Gc Wealth Management Ria, LLC

GC Wealth Brochure 1 Item 1. Cover Page GC WEALTH MANAGEMENT RIA, LLC FORM ADV PART 2A: FIRM BROCHURE 20 University Road, 4th Floor Cambridge, Massachusetts 02138 Phone: (617) 362-3161 Website: www.generalcatalyst.com/wealth March 31, 2026 This brochure (“Brochure”) provides information about the qualifications and business practices of GC Wealth Management RIA, LLC (“GC Wealth”). If you have any questions about the contents of this brochure, please contact us at 617-362-3161 or GCWcompliance@generalcatalyst.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. information about GC Wealth is also available on the SEC’s website at Additional www.adviserinfo.sec.gov. An investment adviser’s registration with the SEC does not imply a certain level of skill or training.  GC Wealth Brochure 2 Item 2. Material Changes GC Wealth filed its most recent annual updating amendment to this Brochure on March 27, 2025. Since our last annual filing, we have made the following material changes to our business practices and disclosures: ● Item 4 – Updated information regarding GC Wealth’s asset under management. ● Item 5 – Updated information regarding fees. ● Item 8 – Updated information and disclosure regarding methods of analysis, investment strategies, business practices and the risks related to such activities. ● Item 11 – Updated information regarding the business practices of GC Wealth and its affiliates and conflicts of interest that arise in the course of GC Wealth’s investment and other activities, and related compliance policies and procedures developed by GC Wealth to address such business practices and conflicts. ● Item 12 – Reflected the addition of Charles Schwab & Co., Inc. as an available custodian and to disclose associated conflicts of interest. 2  GC Wealth Brochure 3 Item 3. Table of Contents Item 1. Cover Page 1 Item 2. Material Changes 2 Item 3. Table of Contents 3 Item 4. Advisory Business 4 Item 5. Fees and Compensation 6 Item 6. Performance-Based Fees and Side-by-Side Management 8 Item 7. Types of Clients 8 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss 8 Item 9. Disciplinary Information 23 Item 10. Other Financial Industry Activities and Affiliations 23 Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading 24 Item 12. Brokerage Practices 27 Item 13. Review of Accounts 30 Item 14. Client Referrals and Other Compensations 31 Item 15. Custody 31 Item 16. Investment Discretion 32 Item 17. Voting Client Securities 32 Item 18. Financial Information 33  GC Wealth Brochure 4 Item 4. Advisory Business Overview GC Wealth is an asset management firm providing tailored financial advisory and wealth management services. GC Wealth provides investment and advisory services to individuals and institutions. GC Wealth is a Delaware limited liability company established in 2023 and wholly owned, indirectly through various intermediate entities, by General Catalyst Group Management, LLC ("General Catalyst"), with principal ownership held by David Fialkow, Hemant Taneja, and Ken Chenault. The firm provides investment individuals and management, financial planning, and family advisory services to institutions. Investment Management Services GC Wealth provides tailored investment and wealth management services to a broad range of clients, including ultra-high and high net worth individuals, families, trusts, estates, foundations, endowments, charitable organizations, corporations, and other business entities (each, a "Client"), pursuant to an investment management agreement ("IMA"). Portfolios are primarily managed on a discretionary basis, though non-discretionary arrangements are available in limited circumstances. In all cases, the firm delivers personalized solutions shaped by each client's specific goals, risk tolerance, and liquidity needs. The firm invests across a broad mix of traditional and alternative assets, including mutual funds, exchange-traded funds, public equities, fixed income, cash-equivalent instruments, currencies, real assets, natural resources, privately offered securities, options, futures, warrants, swaps and forwards, and commodities. GC Wealth also recommends private investments such as venture capital, private equity, and hedge funds. These private fund investments are made through both affiliated and unaffiliated vehicles, including private funds managed by General Catalyst ("GC Funds"). investment advisers Additionally, GC Wealth has entered, and expects to enter into sub-advisory agreements ("Independent for separately managed accounts with other Managers"). Clients can choose to enter into agreements directly with Independent Managers. While the firm conducts due diligence on and monitors these managers, it does not make individual security selections for sub-advised accounts. Wealth management services also include ongoing monitoring of the client's portfolio, including any existing securities, managers, or funds that were not recommended by GC Wealth but that the client has directed one of the firm's investment representatives ("Wealth Managers") to retain as part of their account(s). Clients may impose reasonable investment restrictions, subject to the firm's approval. Financial Planning Services GC Wealth provides collaborative financial planning services to high-net-worth and ultra- high-net-worth clients. By assessing each client's financial situation, goals, and objectives,  GC Wealth Brochure 5 GC Wealth personnel develop tailored plans designed to achieve long-term outcomes. Depending on the client's needs, services may include: Insurance and risk management, ● Retirement and education planning, ● Estate and wealth transfer coordination, ● ● Asset allocation review, ● Cash management and certain treasury services, ● Philanthropic planning, ● Business succession, ● Equity compensation planning. While GC Wealth provides tax education and coordinates insurance needs, it does not provide legal, tax, or accounting advice. Family Advisory Services GC Wealth provides comprehensive family office and advisory services, including entity structuring and layering, next-generation wealth education, and customized multi-entity investment performance reporting for private holdings with relevant benchmark comparisons. Other offerings include: ● Administrative Support: Coordination of bill pay services through third-party providers, preparation of customized CPA-ready documentation, ongoing record management, and managerial support. ● Specialized Coordination: Health and property/casualty insurance coordination, as well as the arrangement of lending solutions, including securities-based lending and custom credit facilities. ● Concierge Referrals: Facilitation of access to third-party providers for travel, luxury experiences, real estate services, and art or collectibles management. Founders Membership Through its Founders Membership, GC Wealth provides a specialized engagement for entrepreneurs and executives focused on equity compensation, tax strategy, and foundational estate planning. This program serves as an entry point for individuals in a investment reporting and strategic wealth-building phase, offering consolidated consultation while providing a seamless transition into comprehensive wealth management as their assets and advisory needs grow. As of December 31, 2025, GC Wealth has $5.8 billion in assets under management.  GC Wealth Brochure 6 Item 5. Fees and Compensation Client Fees GC Wealth charges advisory fees ("Advisory Fees") as described in each Client's agreement. Fee structures include an annual asset-based percentage rate, a tiered/tranche-based fee on asset market value, or a flat fee. Fees are generally assessed on accrued dividends and interest. Advisory Fees are prorated and generally billed quarterly either in advance or in arrears based on the market value of fee-eligible assets as of the last business day of the prior quarter (or the last known market value if current pricing is unavailable). Mid-quarter fee changes take effect at the start of the next billing quarter. GC Wealth may adjust previously billed amounts in a subsequent quarter if the Client's withdrawals or contributions during the prior quarter equaled or exceeded $100,000. Fees are deducted from Client assets or paid directly by the Client. GC Wealth typically requires an annual Advisory Fee minimum for separate account services, as specified in the IMA. The annual Advisory Fee will not exceed 1.5% of assets under management. GC Wealth reserves the right to adjust or waive the minimum and to impose an initial set-up fee. GC Wealth may, in its sole discretion, waive or negotiate different fee rates based on factors such as the Client's circumstances, service level, anticipated assets, dollar amount managed, the broader relationship with GC Wealth or its affiliates, employee discounts, and related-account householding. The existence of negotiable fee arrangements means that similarly situated clients may be charged different rates, and no Client should assume that the fee schedule applied to their account is the same as that applied to any other Client of the firm. Financial Planning and Consulting Services GC Wealth charges negotiable fixed fees for financial planning and consulting, typically payable before work begins. If the engagement is terminated before delivery, the Client may request a refund, which GC Wealth may deny or reduce to offset work already performed. GC Wealth may waive all or part of these fees at its discretion. Founders Membership The Founders Membership carries an annual fee of $10,000 for a two-year term, though this fee is currently waived for members participating in the program's pilot phase. GC Wealth reserves the right to implement a future fee structure with prior written notice, and no fees will be collected without the member’s express written consent and right to terminate the relationship.  GC Wealth Brochure 7 Family Advisory Services An additional fee is assessed where a client engagement includes Family Advisory services. This fee is charged in addition to the investment management fee and is determined based on the scope and complexity of the services provided. The Family Advisory fee and its terms are disclosed and agreed upon in the client's agreement. Pooled Investment Vehicles Investments through an advisory account into private equity, venture capital, credit, hedge, real estate, or other pooled vehicles (including GC Funds) involve multiple layers of fees: Advisory Fees at the account level and separate fees at the fund level payable to the fund's manager and service providers, which may include GC Wealth GC Wealth or GC Wealth affiliates. Investments through unaffiliated feeder funds will carry the feeder's own fees in addition to the underlying fund's fees. Each additional layer of fees reduces net returns. Other Fees and Expenses Clients bear all fees and expenses beyond Advisory Fees, including custodial fees, transaction costs, mutual fund expenses, Independent Manager fees, commissions, wire transfer fees, access and platform fees, investor servicing fees, valuation fees, interest, and taxes except for accounts enrolled in our Advisor Billing program, where GC Wealth pays certain transaction fees as described in Item 12. GC Wealth may also charge separately for non-advisory services (e.g., charitable giving planning) under separate agreements. Independent Managers Clients incur indirect costs through Independent Managers, including custodial fees, transaction costs, commissions, wire transfer and servicing fees, interest, taxes, and fees associated with underlying investment managers in fund-of-funds structures. These managers may not select the lowest-cost mutual fund share class for which a Client is eligible. For put-writing strategies, the Independent Manager charges an additional asset- based fee on the mandate size, expressed in dollar or contract-based terms (with contract values derived from option strike prices and updated quarterly). Referral Fees GC Wealth receives referral fees under agreements with unaffiliated entities, including insurance providers. Wealth Managers who make such referrals also receive a portion of these fees, creating a conflict of interest. This conflict is addressed through disclosure in this Brochure and at the time the Client signs the engagement letter.  