GLASS LAKES CAPITAL MANAGEMENT LLC

Item 1 - Cover Page Glass Lakes Capital Management LLC Registered Investment Adviser CRD # 290064 6580 W. 95th Street/Suite 100 Overland Park, KS 66212 913-647-9555 www.glasslakes.com Form ADV Part 2A Firm Brochure May 15, 2026 This brochure provides information about the qualifications and business practices of Glass Lakes Capital Management LLC. Please contact Joel Hamilton at 913-647-9555 if you have any questions about the content of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities administrator. Additional information about Glass Lakes Capital Management LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD (“CRD”) number, which is 290064. Although the firm and its associates may be notice-filed (“registered”) and/or licensed within a particular jurisdiction it does not imply an endorsement by any regulatory authority nor infers a certain level of skill or training on the part of the firm or its associated personnel. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 1 of 26  Item 2 - Material Changes This Form ADV Part 2A firm brochure has been revised pursuant to Glass Lakes Capital Management LLC’s registration as an investment adviser with the SEC, superseding previous versions. This document has been modified to address disclosure requirements for an SEC-registered firm and therefore clients and prospective clients are encouraged to review the document in its entirety. Updates include our reportable assets under management (Item 4), fee schedule and processing (Item 5), amended risk statements (Item 8), how we serve client accounts (Items 15 and 16), among others. While this registration transition does not change the scope of services we provide or our fiduciary obligation to clients, certain regulatory oversight and disclosure requirements regarding activities involving investment advisers now fall under SEC rules rather than state-level jurisdictions where we have operated in the past. The firm may at any time update this document and either send a copy of its updated brochure or provide a summary of material changes to its brochure and an offer to send an electronic or hard copy form of the updated brochure. Clients are also able to download this brochure from the SEC’s website at www.adviserinfo.sec.gov or contact our firm at 913-647-9555 to request a copy at any time. As with all firm documents, clients and prospective clients are encouraged to review this brochure in its entirety and are encouraged to ask questions at any time prior to or throughout the engagement. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 2 of 26  Item 3 - Table of Contents Item 1 - Cover Page ............................................................................................................................................. 1 Item 2 - Material Changes ................................................................................................................................... 1 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 ............................................................... 9 Item 9 - Disciplinary Information ....................................................................................................................... 15 Item 10 - Other Financial Industry Activities and Affiliations ............................................................................ 15 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 16 Item 12 - Brokerage Practices ........................................................................................................................... 18 Item 13 - Review of Accounts ............................................................................................................................ 22 Item 14 - Client Referrals and Other Compensation ......................................................................................... 23 Item 15 - Custody .............................................................................................................................................. 23 Item 16 - Investment Discretion ........................................................................................................................ 24 Item 17 - Voting Client Securities ...................................................................................................................... 25 Item 18 - Financial Information ......................................................................................................................... 25 Important Information Throughout this document Glass Lakes Capital Management LLC may be referred to as “the firm,” “firm,” “our,” “we” or “us.” The client or prospective client may be also referred to as “the client,” “client,” etc., and refers to a client engagement involving a single person as well as two or more persons and may refer to natural persons and legal entities. The term “advisor” and “adviser” are used interchangeably where accuracy in identification is necessary (i.e., internet address, etc.). Our firm maintains a business continuity and succession plan that is integrated within the organization to ensure it appropriately responds to events that pose a significant disruption to its operations. A statement concerning the current plan is available under separate cover upon request. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 3 of 26  Item 4 - Advisory Business Description of Firm Glass Lakes Capital Management LLC is a Kansas limited liability company formed in August of 2017. The firm’s original registration as a Kansas investment adviser occurred in 2017, followed by the firm’s registration with the SEC in 2026. Our firm and its associates are notice-filed or exempt from notice filing or registration in state jurisdictions where our investment advisory business activities are conducted.1 Our firm is not a subsidiary of, nor does it control, another financial services industry entity. Joel T. Hamilton, CFA, CFP® is the firm’s Principal and Chief Compliance Officer (supervisor). He is also Managing Member and maintains majority interest in the firm. Additional information about Mr. Hamilton and his professional experience may be found in his accompanying Form ADV Part 2B brochure supplement. Description of Services An initial interview is conducted by a representative of the firm to determine the scope of services to be provided. During or prior to this meeting the prospective client will be provided with our Form ADV Part 3 (Form CRS), Form ADV Part 2A firm brochure, privacy policy statement, as well as the Form ADV Part 2B brochure supplement about their investment adviser representative. In addition, the firm will ensure it has disclosed any material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and objective advice, such as information found in Items 10 and 12 of this brochure. If you wish to engage our firm for its services, we must first execute an engagement agreement. Thereafter further discussion and analysis will be conducted to determine financial needs, goals, holdings, etc. Depending on the scope of the engagement, you may be asked to provide copies of the following documents early in the process: • wills, codicils, and trusts • insurance policies, including information about riders, loans and amendments • mortgage information • tax returns • student loans • divorce decree or separation agreement • current financial specifics including W-2s, 1099s, K-1 statements, etc. • information on current retirement plans and other benefits provided by an employer • statements reflecting current investments in retirement and non-retirement accounts • employment or other business agreements, and • completed risk profile questionnaires or other forms provided by our firm. It is important that we are provided with an adequate level of information and supporting documentation throughout the term of the engagement including but not limited to source of funds, income levels, and an account holder or an attorney-in-fact authority to act on behalf of the account, among other information that may be necessary for our services. The information and/or financial statements provided to us need to be accurate. Our firm may, but is not obligated to, verify the information that has been provided to us which will then be used in the advisory process. 1 State jurisdictions where a firm is currently notice filed can be determined via the SEC’s website at www.adviserinfo.sec.gov. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 4 of 26  Financial Planning Services For those interested in areas such as cash flow and budgeting, education funding, retirement planning, risk management, estate planning, plan or portfolio analysis, as well as periodic investment advice (e.g., retirement plan allocation, etc.), we offer our financial planning services. Our planning services may be as broad-based or narrowly focused as desired by the client. The incorporation of most or all components allows not only a thorough analysis but also a refined focus of your plans so that the firm is able to assist you in reaching your goals and objectives. Each financial planning client will receive a written plan and/or allocation report in printed or digital format at the end of the process that is customized for their situation and objectives. Educational Workshops We provide complimentary educational seminar sessions involving personal finance and investing. Topics may include issues related to general financial planning, educational funding, estate planning, retirement strategies, implications involving changes in marital status, and various other current economic or investment topics. Our workshops are educational in nature and do not involve the solicitation of insurance or investment products. Portfolio Management Services We are available to assist you in implementing investment strategies that we have recommended to you. Depending on your risk profile, goals and needs, among other considerations, your portfolio will