the month following the month in which the account was established. Fees for subsequent quarters are adjusted for deposits and 9  withdrawals in excess of $10,000 are made during the prior quarter pro-rata based on the asset value of the transaction. Either party may terminate the agreement at any time upon a written notice to the other party. Our receipt of an asset-based fee presents a conflict of interest. This is because the more assets there are in the client’s account, the more the client will pay in fees. Therefore, we have an incentive to encourage clients to increase the assets in their accounts. We address this conflict of interest by ensuring any such recommendations are in the client’s best interest. OSAIC WEALTH MANAGEMENT PLATFORM – ADVISOR MANAGED PORTFOLIOS PROGRAM Osaic offers Advisor Managed Portfolios as an account where no separate transactions charges apply, and a single fee is paid for all advisory services and transactions ("Wrap Account"). They also offer Advisor Managed Portfolios with separate advisory fees and transaction charges (“Non-Wrap Account”). As such, in addition to the quarterly account fee described below for advisory services, you will also pay separate per-trade transaction charges. You will pay a monthly or quarterly account fee, in advance, based upon the market value of the assets held in your account as of the last business day of the preceding calendar month or quarter. Your account fees are negotiable and will be debited from your account by our custodian. If you terminate your participation in this program, you will be entitled to a pro-rata refund of any prepaid monthly or quarterly fees based upon the number of days remaining in the month or quarter after the date upon which the notice of termination is received. Each of our IARs in consultation with GFA leadership negotiates his or her own account fee schedule. Mutual funds and ETFs invested in the account have their own internal fees which are separate and distinct from the program account fees (for more information on these fees, see the applicable fund prospectus). Some Fund fees include 12b-1 fees which are internal distribution fees assessed by the Fund, all or a portion of which are paid to the distributor(s) of the Funds. The Firm and your Advisory Representative do not retain 12b-1 fees paid by the Funds. In certain instances, there is an opportunity to be eligible to purchase certain mutual funds and ETFs without incurring transaction charges subject to certain conditions. 10  For details, please refer to Item 4 (No Transaction Fee Programs) of the Osaic Advisor Managed Portfolios wrap fee brochure. For complete fee details, including account fee schedule guidelines and a list of transaction charges, please see the Osaic Advisor Managed Portfolios Wrap Fee Program Brochure. OSAIC WEALTH MANAGEMENT PLATFORM – UNIFIED MANAGED ACCOUNT PROGRAM We offer UMA as an account where no separate transactions charges apply, and a single fee is paid for all advisory services and transactions ("Wrap Account"). You will pay a quarterly account fee, in advance, based upon the market value of the assets held in your account as of the last business day of the preceding calendar quarter. Your account fees are negotiable and will be debited from your account by our custodian. If you terminate your participation in this program, you will be entitled to a pro-rata refund of any prepaid quarterly fees based upon the number of days remaining in the quarter after the date upon which the notice of termination is received. Each of our IARs in consultation with GFA leadership negotiates his or her own account fee schedule. The account fees paid by client include portions paid to your Advisory Representative (“Advisory Fees”), as well as to the Firm, the custodian, and the third- party money managers selected (“Program Fees”). Advisory Fees are set independently regardless of the manager selected. Mutual funds and ETFs invested in the account also have their own internal fees (“internal fund expenses”) which are separate and distinct from the program account fees (for more information on these fees, see the applicable fund prospectus). Since fees billed to your UMA account are comprised of both Program Fees and Advisory Fees, Advisory Representatives may have an incentive to select third party money managers with lower Program Fees in order to manage the overall fee charged to you. You and your Advisory Representative should consider the overall fees and expenses, including internal fund expenses, when selecting managers and other portfolio investments. For complete fee details, including account fee schedule guidelines, please refer to The Osaic Wealth Management Platform – Unified Managed Account Wrap Fee Program Brochure, as applicable. Clients in Non-Wrap Accounts on Osaic’s WMP platform will incur transaction charges per trade in addition to the quarterly account fee. Transaction charges are generally included in the quarterly account fee for clients in Wrap Accounts on Osaic’s WMP platform. All accounts on Osaic’s WMP platform, including Wrap Accounts, may incur other ancillary charges which are not included in the quarterly account fee including IRA and Qualified Retirement Plan account maintenance and termination fees, transfer costs, margin interest, national securities exchange fees, costs associated with 11  exchanging currencies, wire transfer fees, paper confirmation fees or other fees as required by law. Clients are responsible for all additional fees, expenses and charges for which they become obligated under any separate agreement with the custodian. GFA’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment managers and other third parties, including for example asset management fees, custodial fees, 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. Mutual funds, exchange traded funds, collective investment trusts, limited partnerships and other commingled vehicles also charge internal management fees, which are disclosed in a fund’s prospectus. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to GFA’s fee, and GFA does not receive any portion of those commissions, fees, and costs. For more information on our brokerage practices, please refer to Item 12 – Brokerage Practices. The amount of the administrative fee payable to Osaic is subject to a discount if GFA maintains Advisor Managed Portfolios or UMA accounts with aggregate assets under management at target levels negotiated with Osaic. The amount of the discount is adjusted on a yearly basis. This presents a conflict of interest, as GFA has an incentive to recommend that clients open Advisory Managed Portfolios or UMA accounts in order to retain a larger amount of the total account fee paid by each client who opens an account on Osaic’s WMP platform. GFA addresses this conflict of interest by ensuring that any such recommendations are in the client’s best interest. Certain of GFA’s supervised persons are registered representatives of Osaic (CRD No. 23131), a registered broker-dealer (member FINRA and SIPC). As registered representatives of Osaic, they will earn commissions for selling securities products in this separate capacity to clients of GFA. An affiliate of GFA, GBS Retirement Services, Inc. (“GBSRS”), also has an arrangement with Osaic in which it will receive commissions for brokerage services provided by GFA’s supervised persons who are also registered representatives of Osaic. These arrangements present a conflict of interest because our supervised persons who are registered representatives have an incentive to recommend securities products to you for the purpose of generating commissions rather than solely based on your needs. To mitigate this conflict of interest, we or our delegate require all supervised persons to ensure that any such recommendations are in the client’s best interest. Certain of GFA’s supervised persons may refer clients to GBS Insurance and Financial Services, Inc. ("GBS Insurance”), an affiliated insurance agency. These persons will 12  earn commissions for selling insurance products in this separate capacity to clients of GFA. This presents a conflict of interest because our supervised persons who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. To mitigate this conflict of interest, we require all supervised persons who are licensed to offer insurance products to our clients to assure that the recommendation to purchase insurance is in the client’s best interest. We require all supervised persons to seek prior approval of any outside employment activity so that we can ensure that any conflicts of interest in such activities are properly disclosed. Commissions earned by these persons are separate and in addition to our advisory fees. Securities and insurance products are available through other channels and as a client you are not obligated to purchase products recommended by our supervised persons. For more information, please see Item 10 of this Brochure. Item 6 – Performance-Based Fees and Side-By-Side Management GFA does not charge any performance-based fees (fees based on a share of capital gains on, or capital appreciation of the assets of a client). If in the future, GFA is compensated by the use of an incentive fee arrangements, we will comply with Rule 205-3, under the Investment Advisers Act of 1940 (the “Advisers Act”). Item 7 – Types of Clients GFA provides investment services to individuals. GFA also provides retirement, investment advisory/consulting and decision-making services to institutional investors, which include public and private sector employee benefit plans (including multiemployer plans), charitable institutions, foundations, endowments, labor organizations, state or municipal government entities, hospitals, non-profit organizations, private trusts, and corporations or business entities. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss GFA utilizes different methods of analysis and investment strategies. Our asset allocation and investment evaluation work spans quantitative as well as qualitative considerations, including traditional modeling, economic conditions and scenarios, and an interrelated set of cash flow, operational, and other considerations. We work with clients to establish a long-term, strategic asset allocation at the “total portfolio level” that is based on a deliberate and evaluative review of the client’s investment objectives, risk tolerance and other relevant information to form a sound foundation for the overall investment program and a road map for implementing investment strategies. We 13  discuss with clients the risks associated with equities, fixed income, and alternative strategies (such as hedge funds of funds, real estate, commodities, and private equity/debt) as well as the relative merits of each. As the capital markets evolve over time and certain asset classes present compelling investment opportunities, we re- review our clients’ strategic asset allocation to make sure it remains efficient and appropriate. GFA continually monitors client accounts, performing periodic reviews with clients. In addition, we use tools to evaluate current investment positions as well as research potential fund replacements as additional resources. GFA has an asset allocation modeling software which enables us to model severe market dislocations and how client portfolios would likely react under stressed market conditions. Communication is a key factor in assessing a client’s needs with respect to investment strategies and portfolio structures and may, from time to time, prove imperfect, although we maintain ongoing communications with our clients regarding those needs. Ascertaining a client’s tolerance for risk requires considerable judgment based on an assessment of the client’s financial position and their attitudes toward risk. It is often difficult to assess attitudes toward risk because of diverse views among individuals. Our assessment of the client’s financial position and capacity for risk (and thus, certain investment strategies) might differ from the client’s own assessment. Investing in securities involves risk of loss that clients should be prepared to bear. GFA does not recommend primarily any particular type of security. The client bears the risk of loss on its investments. It is impossible to describe all possible types of risks which may affect investments. Among the risks are the following:  Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations.  