GC Wealth Brochure 8 Wealth Manager Compensation A portion of Advisory Fees is allocated to the Client's Wealth Manager(s), with a higher percentage generally credited for self-sourced accounts than internally referred ones. Because Client fees factor into Wealth Manager compensation, Wealth Managers have a financial incentive not to reduce fees. Wealth Managers who discount significantly below GC Wealth's guidelines receive reduced payouts, incentivizing pricing at or above standard levels. GC Wealth may change its compensation methods, including reducing or denying payouts, without prior notice. This section is a summary qualified in its entirety by applicable governing documents, including each Client's IMA, and does not preclude different terms for future arrangements. Item 6. Performance-Based Fees and Side-by-Side Management GC Wealth does not charge performance-based fees for its investment advisory services. In certain accounts or strategies, third-party fund managers (which may include affiliates of GC Wealth) earn performance-based compensation with respect to certain investments held by Clients. Performance-based compensation creates a conflict of interest in that it could provide an incentive for third-party fund managers to make more speculative investments than it might otherwise make. Third-party fund manager performance-based fees are addressed in Item 8 disclosure under the Underlying Fund Risk section. Item 7. Types of Clients GC Wealth generally provides investment advice to: ultra-high net worth and high net individuals, families, trusts, estates, foundations, endowments, charitable worth organizations, corporations and other business entities. GC Wealth does not have a minimum account size for Clients but anticipates that they typically will have greater than $1,000,000 in investable assets. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies fees, and minimum Wealth Managers provide investment advice through the selection of individual securities or by allocating portfolios to Independent Managers. Based on the investment objectives of each Client, GC Wealth uses a variety of methods, including Independent Manager reputation, client service, investment philosophy, stability and continuity of management, performance under varying market conditions, investment requirements, to analyze the investment strategies and asset allocations appropriate for each Client. This information will be obtained from business publications, tracking organizations, industry sources, and other sources. Client funds will be invested by the  GC Wealth Brochure 9 Wealth Manager managing each Client account and are subject to the methods of analysis used by such Wealth Managers. GC Wealth seeks to analyze Clients’ financial situations that may take into account several factors and considerations including, but not limited to, defined objectives, tax impact, risk tolerance, time horizon, liquidity needs and other suitability factors. Wealth Managers seek to use their experience and judgment to construct the appropriate investment strategies and allocations based on this analysis. It is important that Clients notify GC Wealth immediately with respect to material changes to their financial circumstances including, for example, any income expectation changes, tax status, or employment. While GC Wealth seeks to maintain portfolio flexibility to react to changes in markets, investment decisions and asset allocation recommendations are generally made with a long-term outlook consistent with each Client’s long-term objectives. Wealth Managers regularly monitor risk levels in Client accounts and portfolios in an effort to ensure continuity with the mutually agreed risk objectives and take advantage of the natural volatility of markets to rebalance portfolios accordingly. GC Wealth selects and monitors investments based on its ongoing operational and investment due diligence. GC Wealth’s pragmatic approach to alternative investments and a constantly expanding universe of potential solutions may dictate using certain strategies and approaches when GC Wealth believes it may offer improved risk-adjusted and cost- effective returns for Clients. The description above is neither a comprehensive list or description, and GC Wealth can utilize additional or a combination of other methods or strategies in developing its advice and providing advisory services. Additionally, a more comprehensive description of the risks of any specific investment can be found in the corresponding offering documents. General Risks GC Wealth supports its investment strategies with risk management procedures intended to keep portfolios in conformity with Client objectives. Prospective Clients should be aware that no assurance can be given that risk frameworks employed by GC Wealth will achieve their objectives and prevent or otherwise limit substantial losses. No assurance can be given that the risk management techniques will accurately predict future trading patterns or the manner in which investments are priced in financial markets in the future. Risks for relevant products are more fully described in such products’ offering and/or governing documents. Certain risks apply specifically to particular investment strategies or investments in different types of securities or other investments that Clients should be prepared to bear. The risks involved for different Client accounts or funds will vary based on a Client’s investment strategy and the type of securities or other investments held in the Client’s account or the fund. The following are descriptions of various primary risks related to the investment strategies used by GC Wealth. Not all possible risks are described below. Investing in securities involves a risk of loss that Clients should be prepared to bear,  GC Wealth Brochure 10 including loss of Clients’ original principal. Past performance is not indicative of future results; therefore, Clients should not assume that future performance of any specific investment or investment strategy will be profitable. GC Wealth does not provide any representation or guarantee that Clients’ goals will be achieved. In addition to general investment risks, there are additional material risks associated with the types of strategies and private funds in which Clients invest from time to time. Artificial Intelligence and Machine Learning. Recent technological advances in artificial intelligence and machine learning technologies (collectively, “AI Technologies”), as well as the rapid growth and widespread use thereof, have the potential to pose risks to GC Wealth. AI Technologies have the potential to result in significant and disruptive changes in companies, sectors or industries, including those in which Clients invest, and any such changes could create new and unpredictable operational, legal and/or regulatory risks. To the extent competitors of GC Wealth make more efficient or extensive use of AI Technologies, there is a possibility that such competitors will gain a competitive advantage. Many jurisdictions have passed or are considering laws and regulations concerning AI Technologies, which could adversely affect GC Wealth and its operations. Additionally, GC Wealth could be further exposed to the risks of AI Technologies if third- party service providers or any counterparties, whether or not known to GC Wealth, use AI Technologies in their business activities. GC Wealth will not be able to control the use of AI Technologies in third-party products or services, including those provided by GC Wealth’s and its affiliates’ service providers. The use of AI Technologies poses various risks related to confidentiality, privacy and cybersecurity. Additionally, GC Wealth and GC Wealth Personnel use AI Technologies in connection with GC Wealth’s business activities and reserves the right to use such AI Technologies with respect to GC Wealth’s investment activities. AI Technologies are highly reliant on the accuracy, adequacy, completeness and objectivity of their underlying data, and any inaccuracies, deficiencies or biases in this data could lead to errors affecting GC Wealth’s decision-making and investment processes. AI Technologies and their applications, including in the financial sector, continue to develop rapidly, and it is impossible to predict the future risks that have the potential to arise from such developments. Any of the foregoing factors could have a material and adverse effect on GC Wealth. AI Technologies are generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that AI Technologies use to operate. Even where AI Technologies are utilizing accurate data, they may, nonetheless, output results that contain, in whole or in part, inaccurate information, which may be difficult or impossible to identify, and it may be difficult or impossible to modify such AI Technologies to eliminate these occurrences. Additionally, the ongoing development, maintenance and operation of AI Technologies is expensive and involve unforeseen difficulties including material performance complex, and may problems and undetected defects or errors. Asset Class Risk. Securities in an asset class in a portfolio have in the past and likely will in the future underperform in comparison to the general securities markets, a particular securities market, or other asset classes.  GC Wealth Brochure 11 Changes in Environment. Clients’ investment programs are intended to extend over a long period of time, during which the business, economic, political, regulatory, legal, and technology environment within which Clients’ investments operate are expected to undergo substantial changes, some of which may be adverse to Clients. There can be no assurance that investment strategies developed and implemented in the current market will remain appropriate as market conditions change. In addition, there is no guarantee that GC Wealth will be able to keep up with developing market trends or other changes in the investment landscape. Returns to Clients will depend upon the successful evolution of Clients’ investment strategies to address changes in market conditions over time. GC Wealth (together with its affiliates, as applicable) will potentially have the exclusive right and authority (within limitations set forth in the applicable IMA) to determine the manner in which Clients shall respond to such changes. The investment sourcing, selection, management and liquidation strategies and procedures exercised in the past by members of GC Wealth with respect to Clients may not be successful, or even practicable, during extended periods. Commodity Risk. Negative changes in a commodity market could have an adverse impact on the value of commodity-linked investments including companies that are susceptible to fluctuations in commodity markets. The value of commodity-linked investments has in the past and likely will in the future be affected by changes in overall market movements, taxation, terrorism, nationalization or expropriation, commodity index volatility, changes in interest rates, or factors affecting a particular industry or commodity, such as, weather (e.g., drought, flooding), livestock disease, embargoes, tariffs and international economic, political and regulatory developments. The prices of sector commodities (e.g., energy, metals, agriculture and livestock) have in the past and likely will in the future fluctuate widely due to factors such as changes in value, supply and demand and governmental regulatory policies. Counterparty Risk. Transactions, including certain derivative transactions, entered into directly with a counterparty are subject to the risks that a