involve the employment of one of our investment strategies as well as either a broad range or more narrowly focused choice of investment vehicles which are further discussed in Item 8 of this brochure. We prepare written investment guidelines reflecting your objectives, time horizon, tolerance for risk, as well as any reasonable account constraints you may have for the portfolio. For example, you have the right to exclude certain securities (e.g., options, stocks, etc.) at your discretion. These guidelines will be designed to be specific enough to provide future guidance while allowing flexibility to work with changing market conditions. Since this effort is the product of information and data you have provided, you may be asked to review it and provide your final approval. We will then develop a customized portfolio for you based on your unique situation, investment goals and tolerance for risk. We manage your portfolio on a discretionary or nondiscretionary basis (defined in Item 16). We want to note that it will remain your responsibility to promptly notify us if there is any change in your financial situation and/or investment objectives for the purpose of our reviewing, evaluating or revising previous account restrictions or firm investment recommendations. We may recommend a client engage an institutional investment manager to serve their portfolio. Prior to recommending a third-party investment manager or sub-adviser (collectively, investment manager), we will conduct what we believe to be an appropriate level of due diligence that includes ensuring the investment manager is appropriately registered or notice-filed within the client’s state of residence. Clients may be required to maintain a minimum account size to be eligible for these services, and certain investment managers may require a higher asset-level to invest in their program. We will inform the client in advance of each investment manager’s minimum investment criteria. Under this type of engagement, we will gather input from the client about their financial situation, investment objectives, reasonable restrictions they want to impose on the management of the account, and we will then provide this information to the investment manager to develop the portfolio. Investment managers will invest on behalf of a client account in accordance with the strategies set forth in their own disclosure documents which will be provided to the client by our firm prior to employing their strategies. The selected investment manager assumes discretionary authority over an account (see Item 16), and some of these programs may not be available for Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 5 of 26  those clients who prefer an account to be managed under a nondiscretionary engagement or who may have other unique account restrictions. At least annually thereafter a review will be performed from both a compliance and performance perspective to determine whether the selected investment manager remains an appropriate fit for the portfolio. Glass Lakes Capital Management LLC may incorporate model portfolios for clients’ accounts that are made available through the firm’s preferred custodian platform (identified in Item 12). Portfolio models are designed to be straightforward, transparent and easy to understand. Leveraging an asset allocation framework, they use a behavior-based approach to encourage positive investor behavior and help clients stay invested through all types of market events. We also offer a wrap fee investment program that is designed for investors that intend to maintain at least $50,000 of investible assets with our firm and whose investment profile necessitates active portfolio management. Within the wrap program engagement we incorporate various advisory services and associated costs into a single asset-based fee, such as our investment management fee and associated transaction charges. We ask that interested eligible parties review our firm’s separate Form ADV Part 2A - Appendix 1 Wrap Fee Program Brochure for further details. As of April 8, 2026, our firm had over $178.3 million of reportable client assets under our management2 on a discretionary basis. Item 5 - Fees and Compensation Forms of payment are based on the types of services being provided, terms of service, etc., and will be stated in your engagement agreement with our firm. Our published fees are negotiable, and we typically waive or discount our fee for associates of our advisory firm and their family members. We strive to offer fees that are fair and reasonable in light of the experience of our firm and the services to be provided to you. Comparable services may be provided by other advisers, potentially for a lower fee. Financial Planning and Education Workshops We believe every client should have a basic knowledge and understanding of their goals and objectives, as well as a foundation -- a plan. As such, we do not charge a fee for our educational workshops or financial planning sessions, whether your plan is broad-based or narrowly focused. Portfolio Management Services We do not require a minimum account size to open and maintain an investment account, nor do we assess account opening and/or administration fees to initiate our portfolio management services. For the benefit of discounting our asset-based fee, we will aggregate accounts within the same household unless instructed by the client not to do so. We assess an annualized asset-based fee for our services up to 1.50% (150 basis points) depending on account size, advisory services required, and as agreed with you in advance. One basis point equals 1/100 of one percent. The advisory fee is paid to our firm quarterly, in advance or in arrears per the engagement agreement, and will be based on the account’s value each billing period as calculated using the following formula: (quarterly account market value) x (applicable number of basis points) ÷ 4 (quarters). Example: A portfolio management account maintaining $1,000,000 of investible assets being assessed a one percent asset-based fee will pay a quarterly fee of $2,500. Formula: ($1,000,000 x 100 bps) = $10,000 (annualized fee) ÷ 4 (quarters) = $2,500 (quarterly fee). 2 The term “assets under management” and rounding per the SEC’s General Instructions for Part 2 of Form ADV. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 6 of 26  In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such an opinion at their own expense as to the valuation of “hard-to-price” securities if they believe it to be necessary. The firm does not bill accounts off-cycle; we only bill on a quarterly basis. Therefore, on any deposits or withdrawals exceeding $50,000 per day we will credit or debit the account for partial periods on a prorated basis during the following quarter’s billing cycle. Fee payments will generally be assessed within the first 15 calendar days of each billing cycle. Your written authorization is required in order for the custodian of record to deduct our advisory fee from your account. By signing our firm’s engagement agreement, as well as the custodian account opening documents, you will be authorizing the custodian to withdraw both advisory fees and any transactional fees from your account. The custodian will remit our fees directly to our firm. Fees deducted from your account will be noted on statements that you will receive directly from your custodian of record.3 We encourage you to verify the accuracy of fee calculations; the custodian may not verify the accuracy of advisory fee assessments for each account or on a consistent basis. Alternatively, you may request to directly pay our advisory firm its portfolio management fee in lieu of having the advisory fee withdrawn from your investment account. A client’s direct payment must be received by our firm within 15 days of our invoice.4 Our firm does not accept cash, money orders or similar forms of payment for its engagements. Third-Party Investment Management Each third-party investment manager program has a stated fee range that will be described using that investment manager’s disclosure documents and prior to the selection of the investment manager. The third-party investment manager’s annualized asset-based fee ranges from 0.10% to 0.75% (10 to 75 basis points); paid in advance or arrears per the selected investment manager’s disclosure. The third-party investment manager’s fee is separate from our advisory fee and is billed separately from ours.5 Additional Client Fees Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees, qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account holder per the custodian of record’s separate fee schedule. We will provide you with a copy of our custodian’s fee schedule at the beginning of the engagement, and you will be notified of any future changes to those fees by the custodian of record and/or third-party administrator for certain tax-qualified plans. Additional information about our fees in relationship to our “brokerage” practices is noted in Item 12 of this document. Fees paid by our clients to our firm for our advisory services are separate from any internal fees or charges a client may pay for mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other similar investments. If a sub-adviser or model portfolio is used within your account, the fee assessed (in addition to our advisory fee) will range from 0.01% to 0.75% (1 to 75 bps).5 3 Periodic account value variances between the firm’s invoice and custodian statement (beyond the firm’s control) may occur due to late trade settlement, dividend distribution, etc., requiring adjusted transaction reporting from the custodian of record. 4 Our invoice will include the total fee assessed, covered time period, calculation formula utilized, and reference to the assets under management in which the fee had been based. 5 Combined asset-based fees will not exceed three percent (3.00% of assets under management) which is considered an excessive fee. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 7 of 26  Per annum interest at the current statutory rate based on the state in which the client resides may be assessed on fee balances due more than 30 days, and we may refer past due accounts to collections or legal counsel for processing. We reserve the right to suspend some or all services once an account is deemed past due. External Compensation involving Transactions Our firm does not charge or receive a commission or a mark-up on securities transactions, nor will the firm or an associate be paid commission on the purchase of a securities holding that is recommended to a client. We do not receive SEC Rule 12b-1 fees (“trails”) from a mutual fund company that may be recommended to a client. Fees charged by such issuers are detailed in prospectuses or product descriptions and interested our clients are encouraged to read these documents before investing. Our firm and its associates receive none of these described or similar fees or charges. Clients retain the right to purchase recommended or similar investments through a provider of their choice. Our firm policy prohibits associates from accepting or receiving additional economic benefit, such as sales awards or other prizes, for providing advisory services to our clients. Termination of Services Either party may terminate the agreement at any time by communicating their intent to terminate in writing. A new client may terminate an agreement with our firm within five business days after the signing of our engagement agreement without penalty or charge. Our firm will not be responsible for investment allocation, advice or transactional services (except for limited closing transactions) upon receipt of a termination notice. It will also be necessary that we inform the custodian of record and/or investment manager that the relationship between parties has been terminated. When a portfolio management services client terminates their agreement after the five business-day rescission period, that client will be assessed fees on a prorated basis for services incurred from either (i) as a new client, the date of the engagement to the date of the firm’s receipt of the written notice of termination, or (ii) all other accounts, the last billing period to the date of the firm’s physical or constructive receipt of written termination notice. Our firm will return any prepaid, unearned fees within 30 days of termination notice. We will coordinate remuneration of prepaid asset-based fees to a client’s investment account. Return of prepaid fees will never involve a personal check, cash or money order from our firm or from an associate of our firm. If we are unable to deduct our fees from the client’s account at the custodian of record, then our earned fees will be due upon the client’s receipt of our invoice. Item 6 - Performance-Based Fees and Side-By-Side Management Our firm’s advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any portion of managed funds, also known as performance-based fees. Our fees will also not be based on side- by-side management, which refers to a firm simultaneously managing accounts that do pay performance- based fees (such as a hedge fund) and those that do not. Item 7 - Types of Clients Glass Lakes Capital Management LLC provides its services to individuals, high net worth individuals, and charitable organizations. Our firm does not require minimum income, asset levels or other similar preconditions noted in this document. We will inform you in advance of any minimum criteria should a sub- Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 8 of 26  adviser or third-party investment manager be engaged. We have established a minimum account size of $50,000 for our wrap program which is described in further detail in our separate wrap fee program brochure. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We utilize what we believe to be an appropriate blend of fundamental and technical analyses. We evaluate various economic factors including interest rates, the current state of the economy, or the future growth of an industry sector. We then study historical market patterns and trends to assist us in determining the direction of market as well as specific securities. Our research is often drawn from sources such as:  financial periodicals  reports from economists and other industry professionals  company press releases  corporate rating services  inspection of corporate activities, and  regulatory filings, such as annual reports, prospectuses, etc. Investment Strategies We recognize that each client's needs and goals are different; subsequently, portfolio strategies and underlying investment vehicles may vary. Our portfolios contain investment vehicles that are globally diversified, tax-efficient and low-cost whenever practical. It is common to find a broad range of ETFs or mutual funds within a portfolio, as well as incorporating individual stocks and bond positions when appropriate. We frequently utilize a Core + Satellite investment strategy; blending passive and active investing, where passive investments are used as the basis or “core” of a portfolio and actively managed investments are added as “satellite” positions. The portfolio core holdings are indexed to potentially more efficient asset classes, while outlying selections are generally limited to active holdings to outperform a particular category (sector), or a selection of positions to increase core diversification, or to improve portfolio performance. For example, the core of a portfolio may be built with index funds or ETFs; satellite holdings would include active investments (e.g., equities) with unique strategies that are believed capable of adding value beyond a stated benchmark over a full market cycle. Risk of Loss Our firm believes its strategies and investment recommendations are designed to produce the appropriate potential return for the given level of risk; however, there is no guarantee that a planning goal or investment objective will be achieved. Past performance is not necessarily indicative of future results. Investing in securities involves risk of loss that clients should be prepared to bear. While the following list is not exhaustive, we provide some examples of such risk in the following paragraphs, and we believe it is important that our clients review and consider each prior to investing. Active Management A portfolio that employs active management strategies may, at times, outperform or underperform various benchmarks or other strategies. To meet or surpass these benchmarks, active portfolio management may require more frequent trading or “turnover.” This may result in shorter holding periods, higher transactional costs and/or taxable events generally borne by the client, thereby potentially reducing or negating certain benefits of active asset management. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 9 of 26  Catastrophic Risk Natural or man-made catastrophes can disrupt financial markets and impact securities prices. Examples include terrorist attacks, natural disasters, war, etc. Investment companies can use "exigent circumstances" or "force majeure" as a defense against claims of loss by investors. Company Risk When investing in securities, such as stocks, there is always a certain level of company or industry-specific risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification. Core + Satellite Strategies Strategies involving Core + Satellite investing may have the potential to be affected by “active risk” (or “tracking error risk”), which might be defined as a deviation from a stated benchmark. Since the core portfolio attempts to closely replicate a stated benchmark, the source of the tracking error or deviation may come from a satellite portfolio or position, or from a “sample” or “optimized” index fund or ETF that may not as closely align the stated benchmark. Country/Regional Risk World events such as political upheaval, financial troubles, or natural disasters will adversely affect the value of securities issued in foreign countries or regions. This risk is especially high in emerging markets where securities may be substantially more volatile and less liquid than securities in more developed countries. Because an ETF may invest a large portion of its assets in securities located in any one country or region, including emerging markets, its performance may be hurt disproportionately by the poor performance of its investments in that area. Currency Risk The risk of loss from fluctuating foreign exchange rates when a portfolio has exposure to foreign currency or in foreign currency traded investments is known as currency risk. Emerging Markets Securities Some of the underlying assets in an ETF or mutual fund may involve emerging market securities which can be considered speculative and subject to heightened risks, in addition to the general risks of investing in foreign securities. Unlike more established markets, emerging markets may have governments that are less stable, markets that are less liquid, and economies that are less developed. In addition, the securities markets of emerging market countries may consist of companies with smaller market capitalizations and may suffer periods of relative illiquidity; significant price volatility; restrictions on foreign investment; and possible restrictions on repatriation of investment income and capital. Foreign investors may be required to register the proceeds of sales, and future economic or political crises could lead to price controls, forced mergers, expropriation or confiscatory taxation, seizure, nationalization, or creation of government monopolies. Equity (Stock) Risk Common stocks are susceptible to general stock market fluctuations and to volatile increases or decreases in value as market confidence in and perceptions of their issuers change. If an investor held common stock or Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 10 of 26  common stock equivalents of any given issuer, they may be exposed to greater risk than if they