Ggm Financial LLC

GGM Financial, LLC 2492 W. Dublin Granville Rd Columbus, OH 43235 Phone (614) 310-2400 www.ggmfin.com Form ADV Part 2A Disclosure Brochure March 2026 Item 1: Cover Page This brochure provides information about the qualifications and business practices of GGM Financial, LLC (“GGM”). If you have any questions about the contents of this brochure, please contact us at compliance@ggmfin.com or (614) 310-2400. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. GGM Financial, LLC is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. Additional Information about GGM Financial, LLC also is available on the SEC’s website at www.advisorinfo.sec.gov.  GGM Financial, LLC Form ADV 2A March 2026 Item 2: Material Changes Since the last annual filing of this brochure on 3/21/2025, the following material changes have occurred: • GGM created a Wrap Fee Brochure to more accurately describe the GGM Financial Wrap Fee Program. 2  GGM Financial, LLC Form ADV 2A March 2026 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 ................................................. 7 Item 9: Disciplinary Information .......................................................................................................... 12 Item 10: Other Financial Industry Activities and Affiliations ................................................................ 12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 13 Item 12: Brokerage Practices ............................................................................................................. 14 Item 13: Review of Accounts ............................................................................................................. 16 Item 14: Client Referrals and Other Compensation ............................................................................ 17 Item 15: Custody ............................................................................................................................... 17 Item 16: Investment Discretion .......................................................................................................... 17 Item 17: Voting Client Securities ........................................................................................................ 18 Item 18: Financial Information ............................................................................................................ 18 3  GGM Financial, LLC Form ADV 2A March 2026 Item 4: Advisory Business GGM Financial, LLC (“GGM Financial”) is a registered investment adviser, based in Columbus, Ohio, offering financial planning and asset management services to clients. GGM Financial has been in business since 2002, and its principal owners are Brady Green, Matthew Collins, and Karen Bauman. Advisory Services Offered WEALTH MANAGEMENT SERVICES GGM provides Wealth Management Services to advisory clients. Wealth Management Services combine Asset Management Services with Financial Planning Services. ASSET MANAGEMENT SERVICES GGM offers asset management services to advisory Clients through the GGM Financial Wrap Free Program. GGM will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. Discretionary When the Client elects to use GGM on a discretionary basis, the Client will sign a limited trading authorization or equivalent allowing GGM to determine the securities to be bought or sold and the amount of the securities to be bought or sold. GGM will have the authority to execute transactions in the account without seeking Client approval on each transaction. Please see the GGM Financial Wrap Fee Program Brochure for more details. THIRD-PARTY MANAGERS When deemed appropriate for the Client, GGM may recommend that Clients utilize the services of a third-party manager (TPM) to manage a portion of, or all of the Client’s portfolio. All TPMs that GGM recommends must be Registered Investment Advisors with the SEC or with the appropriate state authority(ies). After gathering information about your financial situation and objectives, an Investment Advisor Representative of GGM will make recommendations regarding the suitability of a TPM or investment style based on, but not limited to, your financial needs, investment goals, tolerance for risk, and investment objectives. Upon selection of a TPM(s), we will monitor the performance of the TPM(s) to ensure their performance and investment style remain aligned with your investment goals and objectives. In such circumstances, GGM receives fees from the TPM. We act as the liaison between the Client and the TPM in return for a portion of the advisory fees charged by the TPM. GGM may, but is not limited to, the following: • Provide information to each Client concerning the investment advisor services offered by TPM and the fee schedule of such services. • Deliver the Form ADV Part 2, Privacy Notice, Form CRS, and Disclosure Statement to the Client, as applicable. • Meet with the Client to discuss any changes in status, objectives, time horizon, or suitability. • Update the TPM with any changes in Client status that are provided to GGM by the Client. All duties of GGM and TPM will be outlined pursuant to an agreement between both parties. Clients placed with TPM will be billed in accordance with the TPM’s Fee Schedule, which will be disclosed to the Client prior to signing an agreement. 4  GGM Financial, LLC Form ADV 2A March 2026 FINANCIAL PLANNING AND CONSULTING Services include an evaluation of a client’s current and future financial state using currently known variables to predict future cash flows and asset values, recommend purchase and sales, and withdrawal plans. GGM will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Financial planning analysis consists of the following steps: • Initial Client meeting to determine project scope • Presentation of a formal agreement between Client and GGM Financial • Compilation of required financial information, evaluation of current position, and identification and prioritization of the Client’s financial goals • Presentation of the final plan to the Client, which may include: o Analysis of current position o Goal needs, which may include retirement, educational funding, cash flow, estate planning, tax planning, and/or income/asset protection recommendations Topics for planning may include, but are not limited to: • Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress toward financial goals. • Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings, and investment each month. • Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution. • Long-term investment plan: Build a customized asset allocation strategy based on specific investment objectives and a risk profile. This strategy sets guidelines for selecting, buying, and selling investments and establishing benchmarks for performance review. • Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include the identification of tax-favored investment vehicles that can reduce taxation of investment income. • Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. If a conflict of interest exists between the interests of GGM and the interests of the Client, the Client is under no obligation to act upon GGM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through GGM. RETIREMENT PLAN CONSULTING GGM provides a fee-for-service consulting program whereby our advisors offer one-time or ongoing advisory services to qualified retirement plans. GGM can assist plan sponsors with their fiduciary duties and provide individualized advice based upon the needs of the plan and/or plan participants regarding investment management matters. The plan sponsor is still ultimately responsible for the decisions made in their plan. 5  GGM Financial, LLC Form ADV 2A March 2026 Client-Tailored Services and Client-Imposed Restrictions The goals and objectives for each Client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. These restrictions may, however, prohibit engagement with GGM. Wrap Fee Programs GGM is the sponsor and portfolio manager of the GGM Financial Wrap Fee Program. Please refer to GGM’s Wrap Fee Brochure for more information. Client Assets Under Management As of December 31, 2025, the total amount of client assets under management was $512,964,814. All assets were managed on a discretionary basis; no assets were managed on a non-discretionary basis. Item 5: Fees and Compensation Wealth Management Fees GGM offers Wealth Management services to advisory Clients. GGM charges an annual wealth management fee based on the total assets under management as follows: Assets Under Management Annual Fee Less than $500,000 1.25% $500,000 - $1,000,000 1.15% $1,000,000 - $3,000,000 .85% Additional assets over $3,000,000 .65% This is a blended fee schedule, meaning different asset levels are assessed at different fees, as shown above, and then blended together. Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on the last business day of the previous billing period. Lastly, please note that GGM may group certain related Client accounts, often known as “householding,” for the purposes of achieving the minimum account size and determining the annualized fee. Third-Party Management Fees GGM has entered into a Solicitor Agreement with various TPMs, including Commonwealth, to refer Clients to. The fees charged will be disclosed to the Client in a separate agreement executed directly with the referred TPM. Generally, all fees are withdrawn from the Client’s account unless otherwise noted. The TPM will receive written authorization from the Client to deduct advisory fees from their account held by a qualified custodian. The TPM will then remit to GGM their agreed-upon fee, as GGM does not have access to deduct Client fees. Financial Planning and Consulting Fees – Stand-Alone Services GGM charges a fixed fee for financial planning and consulting. Prior to the planning process, the Client will be provided with an estimated plan fee, which will be based on the complexity of the engagement. For hourly and fixed fee arrangements, services will be completed and delivered within ninety (90) days, 6  GGM Financial, LLC Form ADV 2A March 2026 contingent upon the timely delivery of all required documentation. GGM reserves the right to waive the fee should the Client implement the plan through GGM. Fixed Fee Services are offered based on a fixed fee between $2,500 and $10,000, depending on the complexity of the engagement. Fees are billed 50% in advance, with the balance due upon plan delivery. Wealth Management clients receive financial planning services at no additional fee. Retirement Plan Consulting Fees GGM provides clients with the option of paying an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate not to exceed $500. The fee amount a client will pay is negotiable between the client and the advisor and will be associated with all services provided by the advisor under the Retirement Plan Consulting Agreement. Fees may be paid directly from qualified plan assets or may be direct billed, as agreed between the client and the advisor qualified plan assets or may be direct billed, as agreed between the client and the advisor. Payment of Fees Wealth Management fees shall be deducted from the client’s account on a quarterly basis unless otherwise instructed by the client. For TPM services, the method of payment will be disclosed in the TPM’s Form ADV Part 2. Financial Planning and Consulting Fees are generally invoiced directly to the Client, but may also be deducted from another account held with GGM. Retirement Plan Consulting Fees are generally deducted directly from the Client’s/Plan Assets. GGM, in its sole discretion, may charge a lesser fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). For all services, Clients may terminate their engagement with GGM within five (5) business days of signing an Agreement with no obligation and without penalty. After the initial five (5) business days, the Agreement may be terminated by GGM with thirty (30) days written notice to Client and by the Client at any time with written notice to GGM. For accounts opened or closed during the mid-billing period, fees will be prorated based on the days services are provided during the given period. In the case of hourly engagements, fees will be prorated based on the work completed at the stated hourly rate. All unpaid earned fees will be due to GGM, and all unearned fees will be refunded to the Client. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Additional Fees Custodians may charge brokerage commissions, transaction fees, and other related costs on the purchases or sales of mutual funds, equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds, money market funds, and exchange-traded funds may also charge internal management fees, which are disclosed in the fund’s prospectus. GGM does not directly receive any compensation from these fees. All of these fees are in addition to the management fee you pay to GGM. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Fees Asset Management and some Financial Planning fees are paid in advance. 7  GGM Financial, LLC Form ADV 2A March 2026 External Compensation for the Sale of Securities GGM does not receive any external compensation from the sale of securities. Item 6: Performance-Based Fees and Side-By-Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities. GGM does not use a performance-based fee structure nor “side-by-side” management because of the conflict of interest. Performance-based compensation may create an incentive for GGM to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients GGM provides investment advisory services to: Individuals and families • • High net worth individuals and families • Trusts, estates, or charitable organizations • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses GGM Financials' managed account programs generally have a $500,000 minimum investment requirement. In some cases, account balances may be combined at the household level to satisfy the account minimum. GGM Financial may waive account minimum requirements in our sole discretion. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis and Investment Strategies Investing in securities involves the risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Security analysis methods may include: Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns, and if these patterns can be identified, then a prediction can be made. The risk is that markets do not always follow patterns, and relying solely on this method may not consider new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to cross-check data. Using charting analysis without other methods of analysis would assume that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns, which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns, and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Quantitative analysis deals with measurable factors that are distinguished from qualitative considerations, such as the character of management or the state of employee morale, such as the 8  GGM Financial, LLC Form ADV 2A March 2026 value of assets, the cost of capital, historical projections of sales, and so on. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various assets. In developing a financial plan for a Client, GGM’s analysis may include cash flow analysis, investment planning, risk management, tax planning, and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the SEC. TPMs utilized by GGM may use various methods of analysis to determine the proper strategy for the Client referred, and these will be disclosed in the TPM’s Form ADV Part 2. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Other strategies utilized by TPMs may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options, or spreading strategies). Investment Strategy The investment strategy for a specific Client is based on the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to GGM. Each Client executes a client profile form or similar form that documents their objectives and their desired investment strategy. Risks of Investments and Strategies Utilized Investing in securities involves the risk of loss that Clients should be prepared to bear. GGM’s investment approach constantly keeps the risk of loss in mind. Investors may face the following investment risks: General Investment and Trading Risks. Clients may invest in securities and other financial instruments using strategies and investment techniques with significant risk characteristics. Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next year because purchasing power is eroding at the rate of inflation. Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed-income securities. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Management Risk. The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in 9  GGM Financial, LLC Form ADV 2A March 2026 the expected time frame, the overall performance of the Client’s portfolio may suffer. Cybersecurity Risk. GGM and its service providers may be subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cybersecurity attacks affecting GGM and its service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the release of private information about Clients, impede trading, subject GGM to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which Clients may invest, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including, for example, financial losses, cost and reputational damages, and loss from damage or interruption of systems. Although GGM has established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that GGM does not directly control the cybersecurity measures and policies employed by third-party service providers. Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although a lack of liquidity in an ETF could result in it being more volatile, and ETFs have management fees that increase their costs. ETFs are also subject to other risks, including (i) the risk that their prices may not correlate perfectly with changes in the underlying reference units and (ii) the risk of possible trading halts due to market conditions or other reasons that, in view of the exchange upon which an ETF trades, would make trading in the ETF inadvisable. Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods. A mutual fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations of the overall stock market. Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock. Prices of common stock react to the economic condition of the company that issued the security, industry, and market conditions, as well as other factors that may fluctuate widely. Investments related to the value of stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-related securities, including preferred stock, warrants, and options, may also vary widely. Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap issuers. Securities of small-cap issuers may present greater risks than those of large-cap issuers. For example, some small- and mid-cap issuers often have limited product lines, markets, or financial resources. They may be subject to high volatility in revenues, expenses, and earnings. Their securities may be thinly traded, may be followed by fewer investment research analysts, and may be subject to wider price swings, thus creating a greater chance of loss than when investing in securities of larger- cap issuers. The market prices of securities of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations, corporate developments, and market rumors than the market prices of large-cap issuers. Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold commodities, commodities contracts, and/or derivative instruments, including futures, options, and 10  GGM Financial, LLC Form ADV 2A March 2026 swap agreements. The prices of commodities contracts and derivative instruments, including futures and options, are highly volatile. Payments made pursuant to swap agreements may also be highly volatile. Price movements of commodities, futures and options contracts, and payments pursuant to swap agreements are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary, and exchange control programs and policies of governments, and national and international political and economic events and policies. The value of futures, options, and swap agreements also depends upon the price of the commodities underlying them. In addition, Client assets are subject to the risk of the failure of any of the exchanges on which its positions trade or of its clearinghouses or counterparties. Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of forward and other derivative contracts are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary, and exchange control programs and policies of governments, and national and international political and economic events and policies. Clients are also subject to the risk of failure of any of the exchanges on which their positions trade or of its clearinghouses. Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments in securities of non-U.S. issuers pose a range of potential risks, which could include expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains, or other income, political or social instability, illiquidity, price volatility, and market manipulation. In addition, less information may be available regarding securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing, and financial reporting standards and requirements comparable to or as uniform as those of U.S. issuers. Emerging Markets. Certain ETFs and mutual funds hold securities of emerging market issuers. In addition to the risks associated with investments outside of the United States, investments in emerging markets (i.e., developing countries) may involve additional risks. Emerging markets generally are not as efficient as those in developed countries. In some cases, a market for the security may not exist locally, and transactions will need to be made on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than in developed countries. When seeking to sell emerging market securities, little or no market may exist for the securities. In addition, issuers based in emerging markets are not generally subject to uniform accounting and financial reporting standards, practices, and requirements comparable to those applicable to issuers based in developed countries, thereby potentially increasing the risk of fraud or other deceptive practices. Capitalization Risks. Investing in Companies within the same market capitalization category carries the risk that the category may be out of favor due to current market conditions or investor sentiment. Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the Companies, which could have an adverse effect on each of them. If the securities of the Companies experience poor liquidity, investors may be unable to transact at advantageous times or prices, which may decrease the Company’s returns. In addition, there is a risk that policy changes by central governments and governmental agencies, including the Federal Reserve or the European Central Bank, which could include increasing interest rates, could cause increased volatility in financial markets, which could have a negative impact on the Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events could have a significant impact on the Companies. For example, the rapid and global spread of a highly contagious novel coronavirus respiratory disease designated COVID-19, resulted in 11  GGM Financial, LLC Form ADV 2A March 2026 extreme volatility in the financial markets and severe losses; reduced liquidity of many Companies’ securities; restrictions on international and, in some cases, local travel; significant disruptions to business operations (including business closures); strained healthcare systems; disruptions to supply chains, consumer demand, and employee availability; and widespread uncertainty regarding the duration and long-term effects of the pandemic. Some sectors of the economy and individual issuers experienced particularly large losses. In addition, the COVID-19 pandemic could have resulted, and in some respects did result, in domestic and foreign political and social instability, damage to diplomatic and international trade relations, and increased volatility and/or decreased liquidity in the securities markets. The Companies’ values could decline over short periods due to short-term market movements and over longer periods during market downturns. Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that are not traded on an exchange. Penny Stocks typically trade over-the-counter, such as on the OTC Bulletin Board or Pink Sheets. Penny Stocks, unlike listed stocks, are not subject to SEC reporting requirements or the listing standards of stock exchanges. Because of this, information about the Penny Stock companies can be difficult to find and verify. Penny Stocks also have lower liquidity as they are traded less frequently. This also leads to higher volatility. For these reasons, Penny Stocks are considered to be speculative investments, and Clients who trade in penny stocks should be prepared for the possibility that they may lose their entire investment or an amount in excess of their investment if they purchased Penny Stocks on margin. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment with GGM. Item 9: Disciplinary Information GGM and its management have not been involved in any criminal or civil actions, administrative or self- regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a client’s or prospective Client’s evaluation of GGM or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Other Industry Registrations Neither GGM nor its management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither GGM nor its management persons are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. Relationships Material to this Advisory Business and Possible Conflicts of Interest Investment Advisor Representatives of GGM receive external compensation from sales of investment- related services as Insurance Agents. This represents a conflict of interest because it gives an incentive to recommend services based on the fee amount received. This conflict is mitigated by disclosures, procedures, and GGM’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required to engage the Agent or Agency if they do not wish to. More information on this can be found in the respective Investment Advisor Representative’s Form U4 and ADV 2B. Selection of Other Investment Advisers We do not recommend or select other investment advisers for our clients. 