counterparty will fail to perform its obligations in accordance with the agreed terms and conditions of a transaction. A counterparty could become bankrupt or otherwise fail to perform its obligations due to financial difficulties, resulting in significant delays in obtaining any recovery in a bankruptcy or other reorganization proceeding or no recovery in such circumstances. Credit/Default Risk. Debt issuers and other counterparties of fixed income securities or instruments could default on their obligation to pay interest, repay principal or make a margin payment, or default on any other obligation. Additionally, the credit quality of securities or instruments could deteriorate (e.g., be downgraded by ratings agencies), which could impair a security’s or instrument’s liquidity and decrease its value. Currency Risk. Currencies have in the past and likely will in the future be purchased or sold for a portfolio through the use of forward contracts or other instruments. A portfolio that seeks to trade in foreign currencies has in the past and likely will in the future have limited access to certain currency markets due to a variety of factors including government regulations, adverse tax treatment, exchange controls, and currency convertibility issues. A portfolio has in the past and likely will in the future hold investments  GC Wealth Brochure 12 denominated in currencies other than the currency in which the portfolio is denominated. Currency exchange rates can be volatile, particularly during times of political or economic unrest or as a result of actions taken by central banks. A change in the exchange rates has in the past and likely will in the future produce significant losses to a portfolio. Cyber Security and Fraud Risk. GC Wealth and its clients are increasingly dependent on digital technologies, making portfolios susceptible to operational and information security risks. Cybersecurity incidents—ranging from deliberate attacks to unintentional data breaches—can result in unauthorized access to systems, misappropriation of assets, data corruption, or operational disruptions like denial-of-service attacks. A successful breach of GC Wealth’s systems or those of its third-party service providers could lead to the theft of client funds or sensitive data, regulatory penalties, reputational harm, and significant remediation costs. Furthermore, both GC Wealth and its clients face substantial fraud risk, including business email compromise, identity theft, and sophisticated phishing schemes. These fraudulent activities can result in the permanent loss of capital for the client and legal or financial liability for the firm. Similar risks apply to the issuers of securities and Independent Manager within a portfolio; failures at these levels can cause investments to lose value or become illiquid. While GC Wealth maintains administrative and technical safeguards, there is no guarantee that these measures will prevent all cyber-attacks or fraudulent activities. Derivative Risk. Investments in derivatives, or similar instruments, including but not limited to, options, futures, options on futures, forwards, participatory notes, swaps, structured securities, tender-option bonds and derivatives relating to foreign currency transactions, which can be used to hedge a portfolio’s investments or to seek to enhance returns, entail specific risks relating to liquidity, leverage and credit that will reduce returns and/or increase volatility. Losses in a portfolio from investments in derivative instruments can result from the potential illiquidity of the markets for derivative instruments, the failure of the counterparty to fulfill its contractual obligations, the portfolio receiving cash collateral under the transactions and some or all of that collateral being invested in the market, or the risks arising from margin posting requirements and related leverage factors associated with such transactions. In addition, many jurisdictions globally have proposed or adopted new regulations for derivatives transactions. New regulations could make derivatives more costly, limit the availability of derivatives, or otherwise adversely affect the value or performance of derivatives. Digital Assets Risk. Clients may choose to establish and maintain cryptocurrency/digital asset holding accounts through GC Wealth’s platform relationships with custodians. Investing in cryptocurrency involves a high degree of risk and may not be suitable for all clients. Digital assets are subject to extreme price fluctuations. Unlike traditional currencies or securities, their value can drop to zero in a short period. Cryptocurrency markets are currently subject to less regulatory oversight than traditional equity or fixed- income markets, which may increase the risk of fraud or market manipulation. While Fidelity provides institutional-grade custody, digital assets are susceptible to unique cyber risks, including hacking, loss of private keys, or platform vulnerabilities. There may be periods where it is difficult or impossible to liquidate a position due to market closures,  GC Wealth Brochure 13 platform outages, or a lack of buyers. The tax treatment of digital assets is evolving and complex. Clients are responsible for understanding the tax implications of their transactions. Distressed Securities. Investments in companies that are in poor financial condition, lack sufficient capital or are involved in bankruptcy or reorganization proceedings face the unique risks of lack of information with respect to the issuer, the effects of bankruptcy laws and regulations and greater market volatility than is typically found in other securities markets. As a result, investments in securities of distressed companies involve significant risks that could result in a portfolio incurring losses with respect to such investments. investment, Emerging Markets Risk. Investments in emerging markets are potentially subject to a greater risk of loss than investments in more developed markets, as they are more likely to experience inflation risk, political turmoil and rapid changes in economic conditions. Investing in the securities of emerging markets involves certain considerations not typically associated with investing in more developed markets, including but not limited to, the small size of such securities markets and the low volume of trading (possibly resulting in potential lack of liquidity and in price volatility), political risks of emerging markets including unstable governments, government intervention in securities or currency markets, nationalization, restrictions on foreign ownership and laws preventing repatriation of assets and legal systems that do not adequately protect property rights. Further, emerging markets can be adversely affected by changes to the economic health of certain key trading partners, such as the U.S., regional and global conflicts, terrorism and war. Emerging markets often have less uniformity in accounting and reporting requirements, unreliable securities valuation and greater risk associated with custody of securities. Economies in these regions may also be more susceptible to natural disasters (including earthquakes and tsunamis), or adverse changes in climate or weather. In addition, certain countries in this region with less established health care systems have experienced outbreaks of pandemic or contagious diseases from time to time, including, but not limited to, coronavirus, avian flu, and severe acute respiratory syndrome. The risks of such phenomena and resulting social, political, economic and environmental damage (including nuclear pollution) cannot be quantified. Economies in which agriculture occupies a prominent position, and countries with limited natural resources (such as oil and natural gas), may be especially vulnerable to natural disasters and climatic changes. Equity Securities Risk. Equity securities are subject to changes in value and their values can be more volatile than other asset classes. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and the industry in which the issuer securities are subject to stock risk. Historically, U.S. and non-U.S. stock markets have experienced periods of substantial price volatility and will do so again in the future. Financial Institution Risk; Distress Events. An investment by a Client is subject to the risk that one of the banks, brokers, hedging counterparties, lenders, or other custodians (each, a “Financial Institution”) of some or all of Clients’ assets fails to timely perform its obligations or experiences insolvency, closure, receivership or other financial distress or  GC Wealth Brochure 14 difficulty (each, a “Distress Event”). Distress Events can be caused by a variety of factors, including eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance, or accounting irregularities. If a Financial Institution experiences a Distress Event, GC Wealth, a Client or one of its investments may not be able to access deposits, borrowing facilities or other services, either permanently or for an extended period of time. Although assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation, in the case of banks, and the Securities Investor Protection Corporation, in the case of certain broker-dealers, amounts in excess of the relevant insurance are subject to risk of total loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose increased risk of loss. While in recent years governmental intervention has often resulted in additional protections for depositors and counterparties during Distress Events, there can be no assurance that such intervention will occur in a future Distress Event or that any such intervention undertaken will be successful or avoid the risks of loss, substantial delays, or negative impact on banking or brokerage conditions or markets. indices, forward foreign currency contracts, and various Hedging Risk. Hedging techniques could involve a variety of derivatives, including futures contracts, exchanged listed and over-the-counter put and call options on securities, financial interest rate transactions. A transaction used as a hedge to reduce or eliminate losses associated with a portfolio holding or particular market that a portfolio has exposure, including currency exposure, can also reduce or eliminate gains. Hedges are sometimes subject to imperfect matching between the hedging transaction and its reference portfolio holding or market (correlation risk), and there can be no assurance that a portfolio’s hedging transaction will be effective. In particular, the variable degree of correlation between price movements of hedging instruments and price movements in the position being hedged creates the possibility that losses on the hedge can be greater than gains in the value of the positions of the portfolio. Increased volatility will generally reduce the effectiveness of the portfolio’s currency hedging strategy. Hedging techniques involve costs, which could be significant, whether or not the hedging strategy is successful. Hedging transactions, to the extent they are implemented, have in the past and will likely in the future not be completely effective in insulating portfolios from currency or other risks. Index-Related Risk. Index strategies are passively managed and do not take defensive positions in declining markets. There is no guarantee that a portfolio managed to an index strategy (“index portfolio”) will achieve a high degree of correlation to its underlying index and therefore achieve its investment objective. Market disruptions and regulatory restrictions could have an adverse effect on the index portfolio’s ability to adjust its exposure to the required levels in order to track its underlying index. Errors in index data occur from time to time and are sometimes not identified and corrected for a period of time, and can have an adverse impact on a portfolio managed to the index. The index provider does not provide any warranty or accept any liability in relation to the quality, accuracy