held preferred stocks and debt obligations of the issuer. Preferred stocks can be affected by interest rate and liquidity risks (described in adjacent paragraphs). Also note that their dividend payment is not guaranteed; some are subject to a call provision, meaning the issuer can redeem its preferred shares on demand, and usually when interest rates have fallen. ETF Risks ETF risks include risks due to their underlying securities (e.g., stocks, bonds, etc.), and can be affected by risks such as market, currency, interest rate, etc., that are described in adjacent paragraphs. The liquidity of the underlying stocks in the index can affect “ETF liquidity.” Liquidity risk can result from an insufficient number of “active participants” performing their duties as intermediaries and liquidity providers in the ETF market. “Spread risk” may also occur, which is the difference between the bid and the ask price of a security. Since ETF transactions are priced throughout the day and are traded on exchanges like stocks, widening spreads may occur and have an impact on certain portfolios or transactions. As with any security, if the ETF “fails,” the investor may lose their gains and invested principal. ETFs can carry additional expenses based on their share of operating expenses and certain brokerage fees. Indexed ETFs have the potential to be affected by “active risk;” a deviation from its stated index. While many ETFs are known for their potential tax-efficiency and higher “qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be a holding within an ETF), may be considered “non-qualified” under certain tax code provisions. A holding’s QDI will be considered when tax-efficiency is an important aspect of the client’s portfolio. Leveraged and/or inverse ETFs attempt to achieve multiples of the performance of an index or benchmark through the opposite (inverse) of the performance of the tracked index or benchmark. This strategy attempts to profit from, or hedge exposures to, downward drifting markets. There is risk involving this strategy and part of the concern is because leveraged and inverse exchange-traded funds "reset" daily, which means they are designed to achieve their stated objectives on a daily basis. It is due to the compounding effect of daily adjustments that ETF performance over longer periods of time can differ significantly from the performance (or inverse of the performance) of an underlying index or benchmark during the same period. This effect is potentially magnified during volatile markets. If effects contrary to the ETF strategy occur, losses may be significant; therefore, leveraged and/or inverse ETFs will be considered for portfolios either properly hedged or for clients able to sustain potentially higher risks. Leveraged and inverse ETFs will not be recommended for portfolios where a "buy-and-hold" philosophy is important. Failure to Implement Each financial planning client is free to accept or reject any or all the recommendations made by our firm. While no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients who choose not to take the steps recommended in their financial plan may face an increased risk that their stated goals and objectives will not be achieved. Fixed Income Risks Various forms of fixed income instruments, such as bonds, money market or bond funds/ETFs may be affected by various forms of risk, including: Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 11 of 26   Call Risk - During periods of falling interest rates, issuers of callable bonds may call (redeem) securities with higher coupons or interest rates before their maturity dates. The owner of the bond would then lose any potential price appreciation above the bond’s call price and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the owner’s income. Call risk is generally low for short-term bonds, moderate for intermediate-term bonds, high for long-term bonds, and high for high-yield bonds.  Credit Risk - The potential risk that an issuer would be unable to pay scheduled interest or repay principal at maturity, sometimes referred to as “default risk.” Credit risk may also occur when an issuer’s ability to make payments of principal and interest when due is interrupted. Bondholders are creditors of an issuer and have priority over assets before equity holders (e.g., stockholders) when receiving a payout from liquidation or restructuring. When defaults occur due to bankruptcy, the type of bond held will determine seniority of payment.  Interest Rate Risk - The risk that the value of the fixed income holding will decrease because of an increase in interest rates. The longer the maturity of the bond, the more sensitive its value is to changes in interest rates. Bond prices and interest rate changes are inversely correlated.  Prepayment Risk - The prepayment risk is the premature return of principal on a fixed-income security. When principal is returned early on a security, future interest payments will not be paid on that part of the principal. The owner of the security would lose any price appreciation above the principal and be forced to reinvest the unanticipated proceeds possibly at lower interest rates, resulting in a decline of dividends, income, and returns. The risk of prepayment is most prevalent in fixed-income securities such as callable bonds and mortgage-backed securities.  Reinvestment Risk - With declining interest rates, investors may have to reinvest interest income or principal at a lower rate.  State Government and Municipal Securities Risk - State government and municipal securities are subject to various risks based on factors such as economic and regulatory developments, changes or proposed changes in the federal and state tax structure, deregulation, court rulings and other factors. Repayment of state and municipal securities depends on the ability of the issuer or project backing such securities to generate taxes or revenues. There is also a risk that the interest on an otherwise tax- exempt municipal security may be subject to federal income tax. Unfavorable developments in any economic sector may have far-reaching ramifications on the overall state and municipal market.  US Government Securities Risk - US government securities are subject to varying interest rates and inflation risks. Not all US government securities are backed by the full faith and credit of the US government. Certain securities issued by agencies and instrumentalities of the US government are only insured or guaranteed by the issuing agency or instrumentality, which must rely on its own resources to repay the debt. As a result, there is a risk these entities will default on a financial obligation. Foreign Securities Risk Investments in securities of foreign companies (including direct investments as well as investments through American Depository Receipts – aka. ADRs) can be more volatile than investments in US-based companies. Diplomatic, political, or economic developments, including nationalization or appropriation, could affect investments in foreign companies. Foreign securities markets generally have less trading volume and less Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 12 of 26  liquidity than US markets. In addition, the value of securities denominated in foreign currencies, and of dividends from these securities, can change significantly when foreign currencies strengthen or weaken relative to the US dollar. Financial statements of foreign issuers are governed by different accounting, auditing, and financial reporting standards than the financial statements of US issuers and may be less transparent and uniform than in the United States. Thus, there may be less information publicly available about foreign issuers than about most US issuers. Transaction costs generally are higher than those in the US and expenses for custodial arrangements of foreign securities may be somewhat greater than typical expenses for custodial arrangements of similar US securities. Some foreign governments levy withholding taxes against dividend and interest income. Although in some countries a portion of these taxes are recoverable, the non-recovered portion will reduce the income received from the securities comprising an account’s portfolio. These risks may be heightened with respect to emerging market countries since political turmoil and rapid changes in economic conditions are more likely to occur in these countries. Fundamental Analysis The challenge involving fundamental analyses is that information obtained may be incorrect; the analysis may not provide an accurate estimate of earnings, which may be the basis for a security’s value. If a security’s price adjusts rapidly to new information, a fundamental analysis may result in unfavorable performance. Inflation Risk Also called purchasing power risk, is the chance that the cash flows from an investment won’t be worth as much in the future because of changes in purchasing power due to inflation. Legal or Legislative Risk Legislative changes or court rulings may adversely impact the value of individual investments, market sectors, or the overall market. Liquidity Risk Liquidity risk is the inability to readily buy or sell an investment for a price close to the true underlying value of the asset due to a lack of buyers or sellers. While certain types of fixed income are generally liquid (e.g., bonds), there are risks which may occur such as when an issue trading in any given period does not readily support buys and sells at an efficient price. Conversely, when trading volume is high, there is also a risk of not being able to purchase a particular issue at the desired price. Market Risk This is also called systematic risk. In cases where markets are under extreme duress, many securities lose their ability to provide diversification benefits. Money Market Funds A money market fund is managed to maintain a stable net asset value (NAV) of $1 per share, the value of the fund may fluctuate, and you could lose money (termed “breaking the buck”). Money market funds are a type of mutual fund investing in high-quality, short-term debt securities, pay dividends that generally reflect short-term interest rates and seek to maintain a stable NAV per share (typically $1). An investment in a money market mutual fund is typically not insured or guaranteed by the Federal Deposit Insurance Corporation, National Credit Union Association, or any governmental agency. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 13 of 26  Mutual Funds As with ETFs, the risk of owning an open-ended, closed-ended, and fund-of-fund mutual funds is reflected in the underlying security(ies). Mutual funds are affected by risks such as market, interest rate, currency, credit, political, active risk, etc., as described in adjacent paragraphs. It is important to note that even “conservative” funds, such as a money market fund or fixed income fund, can and have lost their value below the principal amount invested. Mutual funds typically carry additional expenses based on their share of operating expenses and trading (brokerage) fees, which may result in the potential duplication of certain fees paid by the investor. Indexed mutual funds can also be adversely affected by “QDI ratios” that are described above. There are essentially nine main types of mutual fund shares classes, as well as sub-classes for some of these. Some mutual funds are sold through brokerage firms and assess a commission (“load) in addition to their underlying fees earlier noted, while others are offered through investment advisers, retirement plans and other institutions. “No load” funds are also available to the public through brokerage firms, and they usually incur trading (brokerage) fees. If a client chooses to purchase a mutual fund on their own through a broker/dealer, they should consider the trading fees, internal operating costs, as well as potential commissions they pay through that executing broker or dealer. Our investment advisory firm and its personnel are not associated with a broker/dealer and are not compensated by a “loaded” fund. Operational Risk The potential for loss from inadequate or failed internal processes, systems, actions of people, or external events. Many industries institute policies and procedures to respond and initiate alternative or supporting operations following significant business disruption, while others do not. The level of operational risk and appropriate response are not uniform in definition, requirement, or measurement, including within the financial services sector. Passive Management A passive portfolio has the risk of generating lower-than-expected returns due to its broad diversification when compared to a more narrowly focused portfolio. Political Risk The risk of financial and market loss because of political decisions or disruptions in a particular country or region, and may also be known as "geopolitical risk." Research Data When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice on or investment management of an account. Sequence of Return Risk The risk of receiving lower or negative returns due to early withdrawals from an investment account. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 14 of 26  Settlement Risk Also called delivery risk. The risk that one party will fail to deliver the terms of an investment contract with another party (contra-party) at the time of settlement. Settlement risk can be a risk associated with default, along with any timing differences in a settlement between the two parties. Small- and Mid-Capitalization Company Risk The small- and mid-capitalization companies in which an account may invest may be more vulnerable to adverse business or economic events than larger, more established companies. Investments in these small- and mid-sized companies may pose additional risks, including liquidity risk, because these companies tend to have limited product lines, markets, and financial resources, and may depend upon a relatively small management group. Small- and mid-cap stocks, therefore, may be more volatile than those of larger companies. These securities may be traded over the counter or listed “off-exchange.” Sub-Advisers/Third-Party Investment Managers We will review with the client the Form ADV Part 2A of any recommended external investment adviser to ensure the client is familiar with the investment strategy and types of investment vehicles they employ so that they align with the client’s investment objectives, as well as discuss the risks these may impose on the account. Our firm does not control the daily business and compliance operations of the external advisers that the firm may recommend or utilize to manage a client portfolio, and the firm may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputation deficiencies. Technical Analysis The risk of investing based on technical analyses is that it may not consistently predict a future price movement; the current price of a security may reflect all known information. This may occur due to analyst bias or misinterpretation, a sector analysis error, late recognition of a trend, etc. Item 9 - Disciplinary Information Neither the firm nor its management has been involved in any criminal or civil action in a domestic, foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization proceeding that would reflect poorly upon our offering advisory business or its integrity. Item 10 - Other Financial Industry Activities and Affiliations Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of interest between the firm and its clients, or that may be contrary to law. Glass Lakes Capital Management LLC will provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of interest involving its business relationships that might reasonably compromise its impartiality or independence. Our firm and its management are not registered nor have an application pending to register as a Financial Industry Regulatory Authority (FINRA) or National Futures Association (NFA) member firm or associated person of such a firm. We are not required to be registered with such entities, nor do they supervise our firm, its activities or our associates. Neither the firm nor its management is or has a material relationship with any of the following types of entities:  accountant or accounting firm  another financial planning firm Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 15 of 26   bank, credit union or thrift institution, or their separately identifiable departments or divisions  insurance company or insurance agency  lawyer or law firm  pension consultant  real estate broker, dealer or adviser  sponsor or syndicator of limited partnerships  trust company  issuer of a security, to include investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) The sub-advisers or third-party investment managers that we recommend to a client are required to be registered with the SEC or a state securities commissioner as an investment adviser (most often they are SEC-registered investment advisers). Both our firm and the external investment manager are paid an advisory fee by the client, as noted in Item 5, for engaging in the selected investment strategy and will be memorialized in the client agreement. We believe we mitigate compensation conflicts of interest since the external investment manager’s fees are separate from our firm’s advisory fee, and our clients retain the right to reject using any external investment manager for their portfolio. Based on our fee structure, we do not earn higher or additional fees from a client if a particular investment manager is chosen over another. As a fiduciary, we will act in the best interests of our clients when recommending an external investment manager. However, there is the potential for clients’ fees assessed via these engagements to be higher than had a client obtained them directly from the other investment manager or if the client purchases similar underlying investments on their own. It should be noted that certain investment managers and/or underlying investments may not be available to self-directed investors or at the same cost. Clients are encouraged to review all our service offerings, and their stated fees prior to the engagement, and each client has the right to purchase recommended or similar investments through their own provider. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Glass Lakes Capital Management LLC is a fiduciary; subsequently, our firm and its associates will act in the utmost good faith, performing in a manner believed to be in the best interest of our clients. We believe that our business methodologies, ethics rules, and adopted policies are designed to eliminate or at least minimize material conflicts of interest, and to appropriately manage any material conflicts of interest that may remain. It is important to point out that no set of rules can anticipate or relieve all material conflicts of interest. Our firm will disclose to its advisory clients any material conflict of interest relating to the firm, its representatives, or any of its employees which could reasonably be expected to impair the rendering of unbiased and objective advice. Code of Ethics We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and professionally responsible manner in all professional services and activities. Firm policies include prohibitions against insider trading, circulation of industry rumors, and certain political contributions, among others. We periodically review and amend our Code of Ethics to ensure that they remain current, and we require firm personnel to annually attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 16 of 26  CFA Principles An associate that is a Chartered Financial Analyst (CFA) also adheres to the CFA Institute’s Code of Ethics and Standards of Professional which you may find at www.cfainstitute.org. CFP® Principles Firm associates that are CERTIFIED FINANCIAL PLANNER® Practitioners also adhere to the Certified Financial Planner Board of Standards, Inc.’s Code of Ethics & Professional Responsibility