Currency 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.  Interest Rate Risk. Movements in interest rates may directly cause prices of fixed income securities to fluctuate. For example, rising interest rates can cause “high quality, relatively safe” fixed income investments to lose principal value.  Credit Risk. If debt obligations held by an account are downgraded by ratings agencies or go into default, or if management action, legislation or other government action reduces the ability of issuers to pay principal and interest when due, the value of those obligations may decline, and an account’s value 14  may be reduced. Because the ability of an issuer of a lower-rated or unrated obligation (including particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain than for an issuer of a higher- rated obligation, lower rated and unrated obligations are generally more vulnerable than higher-rated obligations to default, to ratings downgrades, and to liquidity risk.  Purchasing Power Risk. Purchasing power risk is the risk that an investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply.  Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. For example, Treasury Bills are highly liquid, while real estate properties are not. Some securities are highly liquid while others are highly illiquid. Illiquid investments carry more risk because it can be difficult to sell them.  Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world.  Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments.  Risks Related to Investment Term. If the client requires a liquidation of their portfolio during a period in which the price of the security is low, the client will not realize as much value as they would have had the investment had the opportunity to regain its value, as investments frequently do, or had it been able to be reinvested in another security.  Business Risk. Many investments contain interests in operating businesses. Business risks are risks associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Financial Risk. Many investments contain interests in operating businesses. Excessive borrowing to finance a business’ operations decreases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. 15   Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk.  Large-Cap Stock Risk. Investment strategies focusing on large-cap companies may underperform other equity investment strategies as large cap companies may not experience sustained periods of growth in the mature product markets in which they operate.  Small/Mid-Cap Stock Risk. Investment strategies focusing on small- and mid- cap stocks involve more risk than strategies focused on larger more established companies because small- and mid-cap companies may have smaller revenue, narrower product lines, less management depth, small market share, fewer financial resources and less competitive strength.  Fixed-Income Market Risk. Economic and other market developments can adversely affect fixed-income securities markets in Canada, the United States, Europe and elsewhere. At times, participants in debt securities markets may develop concerns about the ability of certain issuers to make timely principal and interest payments, or they may develop concerns about the ability of financial institutions that make markets in certain debt securities to facilitate an orderly market which may cause increased volatility in those debt securities and/or markets.  Risks of Investment in Futures, Options and Derivatives. Such strategies present unique risks. For example, should interest or exchange rates or the prices of securities or financial indices move in an unexpected manner, we may not achieve the desired benefits of the futures, options and derivatives or may realize losses. Thus, the client would be in a worse position than if such strategies had not been used. In addition, the correlation between movements in the price of the securities and securities hedged or used for cover will not be perfect and could produce unanticipated losses.  ETF Risk. The returns from the types of securities in which an ETF invests may underperform returns from the various general securities markets or different asset classes. The securities in the underlying indexes (the “Underlying Indexes”) may underperform fixed-income investments and stock market investments that track other markets, segments and sectors. Different types of securities tend to go through cycles of out-performance and under- performance in comparison to the general securities markets. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of GFA or the 16  integrity of GFA. Since its creation in 2008, GFA has had no involvement in any legal or disciplinary proceeding that would have been material to any client or potential client evaluating GFA or the integrity of its management. Item 10 – Other Financial Industry Activities and Affiliations GFA is not a registered broker-dealer and does not have an application pending to register as a broker-dealer. Certain of our employees are registered representatives of a broker-dealer, as further described below. Neither the firm nor any of its management employees are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. Lastly, other than as described below or in our ADV or a consultant’s ADV 2B Brochure, neither GFA nor any of its management employees have any material relationships or arrangements with any related broker- dealer, municipal securities dealer, government securities dealer or broker, investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), other investment adviser or financial planner, futures commission merchant, commodity pool operator, commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer, or sponsor or syndicator of limited partnerships. GFA is a single-member, limited-liability company, with GBS as its single member. Itself a wholly- owned subsidiary of AJG, GBS offers expertise and guidance in all areas of benefits planning, delivery and administration for a broad range of employee benefit plans and services, including executive benefits and financial planning, actuarial, data analysis and benchmarking, retirement consulting, benefits outsourcing, and human resources services for its clients. Some consultants for GFA provide fiduciary consulting services to small, mid, and large retirement plans, including 401k, 403b, 457, defined benefit, and nonqualified plans. A plan sponsor client of these consultants may choose to pay such fees for services rendered to a defined contribution plan with revenue generated within the plan or with hard dollars. The client chooses the method of payment; GFA is indifferent to which method the client selects. To accommodate clients that choose to pay within the plan (via commissions), a separate wholly-owned subsidiary called GBS Retirement Services, Inc. (“GBSRS”), a limited purpose, constructive receipt, registered broker dealer was established whose primary function is to receive those plan-generated fees arising from transactions executed by Osaic, an unaffiliated broker-dealer firm. GFA does not receive any of those fees. While GBSRS is registered with FINRA and is registered in Illinois, New York and Texas as an investment adviser, GBSRS cannot 17  and does not execute or clear securities transactions and cannot and does not receive commissions from any investment manager; it receives monies only from Osaic arising from transactions the latter executes. GFA believes this structure prevents the conflicts that other broker-dealer affiliates may pose. We will have a conflict of interest in that we will have an incentive to recommend commissionable securities based on the receipt of commissions, rather than based on the client’s needs. We address this conflict of interest by ensuring that any such recommendations are in the client’s best interest. Certain of GFA’s supervised persons are registered representatives of Osaic. As registered representatives of Osaic, they will earn commissions for selling securities products in this separate capacity to clients of GFA. GBSRS also has an arrangement with Osaic in which it will receive commissions for brokerage services provided by GFA’s supervised persons who are also registered representatives of Osaic. Furthermore, the percentage of commissions paid to GBSRS is based on the aggregate commissions generated by our supervised persons who are registered representatives of Osaic each calendar year and will increase when certain negotiated thresholds are reached. These arrangements present a conflict of interest because we have an incentive for supervised persons to recommend securities products to you for the purpose of generating commissions rather than solely based on your needs. We have an additional incentive for our supervised persons to recommend commissionable products to you in order to increase the percentage of commissions retained by our affiliate GBSRS. To mitigate these conflicts of interest, we require all supervised persons to ensure that any such recommendations are in the client’s best interest. Certain of GFA’s supervised persons may refer clients to GBS Insurance. These persons will earn commissions for selling insurance products in this separate capacity to clients of GFA. This presents a conflict of interest because our supervised persons who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. To mitigate this conflict of interest, we require all supervised persons who are licensed to offer insurance products to our clients to assure that the recommendation to purchase insurance is in the client’s best interest. We require all supervised persons to seek prior approval of any outside employment activity so that we can ensure that any conflicts of interest in such activities are properly disclosed. Commissions earned by these persons are separate and in addition to our advisory fees. Securities and insurance products are available through other channels and as a client you are not obligated to purchase products recommended by our supervised persons. We recommend and assist clients in selecting the managed account programs of Osaic. If a third-party managed account program is selected for a GFA client, they will receive 18  the Form ADV Part 2A or Appendix I, as applicable, (disclosure brochure) for the managed account program. Clients are encouraged to review these disclosures to understand all material aspects of the program including relevant fees and conflicts of interest. We have a conflict of interest in that we will only use or recommend sub- advisers or other third-party managers that have a relationship with GFA and have met the conditions of our due diligence review. There may be other third-party money managers that may be suitable that we do not have a relationship with them or that may be more or less costly. To address this conflict, we consider the best interests of clients in selecting sub-advisers or third-party managers. You are under no obligation to utilize the services of the sub-advisers or third-party managers we