or completeness of data in respect of their indices, and does not guarantee that the index will be in line with its described index methodology. Errors and rebalances  GC Wealth Brochure 15 carried out by the index provider to the underlying index has in the past and likely will in the future increase the costs and market exposure risk of a portfolio. Inflation and Deflation Risk. Inflation risk is the risk that the value of assets or income from investments will be worth less in the future as inflation decreases the value of money. As inflation increases, the real value of a portfolio could decline. Inflation rates may change frequently and drastically as a result of various factors and a portfolio’s investments may not keep pace with inflation, which may result in losses. Deflation risk is the risk that prices decline over time – the opposite of inflation. Deflation may have an adverse effect on the creditworthiness of portfolios and may make defaults more likely. High rates of inflation and rapid increases in the rate of inflation generally have a negative impact on financial markets and the broader economy. In an attempt to stabilize inflation, governments may impose wage and price controls or otherwise intervene in a country’s economy. Governmental efforts to curb inflation, including by increasing interest rates or reducing fiscal or monetary stimuli, often have negative effects on the level of economic activity. Persistently high levels of inflation could have a material and adverse impact on a Client’s investments and its aggregated returns. Additionally, because the preferred return is not linked to the rate of inflation, as the rate of inflation increases, the proportion of real returns (i.e., the nominal rate of return less the rate of inflation) treated as preferred return decreases and the proportion of real returns subject to performance-based compensation increases. There can be no assurance that high rates of inflation will not have a material adverse effect on a Client. Interest Rate and Income Risk. Fixed income securities are subject to both interest rate risk and income risk. When interest rates rise, fixed income securities generally decline in value, with longer-term securities typically experiencing greater price volatility than shorter-term securities. Rising interest rates may also expose fixed-income and related markets to heightened volatility. Conversely, when interest rates fall, a portfolio's income may decline, as issuers may repay principal prior to a security's maturity, requiring the portfolio to reinvest proceeds in lower-yielding securities. Issuer Risk. A portfolio’s performance depends on the performance of individual securities to which the portfolio has exposure. Changes to the financial condition or credit rating of an issuer of those securities can cause the value of the securities to decline or become worthless. Legal and Regulatory Risk. Legal, tax, and regulatory changes may adversely affect Clients’ portfolios. New (or revised) laws or regulations or interpretations of existing law may be issued by the IRS or U.S. Treasury, the U.S. Commodity Futures Trading Commission (the “CFTC”), the SEC, the U.S. Federal Reserve or other banking regulators, or other governmental regulatory authorities, or self-regulatory organizations that supervise the financial markets that could adversely affect Clients’ portfolios. Clients’ portfolios also may be adversely affected by changes in the enforcement or interpretation of existing statutes and rules by these governmental regulatory authorities or self- regulatory organizations. It is impossible to predict what, if any, changes in regulations may occur, but any regulation or change in enforcement or interpretation that restricts the ability to trade in securities could have a material adverse impact on the performance of a  GC Wealth Brochure 16 Client’s portfolio, and a regulation that imposes restrictions on banks (and their affiliates) could have an adverse impact on GC Wealth. Clients have the potential to bear significant increased costs as a result of such changes. Leverage Risk. A portfolio utilizing leverage will be subject to heightened risk. Leverage involves the use of various financial instruments or borrowed capital in an attempt to increase the return on an investment and can be intrinsic to certain derivative instruments. Leverage takes the form of borrowing funds, trading on margin, derivative instruments that are inherently leveraged, including but not limited to, forward contracts, futures contracts, options, swaps (including total return financing swaps and interest rate swaps), repurchase agreements and reverse repurchase agreements, or other forms of direct and indirect borrowings and other instruments and transactions that are inherently leveraged. Any such leverage, including instruments and transactions that are inherently leveraged, can result in the portfolio’s market value exposure being in excess of the net asset value of the portfolio. A portfolio will often need to liquidate positions when it is not be advantageous to do so to satisfy its borrowing obligations. The use of leverage entails risks, including the potential for higher volatility and greater declines of a portfolio’s value, and fluctuations of dividend and other distribution payments. Liquidity Risk. Liquidity risk exists when particular investments are difficult to purchase or sell (e.g., not publicly traded and/or no market is currently available or becomes less liquid in response to market developments). This can reduce a portfolio’s returns because the portfolio is unable to transact at advantageous times or prices. Investments that are illiquid or that trade in lower volumes can be more difficult to value. Management Risk. A portfolio is subject to management risk, which is the risk that the investment process, techniques and analyses applied will not produce the desired results, and those securities or other financial instruments selected for a portfolio has in the past and likely will in the future result in returns that are inconsistent with the portfolio’s investment objective. In addition, legislative, regulatory, or tax developments will affect the investment techniques or opportunities, available in connection with managing the portfolio and has in the past and likely will in the future also adversely affect the ability of the portfolio to achieve its investment objective. Market Risk. The market value of the instruments in which a portfolio invests goes up or down in response to the prospects of individual companies; particular sectors or governments; political, regulatory, market and social developments; and/or general economic conditions throughout the world due to increasingly interconnected global economies and financial markets. In addition, turbulence in financial markets and reduced liquidity in equity, credit and/or fixed income markets may negatively affect many issuers, which could adversely affect market value. Market risk may be magnified if certain events or developments adversely interrupt the global supply chain; in these and other circumstances, such risks might affect companies world-wide. Examples include pandemic risks related to the coronavirus as well as war, terrorism, extreme climate events and geopolitical events. The financial services industry generally and investment activities are affected by general economic and market conditions, including interest rates, availability of credit, lack of price transparency, inflation rates, economic uncertainty,  GC Wealth Brochure 17 changes in tax and other applicable laws and regulations, trade barriers, national and international and environmental and socioeconomic circumstances. Mutual Funds and ETFs. Clients may invest in mutual funds and exchange-traded funds (“ETFs”). Mutual funds and ETFs purchase and sell securities, such as stocks, commodities and bonds (or have exposures to such securities through swaps and other derivative instruments) and may also invest in crypto-currencies. Some of the mutual funds and ETFs that may be purchased for a Client’s portfolio may concentrate heavily in a particular asset category or sector. These categories could include, among others, sector funds, blue chip stock funds, small capitalization stock funds, growth funds, bond funds and international funds or crypto-currency funds; such funds may specialize even further on the basis of country or region of the world and engage in the use of leverage and short selling or trade in crypto-currencies. Investors in mutual funds and ETFs generally bear all of their expenses, including fees of the investment adviser and custodian, brokerage commissions and legal and accounting fees. As a result, Clients will indirectly bear two levels of advisory compensation -- the Advisory Fee and the advisory fee charged by the investment adviser of any mutual funds and ETFs in the Client’s portfolio. The foregoing fees and expenses may be expected to result in a higher cost of investment than would be the case if Clients were to invest directly in the mutual funds and ETFs on their own. As a result, the returns realized by Clients will be lower, all else being equal, than the returns Clients would realize from engaging in the same activities directly on their own. Non-U.S. Securities Risk. Investments in the securities of non-U.S. issuers are subject to the risks associated with non-U.S. markets in which those non-U.S. issuers are organized and operate, including but not limited to, risks related to foreign currency, limited liquidity, less government regulation, privatization, and the possibility of substantial volatility due to adverse political, economic, geographic events, or other developments, differences in accounting, auditing and financial reporting standards, the possibility of repatriation, expropriation or confiscatory taxation, adverse changes in investment or exchange controls or other regulations and potential restrictions on the flow of international capital. These risks are often heightened for investments in smaller capital markets, emerging markets, developing markets or frontier markets. Operational and Trading Risk. GC Wealth’s operations depend on the effective integration of personnel, internal processes, and technology. Despite our oversight, inherent risks exist regarding human error and system limitations, particularly in the administration of client accounts. These risks include potential inaccuracies in advisory fee calculations due to data entry errors or software malfunctions. Additionally, trade errors may occur during the execution process, such as the purchase or sale of an incorrect security or quantity. While the firm maintains procedures to identify and remediate such errors, the correction process may result in execution delays or unintended tax consequences. GC Wealth also relies on third-party service providers and custodians for data reporting and trade settlement; any failure or delay by these external partners can negatively impact account management and reporting accuracy. Other Activities. GC Wealth Personnel will devote only such portions of their time to the affairs of a Client as they consider appropriate in their respective judgment to manage such  GC Wealth Brochure 18 Client’s account. Without limitation, GC Wealth Personnel currently manage, and expect in the future to manage, several other accounts similar to a Client’s, and expect to direct certain relevant investment opportunities or resources to those accounts. GC Wealth Personnel reserve the right to manage their own personal investments and accounts, whether or not through a formal family office or estate planning structure, to establish trusts, endowments, charitable programs, foundations or similar arrangements, and to pay or receive compensation relating to the foregoing. GC Wealth’s principals and investment staff will continue to manage and monitor such investments or accounts until their realization. Such