12  GGM Financial, LLC Form ADV 2A March 2026 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The affiliated persons (affiliated persons include employees and/or independent contractors) of GGM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of GGM-affiliated persons and address conflicts that may arise. The Code defines acceptable behavior for affiliated persons of GGM. The Code reflects GGM and its supervised persons’ responsibility to act in the best interest of their Client. One area that the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. GGM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer, or director of GGM may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. GGM’s Code is based on the guiding principle that the interests of the Client are our top priority. GGM’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Client's purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. GGM will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Recommendations Involving Material Financial Interests Neither GGM nor its related persons recommend to Clients, or buys or sells for Client accounts, securities in which GGM or a related person has a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest GGM and its affiliated persons may invest in the same securities (or related securities, e.g., warrants, options, or futures) that GGM or an affiliated person recommends to Clients. In order to mitigate conflicts of interest, such as frontrunning, GGM’s Chief Compliance Officer or their designee will no less than quarterly review the firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage GGM clients. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest GGM and its affiliated persons may recommend securities or buy or sell securities for Clients' accounts at or about the same time that they also buy or sell the same securities in their own account(s). GGM, 13  GGM Financial, LLC Form ADV 2A March 2026 for instance, will place trades in an account in an attempt to earn better-than-money-market rates. In order to mitigate conflicts of interest, such as frontrunning, GGM’s Chief Compliance Officer or their designee will no less than quarterly review the firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage GGM clients. Item 12: Brokerage Practices The Custodians and Brokers We Use GGM Financial does not maintain physical custody of your assets. Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or other financial institution. We primarily recommend that our clients use National Financial Services, a registered broker-dealer, member SIPC, as a qualified custodian. At times, we may utilize other qualified custodians to hold your assets. We are independently owned and operated and are not affiliated with National Financial Services or any other qualified custodian. The qualified custodian will hold your assets in a brokerage account and buy and sell securities with our instruction. While we will recommend a qualified custodian to hold your assets, you will decide whether to do so and will open the account directly at the qualified custodian with our assistance. Not all advisers require their client to use a particular broker-dealer or other custodian selected by the Advisor. However, if you choose not to open an account with one of the qualified custodians we recommend, we will not be able to provide asset management services to you. Consulting services not including asset management will be available in such cases if you desire. How We Select Brokers/Custodians We seek to use a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], limited partnerships) • Availability of investment research and tools that assist us in making investment decisions. • Quality of services • Competitiveness of the price of those services and willingness to negotiate the prices • Reputation, financial strength, and stability • Prior service to us and our other clients • Availability of other products and services that benefit us Your Brokerage and Custody Costs For our clients’ accounts that GGM Financial maintains via National Financial Services, GGM Financial and National Financial Services generally do not charge you separately for custody services but are compensated by charging you commissions or other fees on trades that are executed or settled into your account. Commonwealth’s commission rates applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a total of at least $50,000,000 of their assets in accounts at National Financial Services. For client accounts at Commonwealth, this commitment benefits you because the overall commission rates you pay are lower than they would be otherwise. Because of these factors, in order to minimize your trading costs, we have Commonwealth (via NFS) 14  GGM Financial, LLC Form ADV 2A March 2026 execute most trades for your account(s). We have determined that having Commonwealth/NFS execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Brokers/Custodians”). Periodically, we will review alternative broker-dealers and custodians in the marketplace to ensure that the custodians we use are meeting our duty to provide best execution for our clients. Best execution does not simply mean the lowest transaction cost. When examining firms, we will compare overall expertise, cost competitiveness, and financial condition. The quality of execution by the custodians we use will be reviewed using publicly available trade execution data and other sources as needed. No single criteria will validate nor invalidate a custodian, but rather, all criteria taken together will be used in evaluating the currently utilized custodian. Products and Services Available to Us from Commonwealth and Our Custodians Commonwealth Financial Network provides GGM Financial with various products and services that enable us to both serve our clients and grow our business. Commonwealth (through their disclosed clearing relationships with National Financial Services and Pershing) provide us and our clients with access to its brokerage services— trading, custody, reporting, and related services. Commonwealth also makes available various support services. Some of those services help us manage or administer our client accounts, while others help us manage and grow our business. Following is a more detailed description of Commonwealth’s support services: Services That Benefit You Commonwealth’s brokerage services include access to a broad range of investment products, execution of securities transactions by Commonwealth’s clearing firms, and custody of client assets via their clearing firms. The investment products available through Commonwealth include some that we might not otherwise have access to, or that would require a significantly higher minimum initial investment by our clients. Services That Do Not Directly Benefit You Commonwealth also makes available to us other products and services that benefit our firm and our advisors but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Commonwealth’s and that of third parties. We use this research to service substantially all our client accounts, including accounts not maintained at Commonwealth. In addition to investment research, Commonwealth also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution • Provide pricing and other market data • Facilitate payment of our fees from our client accounts • Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us Commonwealth also offers other services intended to help us manage and further develop our business enterprise. These services include: • Complementary or discounted attendance at conferences and events • Consulting on technology, compliance, legal, and business needs 15  GGM Financial, LLC Form ADV 2A March 2026 • Publications and conferences on practice management and business succession Our Interest in Commonwealth’s Services Our relationship with Commonwealth requires that we maintain a certain level of assets within Commonwealth’s PPS program and/or our own asset management program. This creates an incentive to recommend that you establish and maintain your account with Commonwealth, based on our interest in receiving Commonwealth’s services that benefit our business, rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. To mitigate the conflict, this disclosure is provided to you. As a fiduciary, we must act in your best interests. We believe that our selection of National Financial Services or Pershing (via Commonwealth) as custodian and broker is in the best interests of our clients and conduct regular reviews of our relationship with Commonwealth to ensure this remains the case. Our choice to maintain a relationship with Commonwealth is primarily supported by the scope, quality, and price of Commonwealth’s services (see “How We Select Brokers/Custodians”) and not by Commonwealth’s services that benefit only us. Brokerage for Client Referrals GGM has no referral relationships with any broker-dealer or third party. Directed Brokerage GGM does not allow Client-directed brokerage. Aggregate Client Orders When a Client authorizes discretionary management, GGM is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of GGM. All Clients participating in the aggregated order shall receive an average share price with all other transactions. If aggregation is not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.), an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. GGM will always attempt to aggregate orders whenever it has the opportunity to do so. Item 13: Review of Accounts Periodic Account Reviews GGM’s Investment Advisory Representatives conduct reviews of each asset management account during the quarterly reporting process. These reviews entail comparing the client’s investment objective to the portfolio holdings, cash flows, and changes in the client’s financial position. Additionally, daily reports are reviewed to determine if an account is out of tolerance as compared to its defined allocation. Financial plans are updated as requested by the Client, and pursuant to a new or amended agreement, GGM suggests updating plans at least annually. Non-Periodic Account Reviews In addition to periodic account reviews, GGM reviews client accounts when deposits or withdrawals are made, as well as whenever indicated by client circumstances or planning for life events, such as education or retirement. Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, or when market conditions dictate. 16  GGM Financial, LLC Form ADV 2A March 2026 Reporting Clients receive written account statements no less than quarterly from the Client’s custodian. Clients will also receive confirmations of each transaction in the account from the Custodian and an additional statement during any month in which a transaction occurs. GGM will also provide account reports upon client request, which will provide further analysis of account activity. These reports will generally be provided in electronic format. Item 14: Client Referrals and Other Compensation In connection with the acquisition of Commonwealth by LPL Financial Holdings, Inc. (“LPLH”), on August 1, 2025, GGM Financial advisors received loans that are forgiven over a multi-year term, subject to continued affiliation with Commonwealth, LPL Financial, LLC (“LPL”), a subsidiary of LPLH, or LPLH’s affiliates after the acquisition. The existence of the loans presents a conflict of interest in that our firm and/or our advisors have a financial incentive to maintain our relationship with LPL and/or Commonwealth. However, to the extent we direct clients to LPL and/or Commonwealth for services, it is because the firm believes that it is in that client’s best interest to do so, given our regular review of the firm’s relationship with Commonwealth and/or LPL. GGM does not pay outside individuals or entities to refer clients. Item 15: Custody All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by GGM. GGM is deemed to have limited custody solely because advisory fees are directly deducted from the Client’s accounts by the custodian on behalf of GGM. GGM will obtain written authorization from Client to allow for such deductions. GGM is deemed to have custody of funds for certain accounts where you have established a standing letter of authorization (“SLOA”) that allows us to disburse funds upon your direction to one or more third parties that you designate. We follow seven conditions set forth in the SEC's No-Action Letter on Custody, dated 2/21/2017, which allow us to avoid an annual surprise custody examination. GGM is not affiliated with the custodian. The custodian does not supervise KNFW, its employees, or activities. Item 16: Investment Discretion If applicable, Client will authorize GGM discretionary authority, via the Advisory Services Agreement, to determine, without obtaining specific Client consent, the securities to be bought or sold and the amount of the securities to be bought or sold. If applicable, Client will authorize GGM discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. If, however, consent for discretion is not given, GGM will obtain prior Client approval before executing each transaction. GGM allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to GGM in writing. GGM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. 17  GGM Financial, LLC Form ADV 2A March 2026 Item 17: Voting Client Securities GGM does not vote proxies for securities held in clients’ accounts. Clients receive proxy material directly from their account custodian or broker by either email or U.S. mail. Clients may address questions concerning a proxy matter to GGM personnel via email or phone. Item 18: Financial Information GGM does not solicit prepayment of more than $1,200.00 in fees per client six months or more in advance. At this time, neither GGM nor its management persons have any financial conditions that are likely to reasonably impair its ability to meet contractual commitments to Clients. GGM has not been the subject of a bankruptcy petition in the last ten years. 18 

GGM Financial, LLC 2492 W. Dublin Granville Rd Columbus, OH 43235 Phone (614) 310-2400 www.ggmfin.com Wrap Fee Program Brochure March 2026 Item 1: Cover Page This wrap fee program brochure provides information about the qualifications and business practices of GGM Financial, LLC (“GGM”). If you have any questions about the contents of this brochure, please contact us at compliance@ggmfin.com or (614) 310-2400. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. GGM Financial, LLC is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. Additional Information about GGM Financial, LLC also is available on the SEC’s website at www.advisorinfo.sec.gov.  GGM Financial, LLC Wrap Fee Brochure March 2026 Item 2: Material Changes This is the initial filing of this brochure. 2  GGM Financial, LLC Wrap Fee Brochure March 2026 Item 3: Table of Contents Item 1: Cover Page .............................................................................................................................. 1 Item 2: Material Changes ..................................................................................................................... 2 Item 3: Table of Contents .................................................................................................................... 3 Item 4: Services, Fees, & Compensation ............................................................................................. 4 Item 5: Account Requirements and Types of Clients ............................................................................ 6 Item 6: Portfolio Manager Selection and Evaluation ............................................................................. 6 Item 7: Client Information Provided to Portfolio Managers ................................................................. 11 Item 8: Client Contact with Portfolio Managers .................................................................................. 12 Item 9: Additional Information ............................................................................................................ 12 3  GGM Financial, LLC Wrap Fee Brochure March 2026 Item 4: Services, Fees, & Compensation GGM Financial, LLC (“GGM Financial”) is a registered investment adviser, based in Columbus, Ohio, offering financial planning and asset management services to clients. GGM Financial has been in business since 2002, and its principal owners are Brady Green, Matthew Collins, and Karen Bauman. Description of the Types of Advisory Services GGM provides Wealth Management Services to advisory clients. Wealth Management Services combine Asset Management Services with Financial Planning Services. GGM offers these services through the GGM Financial Wrap Fee Program. GGM will offer Clients ongoing Asset Management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. Discretionary When the Client elects to use GGM on a discretionary basis, the Client will sign a limited trading authorization or equivalent allowing GGM to determine the securities to be bought or sold and the amount of the securities to be bought or sold. GGM will have the authority to execute transactions in the account without seeking Client approval on each transaction. FINANCIAL PLANNING AND CONSULTING Services include an evaluation of a client’s current and future financial state using currently known variables to predict future cash flows and asset values, recommend purchase and sales, and withdrawal plans. GGM will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Financial planning analysis consists of the following steps: • Initial Client meeting to determine project scope • Presentation of a formal agreement between Client and GGM Financial • Compilation of required financial information, evaluation of current position, and identification and prioritization of the Client’s financial goals • Presentation of the final plan to the Client, which may include: o Analysis of current position o Goal needs, which may include retirement, educational funding, cash flow, estate planning, tax planning, and/or income/asset protection recommendations Topics for planning may include, but are not limited to: • Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress toward financial goals. • Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings, and investment each month. • Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution. • Long-term investment plan: Build a customized asset allocation strategy based on specific investment objectives and a risk profile. This strategy sets guidelines for selecting, buying, and selling investments and establishing benchmarks for performance review. 