recommend. GFA has structured its relationship with all affiliates of GBS and AJG to prevent conflicts of interest and to preserve the objectivity and independence of GFA’s investment consulting and fiduciary decision-making teams and their advice, decisions and operations. Information barrier procedures have been adopted to safeguard the independence of GFA. A copy of these information barrier procedures is available in their entirety to any client or prospective client upon request. Item 11 – Code of Ethics GFA has adopted a Code of Ethics to restrict or prohibit transactions by its employees and their family members that could create actual conflicts of interest, the potential for conflicts or the appearance of conflicts. The Code also established reporting requirements and enforcement procedures. GFA will provide a copy of the Code of Ethics to any client or prospective client upon request. GFA does not typically recommend to its advisory clients that they purchase or sell individual securities other than interests in commingled investment vehicles such as mutual funds, collective trusts, limited partnerships and limited liability companies. As an independent fiduciary decision-maker or adviser, GFA does have authority to purchase or sell, or to recommend the purchase and sale of a particular security. Accordingly, the Code of Ethics includes policies and procedures that limit the ability of employees to purchase or sell certain securities. Those procedures include maintenance and distribution to all GFA employees of a list of companies whose securities may not be traded by a GFA employee or an immediate family member without advance permission from the Chief Compliance Officer or the appropriate delegated representative, as well as other restrictions. The Code of Ethics also requires that employees report all securities transactions (with narrowly-crafted exceptions related to instruments such as shares in registered open- end mutual funds, bank certificates of deposits and U.S. government securities) to the Chief Compliance Officer or the appropriate delegated representative, who uses the reports to monitor compliance with the Code of Ethics and other internal procedures. The Code of Ethics requires that each employee certify in writing that he or she has fully 19  and accurately reported to and provided the Chief Compliance Officer or the appropriate delegated representative with statements for all personal securities accounts in which the employee holds a direct or indirect beneficial interest. GFA also has in place written procedures, as required by Section 204A of the Investment Advisers Act of 1940 to prevent the misuse by employees or other access persons of confidential or material non-public information concerning clients or potential clients. Item 12 – Brokerage Practices GFA generally recommends that investment clients utilize the brokerage and clearing services of Osaic. Prior to engaging GFA to provide investment services, clients will be required to enter into a formal Client Agreement with our firm setting forth the terms and conditions under which GFA will manage the client's assets, and a separate custodial agreement with the designated broker-dealer. We consider a wide range of factors, including but not limited to, fees and expenses, quality of services, responsiveness, financial strength, and stability of the provider, and availability of tools that assist us in helping our clients. GFA receives research or other products or services from Osaic in connection with client securities transactions. These services can include, but are not limited to: research regarding program investments, ongoing review, evaluation and continued recommendation of program investments, quarterly reports outlining the client’s program investment performance, services to facilitate payment of our fees from client accounts, website and associated technology to assist us with the selection of program investments and generation of investment strategy proposals and other associated documents, performance reporting, trading and model management, transition assistance, consultation with compliance, marketing and brokerage services, and discounts on financial planning and business marketing programs. Osaic may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. We do not have to pay the broker-dealer for these services and no client is charged for these services. Therefore, we receive a benefit. This presents a conflict of interest, as we have an incentive to recommend Osaic because of our existing relationship and the benefits we receive, rather than on your interest in receiving most favorable execution. We mitigate this conflict by conducting best execution reviews and through the application of our policies and procedures. We may cause clients to pay commissions that are higher than those charged by another broker-dealer to effect the same transaction. We have determined that the transaction charges incurred are reasonable in relation to the value of the services received. These products or services received may benefit all of our clients, not just those whose assets are custodied at the broker- dealer who provides the products or services. GFA does not receive client referrals or compensation of any kind from broker- dealers 20  or other third parties in exchange for using any particular broker-dealer. We routinely recommend that you direct our firm to execute transactions through broker-dealers with which we have a business relationship. Not all investment advisers recommend that a client use a particular broker-dealer. As such, we may be unable to achieve the most favorable execution of your transactions, and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. If clients prefer to utilize their own broker-dealer, we will not be able to provide investment services to those clients. We do not aggregate the