other investments or accounts that GC Wealth’s principals expect from time to time to control or manage generally have the potential to compete with Client accounts or companies acquired by a Client account. GC Wealth’s principals reserve the right to, and likely will, focus their investment activities on other opportunities and areas unrelated to such Client’s accounts. To the extent an investment opportunity is received that is unsuitable for a Client, in GC Wealth’s sole discretion, GC Wealth and GC Wealth Personnel reserve the right to refer such opportunity to third parties or to make personal investments in the relevant opportunity. Unless restricted by the relevant IMA, GC Wealth Personnel are permitted to serve on boards or act in other roles unaffiliated with GC Wealth, Client accounts or their investments, including boards of charitable and educational institutions, public companies and former account investments, and receive compensation in connection with such services and roles, none of which will offset or otherwise reduce Advisory Fees or Investment Management Fees (as defined below). Public Health Emergencies; Pandemics and other widespread public health emergencies, including global outbreaks of infectious diseases, can cause significant market volatility and disrupt economic production. Such emergencies have the potential to materially and adversely impact global commerce, financial markets, and the operations of specific industries or businesses in ways that are impossible to predict. The resulting economic declines may lead to significant losses for Clients, including substantial reductions in revenue, impaired credit quality, and restricted capital availability. Because the extent and duration of these events are highly uncertain, the firm’s investment strategies and the operational performance of underlying investments may be negatively affected by factors beyond the firm’s control. International Conflicts and Geopolitical Events. Wars and other international conflicts have caused disruption to global financial systems, trade and transport, among other things. In response, multiple other countries have put in place sanctions and other severe restrictions or prohibitions on certain of the countries involved, as well as related individuals and businesses. The ultimate impact of these conflicts (and other geopolitical events, including national referenda, elections, interest rates, political movements, humanitarian crises, national and international policy changes, actual or perceived trade wars, import or export controls, executive orders, laws, legal systems and regulatory regimes) and their effect on global economic and commercial activity and conditions, and on the operations, financial  GC Wealth Brochure 19 condition and performance of GC Wealth or any particular industry, business or investee country and the duration and severity of those effects, is impossible to predict. These matters may have a significant adverse impact and result in significant losses to Clients. This impact may include reductions in revenue and growth, unexpected operational losses and liabilities, supply chain disruptions and reductions in the availability of capital. Developing and further governmental actions (military or otherwise) may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to the investment strategy which any Client intends to pursue, all of which could adversely affect the Client’s ability to fulfill its investment objectives. Further, terrorist activities, anti-terrorist efforts, armed conflicts involving the U.S. or its interests abroad and natural disasters may adversely affect the U.S., its financial markets and global economies and could prevent a client from meeting its investment objectives and other obligations. The potential for future terrorist attacks, the national and international response to terrorist attacks, acts of war or hostility and natural disasters have created many economic and political uncertainties in the past and may do so in the future, which may adversely affect the United States and world financial markets and a Fund for the short- or long-term in ways that cannot presently be predicted. Private Investment Risk. Investments in private investments, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets and other similar types of investments are highly illiquid and long-term. A portfolio’s ability to transfer and/or dispose of private investments is expected to be highly restricted. Portfolio Turnover Risk. Active and frequent trading of securities and financial instruments in a portfolio can result in increased transaction costs, including potentially substantial brokerage commissions, fees and other transaction costs. In addition, frequent trading is likely to result in short- term capital gains tax treatment. As a result of portfolio turnover, the performance of a portfolio can be adversely affected. Put-Writing Strategies Risk. GC Wealth engages Independent Managers who sell put options to generate premium income. While intended to enhance yield, this strategy exposes clients to downside risk: if the underlying asset falls below the strike price, losses may far exceed the premium received. Success depends entirely on the Independent Manager’s ability to manage strike prices and market volatility. These strategies also feature capped upside potential and may employ leverage, increasing the risk of margin calls or forced liquidations during market stress. In volatile or illiquid markets, the manager may be unable to close positions, potentially resulting in total loss of assigned collateral. Real Estate Risk. Historically real estate has experienced significant fluctuations and cycles in value and local market conditions which has in the past and likely will in the future result in reductions in real estate opportunities, value of real property interests and, possibly, the amount of income generated by real property. All real estate-related investments are subject to the risk attributable to, but not limited to: (i) inability to  GC Wealth Brochure 20 terms; consummate investments on favorable terms; (ii) inability to complete renovation, expansion or development on advantageous (iii) adverse government, environmental and tax regulations; (iv) leasing delays, tenant bankruptcies and low occupancy levels and lease rates; and (v) changes in the liquidity of real estate markets. Real estate investment strategies that employ leverage are subject to risks normally associated with debt financing, including the risk that: (a) cash flow after debt service will be insufficient to accumulate sufficient cash for distributions; (b) existing indebtedness (which is unlikely to be fully amortized at maturity) will not be able to be refinanced; (c) terms of available refinancing will not be as favorable as the terms of existing indebtedness; or (d) the loan covenants will not be complied with. It is possible that property could be foreclosed upon or otherwise transferred to the mortgagee, with a consequent loss of income and asset value. Research Risk. Fundamental analysis entails attempting to measure the intrinsic value of a security by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysis attempts to produce a value for a security which can be compared with the current price. There are several weaknesses of fundamental analysis including; models are time consuming and specific to industries or companies, models are based on assumptions which introduce subjectivity, models are subject to biases of the analyst and the definition of fair value. Fundamental analysis should be approached with caution. An inherent risk involved in the analysis is the assumption that the market or security will reach an expected value. Qualitative analysis is a non-statistical oriented analysis. It uses subjective judgment based on unquantifiable information, for example; management expertise, industry cycles, strength of research and development and labor relations. The risk involved with qualitative analysis is that there are biases introduced by the analyst. Quantitative analysis is a method of analysis that seeks to understand behavior by using complex mathematical and statistical modeling. The risk involved with the analysis is that there is no guarantee that these models will accurately forecast results or reduce risk. There can be no assurance that a model will achieve its objective. Technical analysis is based on past market data including price and volume. The risks associated with this model are the assumption that the market will follow a pattern. However, markets do not always follow patterns or predictions of the pattern can be flawed. Risk Management. Although managing risk is a principal element of GC Wealth’s overall investment strategy, Clients are expected to make investments that, viewed in isolation, present very substantial risks. Rather, GC Wealth will seek to manage risk across Clients via a broad array of risk‐offsetting techniques. There can be no assurance that GC Wealth will be successful in avoiding excessive risk exposure in connection with Clients’ investments. GC Wealth’s ability to successfully manage risk will depend in significant part upon: (i) the ability of the members of GC Wealth to accurately obtain and analyze relevant data to identify possible risks; (ii) the ability of the members of GC Wealth to make appropriate adjustments to Clients’ asset allocations; and (iii) the availability and affordability of market vehicles to reduce risk (e.g., swaps, hedges, puts and insurance). If GC Wealth is unable to identify the relevant risks or adjust Clients’ asset allocations to mitigate risks, or if the cost of market vehicles to reduce risk is prohibitive, Clients’ investment performance could suffer.  GC Wealth Brochure 21 Short Selling Risk. Short sales in securities that it does not own exposes a portfolio to speculative exposure risks. If a portfolio makes short sales in securities that increase in value, the portfolio will lose value. Certain securities will not be available or eligible for short sales. Short selling involves the risks of: increased leverage, and its accompanying potential for losses; the potential inability to reacquire a security in a timely manner, or at an acceptable price; the possibility of the lender terminating the loan at any time, forcing the portfolio to close the transaction under unfavorable conditions; the additional costs that will be incurred; and the potential loss of investment flexibility caused by the obligation to provide collateral to the lender and set aside assets to cover the open position. There can be no assurance that a portfolio will be able to close out a short sale position at any particular time or at an acceptable price. Any loss on short positions will not necessarily be offset by investing short-sale proceeds in other investments. Structured Products Risk. Investing in structured products involves a high degree of complexity and risk, as these are typically unsecured debt obligations of a financial institution with returns linked to the performance of an underlying asset, index, or benchmark. These instruments often combine a debt security with a derivative component, such as an option, which makes them significantly more complex than traditional stocks or bonds. Clients must understand that they are subject to the specific credit risk of the issuing institution; should the issuer default or file for bankruptcy, the client may lose their entire principal regardless of how the underlying index performs. Furthermore, structured products are generally designed to be held until maturity and often lack a liquid secondary market, meaning that any attempt to sell the investment prior to maturity may result in a significant loss of value. While these products may offer certain downside protections, such as "buffers" or "floors," these features are frequently provided in exchange for "caps" or "participation rates" that limit the client’s ability to fully capture market gains. Additionally, many structured products are "callable" at the issuer's discretion, which may result in the investment being terminated early and the client facing reinvestment risk in a less favorable market environment. These products are not suitable for all investors and should only be utilized by those who can tolerate the potential for total loss and the lack of liquidity. Tax-loss Harvesting Strategies Risk. GC Wealth engages Independent Managers to implement tax-loss harvesting strategies on behalf of clients. These strategies are intended to realize capital losses to offset taxable gains; however, there is no guarantee that anticipated tax benefits or improved after-tax returns will be achieved. Results depend on market conditions, transaction timing, the client’s tax circumstances, and prevailing tax laws or regulations. Tax-loss harvesting may increase portfolio turnover, transaction costs, and short-term capital gains, and may cause temporary deviations from target allocations. Wash sale rules and other tax limitations may reduce the availability or losses. In addition, custodial platform constraints or effectiveness of harvested operational limitations may restrict a client’s access to or full implementation of these strategies. Clients should consult their tax advisors regarding the appropriateness and tax consequences of such strategies.  