4  GGM Financial, LLC Wrap Fee Brochure March 2026 • Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include the identification of tax-favored investment vehicles that can reduce taxation of investment income. • Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. If a conflict of interest exists between the interests of GGM and the interests of the Client, the Client is under no obligation to act upon GGM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through GGM. GGM offers Wealth Management services to advisory Clients. GGM charges an annual wealth management fee based on the total assets under management as follows: Assets Under Management Annual Fee Less than $500,000 1.25% $500,000 - $1,000,000 1.15% $1,000,000 - $3,000,000 .85% Additional assets over $3,000,000 .65% This is a blended fee schedule, meaning different asset levels are assessed at different fees, as shown above, and then blended together. Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on the last business day of the previous billing period. Lastly, please note that GGM may group certain related Client accounts, often known as “householding,” for the purposes of achieving the minimum account size and determining the annualized fee. Wealth Management fees shall be deducted from the client’s account on a quarterly basis unless otherwise instructed by the client. For all services, Clients may terminate their engagement with GGM within five (5) business days of signing an Agreement with no obligation and without penalty. After the initial five (5) business days, the Agreement may be terminated by GGM with thirty (30) days written notice to Client and by the Client at any time with written notice to GGM. For accounts opened or closed during the mid-billing period, fees will be prorated based on the days services are provided during the given period. In the case of hourly engagements, fees will be prorated based on the work completed at the stated hourly rate. All unpaid earned fees will be due to GGM, and all unearned fees will be refunded to the Client. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Fee Comparison Clients may be able to purchase services similar to those offered under the Program from other service providers either separately or as part of a similar wrap fee program. These services or programs may cost more or less than our Program, depending on the fees charged by such other service providers. For example, the Program Fee, which is fixed regardless of the number of transactions occurring in the account, may be more or less than paying for execution on a per-transaction basis. 5  GGM Financial, LLC Wrap Fee Brochure March 2026 Additional Fees GGM pays all custodian fees and transaction fees for all accounts under this Program. However, custodians may charge other related costs on the purchases or sales of mutual funds, equities, bonds, options, margin interest, and mark-ups, markdowns, or spreads paid to market makers. Mutual funds, money market funds, and exchange-traded funds may also charge internal management fees, which are disclosed in the fund’s prospectus. GGM does not directly receive any compensation from these fees. Additional Compensation GGM nor its employees receive compensation, other than the portfolio management fee, for the recommendation to the Client or the Client’s participation in the Program. Item 5: Account Requirements and Types of Clients GGM provides investment advisory services to: Individuals and families • • High net worth individuals and families • Trusts, estates, or charitable organizations • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses GGM Financials' managed account programs generally have a $500,000 minimum investment requirement. In some cases, account balances may be combined at the household level to satisfy the account minimum. GGM Financial may waive account minimum requirements in our sole discretion. Item 6: Portfolio Manager Selection and Evaluation Portfolio Manager Selection and Evaluation GGM is the sole Portfolio Manager and Advisor for the Program. GGM develops each portfolio strategy around each Client’s unique financial goals. The portfolio development process includes: • Determining the timing targets of the client's goals • Analyzing the individual risk/return comfort level • Developing specific investment strategies using a variety of investment methods (shown below) to match the client's total situation • Monitoring the investment mix in an ongoing manner • Providing ongoing meaningful communication between the advisor and the Client, assuring the investment plan is in concert with the total financial and family situations as they are now and as they evolve. The following industry standards may be used to evaluate the Portfolio Manager’s performance in security selection: • Morningstar Risk Rating (is the holding’s measure should be equal to or better than its return rating; a risk rating of average or lower is better than high; favorable example: low risk rating and average return rating) • Morningstar Return Rating (the investment’s rating should be equal to or better than its risk rating; a return rating of average or higher is better than low; unfavorable example: high risk rating and average return rating) 6  GGM Financial, LLC Wrap Fee Brochure March 2026 • Alpha (how an investment’s return compares with the returns of its peer group); the investment’s 3-year alpha should show no difference or a positive difference between its total return and the return of its peer group. • Sharpe Ratio (evaluates a Mutual Fund’s or Exchange Traded Fund’s risk-adjusted performance); The Sharpe Ratio is calculated by taking the excess return of a portfolio, relative to the risk-free rate, and dividing it by the Standard Deviation of the portfolio’s excess returns (Standard Deviation is a statistical measure of volatility over a period of time). The higher a portfolio’s Sharpe Ratio, the better its risk-adjusted performance. • Morningstar Category (this identifies the investment’s general investment category; stocks have nine categories: large company, mid-cap company and small company for each of the growth, core, and value stock styles; bonds also have nine categories: short, intermediate, and long maturities for each of the high, medium, and low-quality ratings) The investment should be in the same category it was selected to fulfill in the portfolio’s allocation strategy. There is a natural potential conflict of interest with the Portfolio Manager conducting the ongoing review of the standards by which the Portfolio Manager’s selection and management have been acceptable. The fact that the measures are completely objective, are provided by Morningstar, a well-known investment data provider, and are not subject to manipulation acts to mitigate this potential conflict. Related Persons as Program Managers GGM is the only Portfolio Manager for the Program. We do not offer access to additional Portfolio Managers, but offer one fee to our Clients in order to eliminate concerns regarding variable transaction costs. To the extent that we receive the Program Fee as a result of recommending it, we are in a conflict of interest with our Clients. Additional Program Information Client-Tailored Services and Client-Imposed Restrictions The goals and objectives for each Client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. These restrictions may, however, prohibit engagement with GGM. Performance-Based Fees and Side-By-Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities. GGM does not use a performance-based fee structure nor “side-by-side” management because of the conflict of interest. Performance-based compensation may create an incentive for GGM to recommend an investment that may carry a higher degree of risk to the Client. Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis and Investment Strategies Investing in securities involves the risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Security analysis methods may include: Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns, and if these patterns can be identified, then 7  GGM Financial, LLC Wrap Fee Brochure March 2026 a prediction can be made. The risk is that markets do not always follow patterns, and relying solely on this method may not consider new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to cross-check data. Using charting analysis without other methods of analysis would assume that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns, which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns, and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Quantitative analysis deals with measurable factors that are distinguished from qualitative considerations, such as the character of management or the state of employee morale, the value of assets, the cost of capital, historical projections of sales, and so on. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or, equivalently, minimize risk for a given level of expected return, each by carefully choosing the proportions of various assets. In developing a financial plan for a Client, GGM’s analysis may include cash flow analysis, investment planning, risk management, tax planning, and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the SEC. TPMs utilized by GGM may use various methods of analysis to determine the proper strategy for the Client referred, and these will be disclosed in the TPM’s Form ADV Part 2. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Other strategies utilized by TPMs may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options, or spreading strategies). Investment Strategy The investment strategy for a specific Client is based on the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to GGM. Each Client executes a client profile form or similar form that documents their objectives and their desired investment strategy. Risks of Investments and Strategies Utilized Investing in securities involves the risk of loss that Clients should be prepared to bear. GGM’s investment approach constantly keeps the risk of loss in mind. Investors may face the following investment risks: General Investment and Trading Risks. Clients may invest in securities and other financial instruments using strategies and investment techniques with significant risk characteristics. Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market 8  GGM Financial, LLC Wrap Fee Brochure March 2026 values to decline. Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next year because purchasing power is eroding at the rate of inflation. Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed-income securities. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Management Risk. The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. Cybersecurity Risk. GGM and its service providers may be subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cybersecurity attacks affecting GGM and its service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the release of private information about Clients, impede trading, subject GGM to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which Clients may invest, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including, for example, financial losses, cost and reputational damages, and loss from damage or interruption of systems. Although GGM has established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that GGM does not directly control the cybersecurity measures and policies employed by third-party service providers. Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although a lack of liquidity in an ETF could result in it being more volatile, and ETFs have management fees that increase their costs. ETFs are also subject to other risks, including (i) the risk that their prices may not correlate perfectly with changes in the underlying reference units and (ii) the risk of possible trading halts due to market conditions or other reasons that, in view of the exchange upon which an ETF trades, would make trading in the ETF inadvisable. Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods. A mutual fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations of the overall stock market. Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock. Prices of common stock react to the economic condition of the company that issued the security, industry, and market conditions, as well as other factors that may fluctuate widely. Investments related to the value of stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes 9  GGM Financial, LLC Wrap Fee Brochure March 2026 in management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-related securities, including preferred stock, warrants, and options, may also vary widely. Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap issuers. Securities of small-cap issuers may present greater risks than those of large-cap issuers. For example, some small- and mid-cap issuers often have limited product lines, markets, or financial resources. They may be subject to high volatility in revenues, expenses, and earnings. Their securities may be thinly traded, may be followed by fewer investment research analysts, and may be subject to wider price swings, thus creating a greater chance of loss than when investing in securities of larger- cap issuers. The market prices of securities of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations, corporate developments, and market rumors than the market prices of large-cap issuers. Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold commodities, commodities contracts, and/or derivative instruments, including futures, options, and swap agreements. The prices of commodities contracts and derivative instruments, including futures and options, are highly volatile. Payments made pursuant to swap agreements may also be highly volatile. Price movements of commodities, futures and options contracts, and payments pursuant to swap agreements are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary, and exchange control programs and policies of governments, and national and international political and economic events and policies. The value of futures, options, and swap agreements also depends upon the price of the commodities underlying them. In addition, Client assets are subject to the risk of the failure of any of the exchanges on which its positions trade or of its clearinghouses or counterparties. Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of forward and other derivative contracts are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary, and exchange control programs and policies of governments, and national and international political and economic events and policies. Clients are also subject to the risk of failure of any of the exchanges on which their positions trade or of its clearinghouses. Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments in securities of non-U.S. issuers pose a range of potential risks, which could include expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains, or other income, political or social instability, illiquidity, price volatility, and market manipulation. In addition, less information may be available regarding securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing, and financial reporting standards and requirements comparable to or as uniform as those of U.S. issuers. Emerging Markets. Certain ETFs and mutual funds hold securities of emerging market issuers. In addition to the risks associated with investments outside of the United States, investments in emerging markets (i.e., developing countries) may involve additional risks. Emerging markets generally are not as efficient as those in developed countries. In some cases, a market for the security may not exist locally, and transactions will need to be made on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than in developed countries. When seeking to sell emerging market securities, little or no market may exist for the securities. In addition, issuers based in emerging markets are not generally subject to uniform accounting and financial reporting standards, practices, and 10  GGM Financial, LLC Wrap Fee Brochure March 2026 requirements comparable to those applicable to issuers based in developed countries, thereby potentially increasing the risk of fraud or other deceptive practices. Capitalization Risks. Investing in Companies within the same market capitalization category carries the risk that the category may be out of favor due to current market conditions or investor sentiment. Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the Companies, which could have an adverse effect on each of them. If the securities of the Companies experience poor liquidity, investors may be unable to transact at advantageous times or prices, which may decrease the Company’s returns. In addition, there is a risk that policy changes by central governments and governmental agencies, including the Federal Reserve or the European Central Bank, which could include increasing interest rates, could cause increased volatility in financial markets, which could have a negative impact on the Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events could have a significant impact on the Companies. For example, the rapid and global spread of a highly contagious novel coronavirus respiratory disease designated COVID-19, resulted in extreme volatility in the financial markets and severe losses; reduced liquidity of many Companies’ securities; restrictions on international and, in some cases, local travel; significant disruptions to business operations (including business closures); strained healthcare systems; disruptions to supply chains, consumer demand, and employee availability; and widespread uncertainty regarding the duration and long-term effects of the pandemic. Some sectors of the economy and individual issuers experienced particularly large losses. In addition, the COVID-19 pandemic could have resulted, and in some respects did result, in domestic and foreign political and social instability, damage to diplomatic and international trade relations, and increased volatility and/or decreased liquidity in the securities markets. The Companies’ values could decline over short periods due to short-term market movements and over longer periods during market downturns. Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that are not traded on an exchange. Penny Stocks typically trade over-the-counter, such as on the OTC Bulletin Board or Pink Sheets. Penny Stocks, unlike listed stocks, are not subject to SEC reporting requirements or the listing standards of stock exchanges. Because of this, information about the Penny Stock companies can be difficult to find and verify. Penny Stocks also have lower liquidity as they are traded less frequently. This also leads to higher volatility. For these reasons, Penny Stocks are considered to be speculative investments, and Clients who trade in penny stocks should be prepared for the possibility that they may lose their entire investment or an amount in excess of their investment if they purchased Penny Stocks on margin. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment with GGM. Voting Client Securities GGM does not vote proxies for securities held in clients’ accounts. Clients receive proxy material directly from their account custodian or broker by either email or U.S. mail. Clients may address questions concerning a proxy matter to GGM personnel via email or phone. Item 7: Client Information Provided to Portfolio Managers GGM is the sole Portfolio Manager of the Program and collects and shares nonpublic information (such as financial information, investment objectives, and risk tolerance) about Clients to aid in providing appropriate and suitable investment advice. Nonpublic personal information about 11  GGM Financial, LLC Wrap Fee Brochure March 2026 Clients will be shared consistent with the disclosures made on GGM’s Privacy Policy. Item 8: Client Contact with Portfolio Managers Clients are always free to directly contact their Portfolio Manager(s) with any questions or concerns they have about their portfolios or other matters. Item 9: Additional Information Disciplinary Information GGM and its management have not been involved in any criminal or civil actions, administrative or self- regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a client’s or prospective Client’s evaluation of GGM or the integrity of its management. Other Financial Industry Activities and Affiliations Other Industry Registrations Neither GGM nor its management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither GGM nor its management persons are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. Relationships Material to this Advisory Business and Possible Conflicts of Interest Investment Advisor Representatives of GGM receive external compensation from sales of investment- related services as Insurance Agents. This represents a conflict of interest because it gives an incentive to recommend services based on the fee amount received. This conflict is mitigated by disclosures, procedures, and GGM’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required to engage the Agent or Agency if they do not wish to. More information on this can be found in the respective Investment Advisor Representative’s Form U4 and ADV 2B. Selection of Other Investment Advisers We do not recommend or select other investment advisers for our clients. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The affiliated persons (affiliated persons include employees and/or independent contractors) of GGM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of GGM-affiliated persons and address conflicts that may arise. The Code defines acceptable behavior for affiliated persons of GGM. The Code reflects GGM and its supervised persons’ responsibility to act in the best interest of their Client. One area that the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. GGM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer, or director of GGM may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. 12  GGM Financial, LLC Wrap Fee Brochure March 2026 GGM’s Code is based on the guiding principle that the interests of the Client are our top priority. GGM’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Client's purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. GGM will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Recommendations Involving Material Financial Interests Neither GGM nor its related persons recommend to Clients, or buys or sells for Client accounts, securities in which GGM or a related person has a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest GGM and its affiliated persons may invest in the same securities (or related securities, e.g., warrants, options, or futures) that GGM or an affiliated person recommends to Clients. In order to mitigate conflicts of interest, such as frontrunning, GGM’s Chief Compliance Officer or their designee will no less than quarterly review the firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage GGM clients. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest GGM and its affiliated persons may recommend securities or buy or sell securities for Clients' accounts at or about the same time that they also buy or sell the same securities in their own account(s). GGM, for instance, will place trades in an account in an attempt to earn better-than-money-market rates. In order to mitigate conflicts of interest, such as frontrunning, GGM’s Chief Compliance Officer or their designee will no less than quarterly review the firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage GGM clients. Review of Accounts Periodic Account Reviews GGM’s Investment Advisory Representatives conduct reviews of each asset management account during the quarterly reporting process. These reviews entail comparing the client’s investment objective to the portfolio holdings, cash flows, and changes in the client’s financial position. Additionally, daily reports are reviewed to determine if an account is out of tolerance as compared to its defined allocation. Financial plans are updated as requested by the Client, and pursuant to a new or amended agreement, GGM suggests updating plans at least annually. Non-Periodic Account Reviews In addition to periodic account reviews, GGM reviews client accounts when deposits or withdrawals are made, as well as whenever indicated by client circumstances or planning for life events, such as education or retirement. Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, or when market conditions dictate. 13  GGM Financial, LLC Wrap Fee Brochure March 2026 Reporting Clients receive written account statements no less than quarterly from the Client’s custodian. Clients will also receive confirmations of each transaction in the account from the Custodian and an additional statement during any month in which a transaction occurs. GGM will also provide account reports upon client request, which will provide further analysis of account activity. These reports will generally be provided in electronic format. Client Referrals and Other Compensation In connection with the acquisition of Commonwealth by LPL Financial Holdings, Inc. (“LPLH”), on August 1, 2025, GGM Financial advisors received loans that are forgiven over a multi-year term, subject to continued affiliation with Commonwealth, LPL Financial, LLC (“LPL”), a subsidiary of LPLH, or LPLH’s affiliates after the acquisition. The existence of the loans presents a conflict of interest in that our firm and/or our advisors have a financial incentive to maintain our relationship with LPL and/or Commonwealth. However, to the extent we direct clients to LPL and/or Commonwealth for services, it is because the firm believes that it is in that client’s best interest to do so, given our regular review of the firm’s relationship with Commonwealth and/or LPL. GGM does not pay outside individuals or entities to refer clients. Financial Information GGM does not solicit prepayment of more than $1,200.00 in fees per client six months or more in advance. At this time, neither GGM nor its management persons have any financial conditions that are likely to reasonably impair its ability to meet contractual commitments to Clients. GGM has not been the subject of a bankruptcy petition in the last ten years. 14