which you may find at www.cfp.net. Privacy Policy Statement We respect the privacy of all clients and prospective clients (collectively termed “customers” per federal guidelines), both past and present. It is recognized that clients have entrusted our firm with non-public personal information, and it is important that both access persons and customers are aware of firm policy concerning what may be done with that information. The firm collects personal information about customers from the following sources: • information provided to us complete their plan or investment recommendation • information provided via engagement agreements and other documents completed in connection with the opening and maintenance of an account • information customers provide verbally, and • information received from service providers, such as custodians, about client transactions. The firm does not disclose non-public personal information about our customers to anyone, except in the following circumstances when: • required to provide services our customers have requested, • our customers have specifically authorized us to do so, • required during a firm assessment (i.e., independent audit), or • permitted or required by law (i.e., periodic regulatory examination). To ensure security and confidentiality, our firm maintains physical, electronic, and procedural safeguards to protect the privacy of customer information. Within the firm, access to customer information is restricted to personnel that need to know that information. All access persons and service providers understand that everything handled in firm offices is confidential and they are instructed not to discuss customer information with someone else that may request information about an account unless they are specifically authorized in writing by the customer to do so. This includes providing information about a family member’s account. The firm will provide customers with its privacy policy at any time, in advance, if firm privacy policies are expected to change. Firm Recommendations and Conflicts of Interest Our associates are prohibited from borrowing from or lending to a client unless the client is an approved financial lending institution (e.g., bank, broker/dealer, etc.). Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 17 of 26  Neither our firm nor its associates are authorized to recommend to a client, or effect a transaction for a client, involving any security in which our firm or a “related person” (associates, their immediate family members, etc.) has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc. Our firm does not trade in its own account (proprietary trading). Our firm’s related persons may buy or sell securities that are the same as, similar to, or different from, those we recommend to clients for their accounts. A recommendation made to one client may be different in nature or in timing from a recommendation made to a different client. Clients often have different objectives and risk tolerances. At no time will our firm or any related party receive preferential treatment over our clients. We mitigate this conflict by ensuring that we have policies and procedures in place to ensure that the firm or a related person will not receive preferential treatment over a client. In order to reduce or eliminate certain conflicts of interest involving personal trading (e.g., trading ahead of client recommendations or trades, etc.), firm policy requires that we restrict or prohibit certain related parties’ transactions. Any exceptions must be approved in writing by our Chief Compliance Officer, and personal trading accounts are reviewed on a quarterly or more frequent basis. Please refer to Item 6 of the accompanying Form ADV Part 2B for further details. Item 12 - Brokerage Practices Factors Used to Select Broker/Dealers for Client Transactions Your accounts must be separately maintained by a qualified custodian (generally a broker/dealer or national bank) that is frequently reviewed for its capabilities to serve in that capacity by their respective industry regulatory authority. Our firm is not a custodian, there is not an affiliate that is a custodian, nor does a custodian supervise our firm, its activities or our associates. We are listed as a resource on our custodian’s website, but we do not compensate our custodian for that recommendation, nor would referrals from a custodian be a factor in our recommendation of a custodian. Accounts served by a third-party investment manager are to be maintained at one or more custodians that have been selected by the respective third-party investment manager, and they will be disclosed in the third-party investment manager’s disclosure documents and account opening forms. We have entered into an agreement with Charles Schwab & Co., Inc. (“Schwab”) to serve as custodian for our clients. Schwab is a FINRA and SIPC member,6 and an SEC-registered broker/dealer. While we recommend that you use Schwab as custodian, you must decide whether to do so, and you will open the account by entering into an account agreement directly with Schwab. We do not technically open the account for you, but we will assist you in doing so. If you do not wish to place your account assets with Schwab, we may be able to manage the account at your preferred custodian depending on that custodian’s account trading policies. We seek to use a custodian who will hold client assets and execute transactions on terms that are overall advantageous when compared to other available providers and their services. Our firm considers a wide range of factors, including, among others, these:  combination of transaction execution services along with asset custody services (generally without a separate fee for custody) 6 Our advisory firm is not, nor required to be, a Securities Investor Protection Corporation (SIPC) member. Clients may learn more about the SIPC and how it serves member firms and the investing public by going to their website at http://www.sipc.org. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 18 of 26   capability to execute, clear and settle trades (buy and sell securities for an account)  capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)  breadth of investment products made available (stocks, bonds, mutual funds, ETFs, etc.)  availability of investment research and tools that assist us in making investment decisions  quality of services  competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them  reputation, financial strength and stability of the provider  their prior service to us and our other clients, and  availability of other products and services that benefit us, as discussed below. When your account is maintained at Schwab, you are typically not charged separately for custody services and Schwab is compensated by charging a commission or fee on trades that Schwab executes or that settle into a Schwab account. Schwab’s rates applicable to our client accounts were negotiated based on our commitment to maintain a certain amount of clients’ assets in accounts held at Schwab. This commitment benefits our client because overall fees may be lower than they would have been if we had not made the commitment. Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory firms similar to ours. They provide our firm and its clients with access to its institutional brokerage - trading, custody, reporting and related services - many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available to us on an unsolicited basis (we don’t have to request them) and at no charge to us if we keep a certain level of our clients’ assets in accounts at Schwab. Our custodian’s institutional services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. Schwab’s services described in previous paragraphs generally benefit our clients. Schwab also makes available to our advisory firm other products and services that benefit us but may not directly benefit each client’s account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  provides access to client account data (such as duplicate trade confirmations and account statements)  facilitates trade execution and allocates aggregated trade orders for multiple client accounts  provides pricing and other market data  facilitates payment of our fees from our clients’ accounts, and  assists with back-office functions, recordkeeping and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise, such as:  educational conferences and events  technology, compliance, legal, and business consulting  publications and conferences on practice management and business succession, and  access to employee benefits providers, human capital consultants and insurance providers. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 19 of 26  Schwab may provide some of these services itself. In other cases, they may arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Some of the noted tools and services made available by Schwab may benefit our advisory firm but may not directly benefit a client account. While our firm does not think these services are considered "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934, certain jurisdictions where we serve client accounts believe they fall under this definition. However, the availability of these services benefits our firm because we do not have to produce or purchase them if clients maintain assets in accounts at our recommended custodian. There is a conflict of interest since our firm has an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than the client’s interest in receiving favorable trade execution. It is important to mention that the benefit received by our firm through participation in a custodian’s program does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a whole, not just those services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the custodian we may select. Our firm conducts periodic assessments of any recommended service provider which generally involves a review of the range and quality of services, reasonableness of fees, among other items, in comparison to industry peers. Best Execution “Best execution” means the most favorable terms for a transaction based on all relevant factors, including those listed in the earlier paragraphs. We recognize our obligation in seeking best execution for our clients; however, it is our belief that the determinative factor is not always the lowest possible cost but whether the selected custodian’s transactions represent the best “qualitative execution” while taking into consideration the full range of services provided. Our firm will seek services involving competitive rates, but it may not necessarily correlate to the lowest possible rate for each transaction. We have determined that having our clients’ accounts trades completed through our recommended custodian is consistent with our obligation to seek best execution of client trades. A review is regularly conducted regarding recommending a custodian to our clients in light of our duty to seek best execution. Glass Lakes Capital Management LLC may, in its discretion and following custodian approval, accept a client’s transfer of preexisting “retail” (“loaded”) mutual funds into their account. A transfer-in-kind of retail share-class mutual funds may potentially benefit the client since they are able to invest in their portfolio more quickly, mitigate tax and/or short-term trading liabilities, and/or avoid contingent deferred sales charges (CDSC). Our firm regularly reviews accounts that have transferred different share classes of mutual funds and will convert share classes into a lower expense share class when we believe doing so would be beneficial to the client. In addition, if account assets remain in a retail share class and within a CDSC period, we may exclude those assets from our advisory fee until they have been converted into what we believe is a more appropriate share class. While our firm has access to a broad range of securities through our custodian, it is a finite number. In addition, not all investment managers (mutual funds), share classes, etc., are represented at each custodian. Due to these normal and customary limitations, not all portfolio holdings will be readily available, least expensive, best performing, etc. It is an unrealistic expectation for an investor to maintain a premise otherwise. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 20 of 26  Directed Brokerage Our internal policy and operational relationship with our custodian require client accounts custodied with them to have trades executed per their order routing requirements. We do not direct which executing broker should be selected for client account trades, whether that is an affiliate of our preferred custodian or another executing broker of our custodian’s choice. As a result, the client may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net prices on transactions than might otherwise be the case. In addition, since we routinely recommend a custodian to our advisory clients, and that custodian may choose to use the execution services of its broker affiliate for some or all our client account transactions, there is an inherent conflict of interest involving our recommendation since our advisory firm receives various products or services described above from that custodian. Note that we are not compensated for trade routing/order flow, nor are we paid commissions on such trades. We do not receive interest on an account’s cash balance. Client accounts maintained at our custodian are unable to direct brokerage. As a result, they may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case if they had the opportunity to direct brokerage. For accounts maintained at a custodian of the client’s choice (e.g., held-away accounts), the client may choose to request that a particular broker is used to execute some or all account transactions. Under these circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or arrangements involving their account with that broker, and whether the selected broker is affiliated with their custodian of record or not. We will not be obligated to seek better execution services or prices from these other brokers, and we will be unable to aggregate transactions for execution via our custodian with other orders for accounts managed by our firm. As a result, the client may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case. Aggregating Securities Transactions Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. This may also be termed “blocked” or “batched” orders. Aggregated orders are effected to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple client accounts should there be differences in prices, brokerage commissions or other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm may, but is not obligated, aggregate orders, and our firm does not receive additional compensation or remuneration because of aggregated transactions. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that the firm determines to aggregate client orders for the purchase or sale of securities, including securities in which a related person may invest, the firm will generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. Note that when trade aggregation is not allowed or infeasible and necessitates individual transactions (e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may have assessed higher costs or less favorable prices than those where aggregation has occurred. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 21 of 26  We review firm trading processes on a periodic basis to ensure they remain within stated policies and regulations. Our clients will be informed, in advance, when our trading practices change at any point in the future. Item 13 - Review of Accounts Scheduled Reviews Portfolios that we supervise are reviewed on a quarterly or more frequent basis by the client’s investment adviser representative. We encourage scheduled financial check-ups and client-level portfolio reviews to occur on an annual basis whenever practical. Reviews will be conducted by the client’s investment adviser representative and typically involve analysis and possible revision of your previous financial plan or investment allocation. A copy of revised plans or asset allocation reports in printed or digital format will be provided to the client upon request. For those accounts served by a recommended third-party investment manager, the client’s investment adviser representative will periodically review reports provided to the client by the third-party investment manager. Our firm will contact the client at least annually to review the client’s financial situation and objectives. We will communicate information to the selected third-party investment manager as warranted and will assist the client in understanding and evaluating the services provided by that investment manager. In certain instances, the client may be able to communicate directly with their investment manager, which we will need to coordinate in advance. Interim Reviews You should contact our firm for additional reviews when you anticipate or have experienced changes in your financial situation (i.e., changes in employment, an inheritance, the birth of a new child, etc.), or if you prefer to change requirements involving your account. Interim reviews are conducted by Mr. Hamilton. A copy of revised plans or asset allocation reports in printed or digital format will be provided to the client upon request. Additional reviews by an investment manager and/or the client’s investment adviser representative may be triggered by news or research related to a specific holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector. A portfolio may be reviewed for an additional holding or when an increase in a current position is under consideration. Account cash levels above or below what we deem appropriate for the investment environment, given the client's stated tolerance for risk and investment objectives, may also trigger a review. Client Reports Whether you have opened and maintained an investment account on your own or with our assistance, you will receive account statements sent directly from your account custodian where your investments are held. We urge you to carefully review these account statements for accuracy and clarity, and to ask questions when something is not clear. Our firm utilizes third party performance calculating software that is calculated using time-weighted return methodologies. Internal rate of return (dollar-weighted) methodologies is made available where the two methods differ significantly due to the size and timing of cash flows into and out of the portfolio. These reports are provided in printed and digital format and are reviewed for accuracy by the client’s investment adviser representative prior to their delivery. Our reports are intended to inform clients about investment Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 22 of 26  performance over the current period, as well as over the longer term since the account’s inception; both on an absolute basis and as compared to a known benchmark. We do not back-test or certify reports from an external party. Clients are urged to carefully review and compare account statements that they have received directly from their custodian of record with any report they may receive from our firm or any other source that contains investment performance information. Item 14 - Client Referrals and Other Compensation Please refer to Items 5, 10 and 12 for information with respect to our offerings/services and the potential conflicts of interest they present. Our firm does not participate in or receive economic benefit from any sales awards or other similar prizes involving its investment advisory activities. If we receive or offer an introduction to a client, we do not pay or earn referral fees, nor are there established quid pro quo arrangements. Each client retains the option to accept or deny such referral or subsequent services. An associate of the firm may hold