GC Wealth Brochure 22 Underlying Fund Risk. A portfolio investing in funds (underlying funds), including but not limited to GC Funds, includes, but is not limited to the performance of the underlying fund and investment risk of the underlying funds’ investment, as the underlying funds could involve highly speculative investment techniques, including extremely high leverage, highly concentrated portfolios, workouts and startups, control positions and illiquid investments. In particular, the risks for a portfolio operating under a fund of funds structure include, but are not limited to, the following: the performance of the portfolio will depend on the performance of the underlying funds’ investments; there can be no assurance that a multi-manager approach will be successful or diversified, or that the collective performance of underlying fund investments will be profitable; one or more underlying funds will be allocated a relatively large percentage of the portfolio’s assets; there can be limited information about or influence regarding the activities of the underlying fund’s investment advisors and underlying funds, like any other asset, will be subject to trading restrictions or liquidity risk. Portfolio investments in underlying funds will generally be charged the proportionate share of the expenses of investing in the underlying fund(s). interest, Underlying managers are entitled to receive management fees, carried performance-based fees and/or other forms of compensation in respect of underlying funds or investment vehicles, resulting in multiple layers of fees. A Client investing in an underlying fund (including potentially a GC Fund) will generally be charged fees by both GC Wealth and the underlying managers. In addition to paying fees at multiple levels, a client will bear its share of the transaction-related expenses and other operating costs of both the Client and its respective investments (such as the underlying fund in which it invests). As a result of the pooled nature of the GC Funds, even if a GC Fund’s overall performance is negative, one or more of its investments may still have positive performance, and the GC Fund (and therefore its investors, such as a Client) will still be charged an incentive fee by the underlying manager, regardless of the overall performance of the GC Fund. There will generally be no reduction in the Advisory Fees or Investment Management Fees, or any other potential fees or compensation received by GC Wealth or one of its affiliates, with respect to the portion of a Client’s capital that is invested in the underlying funds. Use of Independent Managers. The use of Independent Managers involves additional risks, as the success of these programs depends on the infrastructure and investment personnel of the underlying managers. These managers are often dependent on a limited number of key individuals; the loss of such personnel or other adverse events could significantly impair or result in the loss of a Client’s investment. Furthermore, there is no assurance that a manager's past performance will indicate future results, which may differ significantly. While GC Wealth employs reasonable diligence to evaluate and monitor Independent Managers—focusing on strategies with the potential for strong risk-adjusted returns based on objective and subjective data—this complex process cannot eliminate all risks. GC Wealth may miss or misinterpret information, and managers may provide misleading or false representations or engage in undetected fraudulent conduct, such as misappropriation of assets or unauthorized strategy changes. Additionally, underlying managers provide information at their own discretion and may withhold data due to legal or confidentiality restrictions, making it more difficult for GC Wealth to assess their  GC Wealth Brochure 23 performance and allocate capital effectively. Even if GC Wealth accurately identifies high- potential managers, there is no guarantee that Clients will be able to invest in their vehicles. Investment opportunities may be missed due to misaligned fundraising cycles, lack of available capital during "open window" periods, or the manager's refusal to accept a Client's offer to invest. Finally, many of the risks associated with GC Wealth’s own management, including conflicts of interest, apply in a corresponding or more significant manner to the vehicles of underlying managers. Valuation Risk. The net asset value of a portfolio as of a particular date can be materially greater than or less than its net asset value that would be determined if a portfolio’s investments were to be liquidated as of such date. For example, if a portfolio was required to sell a certain asset or all or a substantial portion of its assets on a particular date, the actual price that a portfolio would realize upon the disposition of such asset or assets could be materially less than the value of such asset or assets as reflected in the net asset value of a portfolio. Volatile market conditions could also cause reduced liquidity in the market for certain assets, which could result in liquidation values that are materially less than the values of such assets as reflected in the net asset value of a portfolio. Volatility Risk. The prices of a portfolio’s investments can be highly volatile. Price movements of assets are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, developments or trends in any particular industry, the financial condition of the issuers of such assets, changing supply and demand relationships, programs and policies of governments, and national and international political and economic events and policies. The foregoing is only a summary of the potential risks and is not a complete explanation of the risks involved in investing in an investment strategy or engaging the assistance of GC Wealth. Item 9. Disciplinary Information GC Wealth and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to a Client’s evaluation of GC Wealth or GC Wealth Personnel. Item 10. Other Financial Industry Activities and Affiliations GC Wealth has certain financial industry affiliations that are material to its advisory business. General Catalyst, an SEC-registered investment adviser, is under common control with GC Wealth through common ownership. Common ownership can create a conflict of interest. GC Wealth believes that conflicts of interest between the two registered advisers as a result of common ownership are mitigated as a result of several factors. For instance, GC Wealth’s investment professionals are solely dedicated to GC Wealth. In addition, the advisers are not direct or indirect competitors for investments or Clients. GC Wealth does have a conflict of interest when (i) recommending or investing in private funds managed  GC Wealth Brochure 24 by General Catalyst (i.e., the GC Funds) or (ii) recommending or investing in portfolio companies of GC Funds; however, GC Wealth believes those risks are partially mitigated as GC Wealth will only invest Client assets in one or more GC Funds (or portfolio companies thereof) that it deems appropriate and consistent with the Client’s investment plan and permitted by applicable law. Furthermore, GC Wealth does not receive a ‘double-dip’ of advisory fees on assets invested in GC Funds unless specifically disclosed and agreed upon in the Client’s IMA. GC Wealth has an incentive to direct Client assets to its related person managed private funds or their portfolio investments as a result of the compensation and fees paid to the related person for managing private funds. See Item 11 for a discussion of conflicts of interest. Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Code of Ethics GC Wealth maintains a written Code of Ethics that is applicable to all of its partners, officers and employees, as well as certain part-time employees and certain independent contractors (collectively, “GC Wealth Personnel”). The Code of Ethics, which is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940 (as amended, the “Advisers Act”), establishes guidelines for professional conduct and personal trading procedures, including certain pre-clearance and reporting obligations. GC Wealth Personnel and their families and households are permitted to purchase investments for their own accounts, including the same investments as may be purchased or sold for Clients, subject to the terms of the Code of Ethics. Under the Code of Ethics, GC Wealth Personnel are required to file certain periodic reports with GC Wealth’s Chief Compliance Officer as required by Rule 204A-1 under the Advisers Act. The Code of Ethics helps GC Wealth detect and prevent conflicts of interest. GC Wealth Personnel who violate the Code of Ethics may be subject to remedial actions, including, but not limited to, profit disgorgement, fines, censure, demotion, suspension or dismissal. GC Wealth Personnel are also required to promptly report any violation of the Code of Ethics of which they become aware and are required to annually certify compliance with the Code of Ethics. GC Wealth’s policies and procedures strictly prohibit engaging in insider trading and misuse of confidential information. If GC Wealth Personnel come into possession of material non-public information, GC Wealth may not be able to transact in a security or investment held on behalf of a Client, even though such action would otherwise be in the best interest of a Client. A copy of the Code of Ethics is available to any Client or prospective Client upon written request to: GC Wealth Management RIA, LLC, 20 University Road, 4th Floor Cambridge, Massachusetts 02138. GC Wealth reserves the right to refine and modify the Code of Ethics and its other policies and procedures over time. No Client or prospective Client should invest with GC Wealth on the basis of, or otherwise rely on, the provisions thereof, and any such refinements or modifications have the potential materially to affect the investments available to Clients or the expenses borne thereby.  