purchase or sale of the same securities for various client accounts. Accordingly, you may pay different prices for the same securities transactions than other clients pay. Item 13 – Review of Accounts GFA’s investment adviser representatives monitor accounts on an ongoing basis and conduct account reviews at least annually or as agreed upon with individual clients. Reviews consist of determining whether your portfolios and strategies continue to align with your investment goals and objectives. All investment clients are advised that it remains their responsibility to advise GFA of any changes in their investment objectives and/or financial situation. GFA’s investment adviser representatives may conduct account reviews on an other than periodic basis upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections, economic or political events and client request. Clients are provided, at least quarterly (unless the client elects otherwise), with written summary account statements directly from the broker-dealer for the client accounts. From time to time, GFA may also provide separate written reports summarizing account activity and performance to clients. Clients are encouraged to compare the information on any such reports prepared by GFA against the information in the statements provided directly from the broker-dealer and alert GFA of any discrepancies. Item 14 – Client Referrals and Other Compensation GFA may directly compensate persons who refer clients to it. However, if applicable, we pay such compensation only through “hard dollars” and do not pay such compensation through directed brokerage involving transactions effectuated on behalf of its clients. In addition, full disclosure is made to clients, if applicable. Compensating third parties for client referrals presents a conflict of interest, as the third party has an incentive to recommend our firm in exchange for the compensation. We address this 21  conflict of interest through disclosure in this Brochure and at the time of the recommendation, in accordance with applicable regulations. The only compensation GFA receives comes directly from our clients for the investment services provided. We do not provide investment advice or recommendations to investment managers regarding their proprietary businesses and do not receive compensation from investment managers for doing so. However, GFA does provide performance measurement service in a non-advisory capacity to a single entity organized as a federally chartered savings bank and which is a registered investment adviser. No actual or potential conflicts are created as a result of this relationship as GFA neither recommends the use of any investment offerings from this entity to its clients nor advises any of its clients regarding this entity. Item 15 – Custody GFA does not hold physical custody of client funds or securities. We require that qualified custodians hold client assets, as fully described in Item 12 – Brokerage Practices. GFA has custody because we are granted authority, upon written consent from our clients in our Client Agreement, to deduct the management fees directly from client accounts and to delegate that authority to a financial institution. We also have custody due to our standing authority to make third-party transfers on behalf of our clients who have granted us this authority. This authority is granted to us by the client through the use of a standing letter of authorization (“LOA”) established by the client with his or her qualified custodian. The standing LOA authorizes our Firm to disburse funds to one or more third parties specifically designated by the client pursuant to the terms of the LOA and can be changed or revoked by the client at any time. We have implemented the safeguard requirements of SEC regulations by requiring safekeeping of client funds and securities by a qualified custodian. We have further implemented procedures to comply with the requirements outlined by the SEC in its February 1, 2017, No- Action Letter to the Investment Adviser Association. Account statements are delivered directly from the qualified custodian to each client at least quarterly. Clients should carefully review those statements and are urged to compare the statements against any reports received from us. When clients have questions about their account statements, they should contact us or the qualified custodian preparing the statement. Item 16 – Investment Discretion GFA accepts discretionary authority to manage securities accounts on behalf of clients pursuant to the Client Agreement that specifically describes the scope and limits on that authority. With discretionary authority our firm is authorized to execute securities transactions for the client without first having to seek the client’s consent for each 22  transaction. Clients who engage the firm on a discretionary basis may, at any time, impose reasonable restrictions in writing on GFA’s discretionary authority. Clients may also request that we manage their investments on a non-discretionary basis. This means that we will seek the client’s consultation prior to implementing investment decisions. Item 17 – Voting Client Securities GFA does not vote or assist in voting proxies for our individual clients. Certain third- party managers selected or recommended by GFA may vote proxies for clients, as further described in the manager’s respective Brochure. Therefore, except in the event a third-party manager votes proxies, clients will receive proxies or other solicitations directly from the custodian and are responsible for making all decisions relating to any such matters. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about GFA’s financial condition. GFA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Item 19 – Requirements for State-Registered Advisers This section is not applicable since GFA is registered with the SEC. 23