GC Wealth Brochure 25 Securities Recommendations GC Wealth invests Clients, directly or indirectly, in private funds managed by its affiliate General Catalyst (“GC Funds”), to the extent permitted by applicable law. This relationship creates a financial incentive for GC Wealth to favor GC Funds over funds managed by unaffiliated advisers. GC Wealth may also invest in third-party funds or accounts in which GC Wealth, its supervised persons, or related persons have a material financial interest, presenting additional conflicts. GC Wealth will at all times make recommendations in Clients’ best interest and will manage these conflicts through periodic review and assessment of Client investments. Conflicts of Interest GC Wealth and its affiliates have, and will likely continue to have, business, family, or personal relationships with private funds, third-party fund managers, affiliated entities, and key principals. GC Wealth affiliates also have business relationships with Clients who invest in GC Funds. GC Wealth’s goal is to avoid or address conflicts consistent with Clients’ best interests, through disclosure, internal controls, and review processes. While GC Wealth endeavors to resolve conflicts fairly, there can be no assurance that its own interests will not influence its conduct and decisions. Participation or Interest in Client Transactions GC Wealth Personnel may invest in the same or opposite direction as Clients in the same securities or assets, creating potential conflicts of interest. To address these conflicts, Personnel must obtain pre-clearance from the Compliance team before executing any reportable security transactions in their personal accounts. GC Wealth Personnel may, in certain circumstances, provide management or board-level services for client-owned entities (such as LLCs or private corporations) as part of our comprehensive wealth management offering. Because these personnel may exercise control or influence over the business decisions of these entities—including the management of real estate or the selection of third-party service providers—a potential conflict of interest exists. To mitigate these conflicts, these personnel act as fiduciaries and receive no additional compensation beyond the fees stated in the IMA, while all material business decisions and potential vendor relationships are subject to review and approval by the Client’s third-party appointees. Participation in Investment Opportunities GC Wealth Personnel may participate in investment opportunities offered to them in their personal capacity when such opportunities are not offered to the Adviser as investment opportunities for firm or client participation.  GC Wealth Brochure 26 Allocation of Investment Opportunities In connection with its investment activities, the Adviser will encounter situations in which it must determine how to allocate investment opportunities, including private offerings, across and among various Clients. GC Wealth maintains written policies and procedures relating to the allocation of investment opportunities as well as adheres to investment limitations as described in the IMAs. GC Wealth Personnel are permitted to invest in such investment opportunities (including those sponsored by Clients) as long as there are no material conflicts with Client interests and in accordance with written policies and procedures. Managed Fund Fees Affiliates of GC Wealth receive investment management fees and performance fees from the GC Funds and may receive other payments from time to time. Consistent with each GC Fund’s governing documents (including limited partnership agreements, subscription agreements, private placement memoranda, and side letters, collectively “Governing Documents”), the GC Funds may bear certain expenses incurred by GC Wealth or its affiliates in providing services to the GC Funds. Investment management fees are calculated based on each GC Fund’s net asset value or committed capital, as described in the relevant Governing Documents. Principal Transactions Section 206(3) of the Advisers Act regulates principal transactions—where an investment adviser or affiliate proposes to buy a security from, or sell a security to, a client. Before engaging in a principal transaction, the adviser must disclose the transaction’s terms to the client and obtain consent. GC Wealth and its affiliates may engage in principal transactions, and GC Wealth maintains policies and procedures to comply with these requirements, including required disclosures and prior client consent. Cross-Transactions GC Wealth may, in certain cases, cause one Client to purchase investments from, or sell investments to, another Client, though GC Wealth has not historically engaged in such transactions. Cross-transactions create conflicts of interest: a Client may not receive the best available price, and GC Wealth or its affiliates may have financial interests in the relevant funds, earn fees, or share in investment profits from the transaction. To address these conflicts, GC Wealth follows established allocation procedures set forth in the applicable IMAs. Where allocation procedures do not govern, the CCO will confirm that GC  GC Wealth Brochure 27 Wealth (i) considers its duties to each Client, (ii) assesses whether the transaction terms are comparable to an arm’s-length transaction, and (iii) obtains any required approvals. Material, Nonpublic Information GC Wealth and its affiliates may receive MNPI regarding issuers, including through board memberships. Under applicable law and GC Wealth’s policies, Personnel are prohibited from disclosing or using MNPI for personal benefit or for the benefit of any other person, including Clients. Receipt of MNPI may therefore limit GC Wealth’s ability to buy, sell, or hold certain investments on behalf of Clients, potentially affecting investment results. GC Wealth has no obligation to disclose MNPI to, or use it for the benefit of, any person—even if failure to do so is detrimental to that person’s interests. Adviser Relationships with Service Providers GC Wealth selects service providers for Clients based on merit and Clients’ best interests, not the personal interests of GC Wealth or its affiliates. However, GC Wealth may recommend service providers with which GC Wealth, its affiliates, or GC Wealth Personnel have a relationship or from which they receive financial or other benefits. For example, GC Wealth may recommend banking institutions that offer Clients favorable loan terms based on those institutions’ relationships with GC Wealth or its affiliates. If such a relationship ends, Clients may lose access to favorable terms. These relationships may influence GC Wealth’s service provider recommendations. Item 12. Brokerage Practices Best Execution GC Wealth is not affiliated with any custodian or broker-dealer but is party to service agreements with unaffiliated custodians and broker-dealers. With limited exceptions, GC Wealth has sole discretion to select broker-dealers or other execution facilities in executing Client trades. In selecting or recommending brokers, most often with respect to trading in publicly-traded securities, GC Wealth seeks best execution, which involves a number of qualitative and quantitative factors. In seeking best execution, GC Wealth need not solicit competitive bids and does not have an obligation to seek or pay the lowest available commission or execution cost. In selecting a broker, GC Wealth takes into account, among other things, the broker’s commission rate, execution capabilities and costs, actual experience, efficiency, promptness, financial stability, reputation, confidentiality, and research or other services provided by the broker. Currently, GC Wealth generally recommends that Clients utilize the custody and brokerage services of Fidelity Brokerage Services LLC (“Fidelity”), or Charles Schwab & Co., Inc. (“Schwab”) both of which are unaffiliated broker-dealers and custodians. Clients will continue to be responsible for the following "Excluded Fees": ● Fund-Level Internal Expenses: All fees and expenses charged by mutual funds, exchange-traded funds (ETFs), and alternative investment vehicles. These include,  GC Wealth Brochure 28 but are not limited to, management fees, 12b-1 fees, internal administrative expenses, sales loads, and short-term redemption fees. ● Account Activity and Maintenance Fees: Fees charged by the custodian for specific account actions or maintenance, such as wire transfer fees, overnight check fees, paper statement fees, margin interest, and retirement account (IRA) maintenance fees. ● Trade-Away and Prime Brokerage Fees: Any fees or "mark-ups" incurred if GC Wealth determines that a trade should be executed through a broker-dealer other than the account’s primary custodian (Schwab or Fidelity). ● Direct Client-Initiated Trades: Any trades or transactions initiated directly by the Client without the involvement of GC Wealth (e.g., trades placed via a custodian's retail website or platforms like thinkorswim) will be charged to the Client at the custodian's standard retail rates. ● Regulatory and Third-Party Charges: Fees imposed by third parties or regulatory bodies, including but not limited to transfer taxes, electronic fund transfer fees, and American Depositary Receipt (ADR) pass-through fees. For certain accounts, GC Wealth has entered into an agreement with Schwab (and/or Fidelity) where the Firm, rather than the Client, pays certain transaction-based fees and commissions ("Brokerage Fees"). This is an "Advisor Billing" arrangement. Because GC Wealth pays these fees, it creates a conflict of interest: the Firm has a financial incentive to limit the frequency of trading or to select investment products (such as no-transaction- fee funds) that do not result in a direct cost to the Firm. GC Wealth manages this conflict by putting the Client's interests first and ensuring all trades are consistent with the Client’s investment objectives. Support Products and Services; Advisor Billing Arrangement Under GC Wealth’s Client Benefit Agreement with Schwab, pursuant to which Schwab provides the firm with significant economic benefits to support our business operations, including marketing, technology, consulting, and research expenses, the availability and payment of this support are specifically contingent upon GC Wealth reaching and maintaining certain tiered thresholds of "Net New Assets" (assets transferred from outside financial firms) at Schwab within a specified timeframe. This arrangement creates a material conflict of interest because GC Wealth has a financial incentive to recommend that Clients custody their assets at Schwab rather than another custodian. Our recommendation may be influenced by the firm's desire to reach the asset milestones required to unlock additional support payments or to prevent the rescission of existing benefits, rather than being based solely on a Client's interest in receiving the best value or most favorable execution. Under our Advisor Billing arrangement, GC Wealth pays certain transaction-based fees and commissions that would otherwise be charged to the Client. The cost of these fees to GC Wealth often varies between our recommended custodians (Schwab and Fidelity). Consequently, GC Wealth has a financial incentive to recommend the custodian with the lower cost structure for the firm, as this reduces our operating expenses and increases firm profitability. This creates a conflict of interest because our recommendation of a  GC Wealth Brochure 29 custodian may be influenced by these cost savings rather than the specific execution quality or service needs of the Client. To mitigate these conflicts, GC Wealth manages these arrangements by putting the Client’s interests first and ensuring all trades and custodial recommendations are based on the quality of service and overall benefit to the Client rather than the firm’s financial incentive to reduce its own operating costs or receive economic benefits. Research and Other Soft Dollar Benefits GC Wealth does not have any formal soft dollar arrangements; however, in the normal course of business, GC Wealth receives research customarily made available by broker- dealers to their customers. GC Wealth believes that it would obtain such research regardless of the amount of commissions it generates throughout the year, and any receipt of such research will be in accordance with the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934, as amended. Certain brokers and custodians utilized by GC Wealth provide general assistance to GC Wealth, including, but not limited to, technical support, consulting services, waivers of fees, and consulting services related to staffing needs. In selecting a broker, GC Wealth considers the scope of general assistance, waivers of fees, and consulting services provided. To the extent GC Wealth would otherwise be obligated to pay for such assistance, GC Wealth would have a conflict of interest in considering those services when selecting a broker. However, GC Wealth’s selection is supported by the scope, quality, and price of services to its Clients and not the services that benefit GC Wealth. Directed Brokerage In the limited situations where a Client directs GC Wealth to use a specific broker and GC Wealth has not negotiated the terms and conditions (including, but not limited to, commission rates), GC Wealth does not have any responsibility for obtaining the best prices or particular commission rates. GC Wealth will not seek better execution services or prices from other broker-dealers or be able to aggregate the Client’s transactions, for execution through other broker-dealers, with orders for other accounts advised or managed by GC Wealth. As a result, in these cases of directed brokerage, GC Wealth may not obtain best execution on behalf of the Client, who may pay materially disparate commissions, greater spreads or other transaction costs, or receive less favorable net prices on transactions for the account than would otherwise be the case. If a Client’s broker-dealer cannot execute a transaction on the Client’s behalf, or in GC Wealth’s sole discretion, GC Wealth determines that the transaction should not be executed by the Client’s broker- dealer, GC Wealth has a duty of best execution and may aggregate Client transactions, as well as, effect the transaction through a different broker, dealer, or bank, including those affiliated with GC Wealth. Other Clients who direct GC Wealth to use a specific broker may pay higher commission rates or receive less favorable execution transactions than non-directing Clients.  GC Wealth Brochure 30 Brokerage for Client Referrals GC Wealth does not consider, in selecting or recommending broker-dealers, Client referrals from a broker-dealer. Order Aggregation and Allocation of Trades GC Wealth and its affiliates have several investment strategies and several types of Clients. At times, there will be transactions executed to purchase or sell the same investment in more than one strategy. When there are concurrent transactions across GC Wealth managed accounts, GC Wealth’s objective is to allocate trades equitably and consistent with its duties to Clients. In doing so, GC Wealth takes into consideration a number of factors, including, but not limited to, Client objectives, capacity, availability of funds, and consideration of pro-rata allocations. Where possible, GC Wealth will aggregate orders of Clients. In situations where aggregated trades are executed in multiple lots at varying prices, each participating Client’s proportionate share will reflect the average price paid or received with respect to the aggregate order. Allocation decisions are made in conformance with basic fiduciary principles, so as to seek fair and equitable treatment of each Client participating in the aggregated trade. Instances in which Client trades will not be aggregated include, but are not limited to, the following: ● Clients whose account guidelines have certain requirements unique to that Client which would make trade aggregation impractical or not in the best interest of all Clients; ● The timing of the trades entered during the trading day; and ● Traders and/or Wealth Managers determine that aggregation is not appropriate due to market conditions. GC Wealth will rely on the judgment of trading personnel as to what course of action is likely to be fair and in the best interests of the relevant accounts on an overall basis. Transactions involving commingled orders will be allocated in a manner deemed equitable by GC Wealth to each Client account. GC Wealth seeks to avoid putting any Client account at an advantage or disadvantage compared to GC Wealth’s other Client accounts that are buying or selling the same security. When a combined order is executed in a series of transactions at different prices, each Client account participating in the order will typically be allocated an average price obtained from the executing broker. To help ensure the equitable distribution of investment opportunities among its Clients, GC Wealth has adopted written trade allocation guidelines for GC Wealth Personnel. Item 13. Review of Accounts GC Wealth’s investment professionals routinely review portfolios to monitor performance, liquidity, and suitability of investments as well as assess investment opportunities for Clients and determine whether rebalancing or reallocations are warranted. Such reviews are typically performed on a regular basis. Similarly, the performance of third-party  GC Wealth Brochure 31 investment funds is monitored on a regular basis and is subject to ongoing supervision and review by GC Wealth’s investment professionals. A Client’s custodian provides at least quarterly reports to the Client showing the assets held in each Client account at the relevant custodian, the market value, and each account’s change in value for the quarter. Certain assets, such as private investments, will not be held in a custodial account and any valuations or reports related thereto shall be provided by the fund administrator, the auditor or the underlying manager of such private investments. Moreover, Clients should be aware that it is possible that certain independent systems used by GC Wealth or provided to, or used by, a Client may reflect slightly different values for certain securities in a Client’s account as opposed to what the Client receives in its custodial statement, which may come as a result of different accrual methodologies, for example. However, a Client’s custodial statements shall serve as the official books and records for the Client’s account, regardless of whether a lower valuation is provided. Clients have periodic meetings with their respective Wealth Managers to discuss their portfolios, and will receive reports, including balance and performance information, in connection with these meetings. Item 14. Client Referrals and Other Compensations GC Wealth does not receive economic benefits from third parties for providing advisory services, though it may receive referral fees or revenue-sharing payments when referring clients to outside service providers, such as insurance agencies. This creates a financial incentive for GC Wealth to recommend these specific providers, constituting a conflict of interest. GC Wealth expects to enter into arrangements where certain third-party promoters are paid for client referrals, typically as a percentage of the advisory fees collected. This arrangement creates a material conflict of interest for the promoter. In accordance with Rule 206(4)-1, GC Wealth requires promoters to provide clients with a written disclosure detailing their relationship with the firm, the compensation terms, and the resulting conflicts of interest. GC Wealth conducts due diligence to ensure all promoters are eligible to provide solicitation services. The firm will not compensate any promoter known to be subject to a "disqualifying event" or "bad actor" status as defined by the Advisers Act. GC Wealth monitors these relationships to maintain compliance with SEC disqualification standards Item 15. Custody Except for certain private fund investments, Client funds and securities are maintained by independent qualified custodians. While Clients may select their own qualified custodian in limited situations, GC Wealth generally recommends or requires the use of Fidelity and Schwab as custodians and to facilitate trading and reporting. The custodians send account  GC Wealth Brochure 32 statements directly to Clients at least quarterly. GC Wealth may provide supplemental reports or summaries, but Clients should carefully compare these to the official statements received from their custodian. If any discrepancies are discovered, Clients should contact GC Wealth or the custodian immediately. For Client assets invested in private funds that have been recommended to Clients by GC Wealth—whether managed by our affiliate, General Catalyst, or by unaffiliated third-party fund managers—we comply with the Custody Rule by ensuring each fund undergoes an annual audit by an independent public accountant registered with the PCAOB. Audited financial statements are distributed to investors within 120 days of the fund’s fiscal year- end (or 180 days for funds-of-funds). This annual audit serves as the independent verification of the assets held within these recommended private vehicles. Because GC Wealth is deemed to have custody for reasons beyond fee deduction, including because certain GC Wealth Personnel provide management or board-level services for client-owned entities, it is required to undergo an annual surprise examination. This unannounced examination is conducted by an independent public accountant to verify the existence of Client funds and securities. The accountant performs this review at a time of their choosing without prior notice to the firm and files a certificate with the SEC detailing their findings. Item 16. Investment Discretion Each IMA generally authorizes GC Wealth to invest and trade the Client’s assets in a broad range of investments, to be selected at GC Wealth’s sole discretion, with no specific limitations as to type, amount, or concentration. GC Wealth will enter into any type of investment transaction and employ any investment methodology or strategy it deems appropriate, including, in cases where it deems to be in the Client’s best interests, allocating to GC Funds. Each Client authorizes GC Wealth to execute certain documents necessary to facilitate the Client’s investments. In making investments on behalf of Clients, GC Wealth exercises its discretion in a manner consistent with the Client’s stated goals and investment objectives. In limited circumstances, GC Wealth may enter into an IMA that only grants it non- discretionary authority whereby GC Wealth must obtain a Client’s approval before executing on an investment recommendation. Item 17. Voting Client Securities GC Wealth will vote Client proxies where such responsibility has been properly delegated to (via the IMA) and assumed by GC Wealth. GC Wealth casts proxy votes in a manner consistent with the best interest of Clients. In the event that GC Wealth has authority to vote proxies for a Client, GC Wealth expects to delegate the responsibility to review proxy proposals and make voting recommendations to a non-affiliated third-party vendor. Proxies will be voted consistent with GC Wealth’s Proxy Voting Policies and Procedures. GC Wealth will use reasonable efforts to ensure that the third-party vendor has developed policies and procedures that ensure that Client proxies are voted in the best interest of  GC Wealth Brochure 33 Clients. Clients may retain the authority to vote all proxies in their account, but a Client may not otherwise direct GC Wealth’s vote for particular solicitations. If GC Wealth becomes aware of any type of potential or actual conflict of interest relating to a particular proxy proposal, GC Wealth’s Chief Compliance Officer will be responsible for resolving the conflict. GC Wealth can resolve the conflict in a number of ways depending on the type and materiality. The method selected by GC Wealth will depend upon the facts and circumstances of each situation and the requirements of applicable laws. At any time, Clients may contact GC Wealth to request information about how proxies were voted for such Client’s securities or to obtain a copy of GC Wealth’s Proxy Voting Policies and Procedures. Item 18. Financial Information GC Wealth does not have any financial conditions that are likely to impair its ability to meet contractual commitments to its Clients.