individual membership or serve on boards or committees of professional industry associations. Generally, participation in any of these entities require membership fees to be paid, adherence to ethical guidelines, as well as in meeting experiential and educational requirements. A benefit these entities may provide to the investing public is the availability of online search tools that allow interested parties (prospective clients) to search for individual participants within a selected state or region. These passive websites may provide means for interested people to contact a participant via electronic mail, telephone number, or other contact information, to interview the participating member. The public may also choose to telephone staff to inquire about an individual within their area and would receive the same or similar information. A portion of these participant’s membership fees may be used so that their name will be listed in some or all these entities’ websites (or other listings). Prospective clients locating our advisory firm or an associate via these methods are not actively marketed by the noted associations, nor will they be the recipient of a testimonial or endorsement. Clients who find our firm in this way do not pay more for their services than clients referred to us in any other fashion. The firm does not pay these entities for prospective client referrals, nor is there a fee-sharing arrangement reflective of a solicitor engagement. Item 15 - Custody Funds and securities will be maintained by an unaffiliated, qualified custodian, such as a bank, broker/dealer, mutual fund companies, or transfer agent. Account assets are not held by our firm or any of our associates. In keeping with this policy involving our clients’ accounts, our firm:  restricts the firm or an associate from having general power of attorney over a client account  restricts the firm or an associate from serving as trustee over a client account (unless it is an immediate family member)  does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm  prohibits the firm or an associate from having the client’s bank or investment account access information (i.e., passwords and user identification)  will not collect advance fees of $1,200 or more for services that are to be performed six months or more into the future, and  prohibits associates from having authority to directly withdraw securities or cash assets from a client account. Although we may be deemed to have limited (aka. constructive or indirect) custody of an account since we may request the withdrawal of advisory fees from an investment account, we will do so only on the following terms: Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 23 of 26  o our firm will possess written authorization from the client to deduct advisory fees from an account held by their custodian of record o we will send the client’s qualified, unaffiliated custodian a notice of the amount of the fee to be deducted from the client’s account, and o the client must be able to receive an account statement directly from the account custodian.  does not allow standing letters of authority (SLOAs) unless the: o client provides written instruction to their qualified custodian that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed o client authorizes the firm in writing on their qualified custodian’s form any power to direct transfers to the third party either on a specified schedule or from time to time o client’s qualified custodian performs appropriate verification of the client’s instructions, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer o client can terminate or change the instruction to the client’s qualified custodian o firm has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction o third party is not a related party to our firm and is located at a different address as the firm o client’s qualified custodian sends the client a written initial notice confirming the instruction, and o client is annually provided notice reconfirming their instructions. The client’s custodian of record will provide account transaction confirmations and account statements, which include debits and credits, as well as our firm’s advisory fee for that period. Statements are provided on at least a quarterly basis or as transactions occur within an account. We urge all our clients to inform us if they are not receiving their trade confirmations or account statements from their custodian. Our firm will not create a separate account statement for a client nor serve as the sole recipient of a client account statement. Item 16 - Investment Discretion We will account for any reasonable restrictions involving the management of the client’s account (i.e., no sin stocks, avoiding international holdings, etc.). It remains the client’s responsibility to notify us if there is any change in their situation and/or investment objective so that we may reevaluate previous investment recommendations or portfolio holdings. Our clients retain the right to amend our account authority, in writing. We typically serve portfolio management accounts on a discretionary basis. Via limited power of attorney, clients grant our firm the authority to implement investment decisions, such as the purchase or sale of a security on behalf of an account, without requiring the client’s prior authorization for each transaction to meet stated investment objectives. This authority will be provided by the client through the execution of both our engagement agreement and the custodian’s account opening documents. Note that the custodian will specifically limit our firm’s authority within an account for the placement of trade orders and our request for the deduction of our advisory fees. On a case-by-case basis, our firm may manage a client portfolio on a nondiscretionary basis. This type of account authority requires the client’s ongoing prior approval involving the investment and reinvestment of account assets, and portfolio rebalancing. The client will be required to execute our firm’s client services Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 24 of 26  agreement that describes our limited account authority, as well as the custodian of record’s account opening document that includes their limited power of attorney form or clause. Considering trading pre- approval requirements, the client must make themselves available and keep our firm updated on their contact information so that instructions can be efficiently effected on their behalf. Nondiscretionary accounts are generally unable to be aggregated (see Item 12) and may therefore be assessed higher trading fees or receive less favorable prices than those accounts where trade aggregation has occurred. Third-party investment managers and sub-advisers generally provide their services on a discretionary basis. This authority will be provided by the client through the execution of third-party management or sub- adviser’s agreement and custodian documents. If a client requires their account to be managed on a nondiscretionary basis, it is important to note that most third-party investment managers and sub-advisers retain the right to either refuse or terminate an account or will continue to manage the account under a higher asset-based fee due to increased operational costs. We will inform clients in advance of the recommended external investment manager’s requirements involving account trading authority. Note that our firm also typically has discretionary authority over a client account under this type of engagement. Item 17 - Voting Client Securities Our clients may periodically receive proxies or other similar solicitations sent directly from the custodian of record or transfer agent. If we receive a duplicate copy, note that we do not forward these or any similar correspondence relating to the voting of the client securities, class action litigation, or other corporate actions. Our firm does not vote proxies on a client’s behalf, including those accounts that we have discretionary authority over; nor do we offer specific guidance on how to vote proxies. We will not offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. However, we will answer limited questions via a scheduled meeting with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer or its legal representative. If an account is supervised by a third-party investment manager, the client should review the third-party investment manager’s Form ADV Part 2 to determine their proxy voting policies. Otherwise, each account holder will maintain responsibility for directing the manner in which proxies solicited by issuers of securities that are beneficially owned shall be voted, as well as making all other elections relative to mergers, acquisitions, tender offers or other legal matters or events pertaining to holdings. Clients should consider contacting the issuer or their legal counsel involving specific questions they may have with respect to a particular proxy solicitation or corporate action. Item 18 - Financial Information Fee withdrawals must be made through a qualified intermediary (e.g., your custodian of record) following your written agreement. Engagements with our firm do not require the collection of fees from you of $1,200 or more for our advisory services that have been agreed to be performed six months or more into the future. Neither our firm nor its management serve as general partner for a partnership or trustee for a trust in which the firm’s advisory clients are either partners of the partnership or beneficiaries of the trust. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 25 of 26  The firm and its management do not have a financial condition likely to impair its ability to meet commitments to clients, nor has the firm and its management been the subject of a bankruptcy petition. Due to the nature of our firm’s advisory services and operational practices, an audited balance sheet is not required nor included in this brochure. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 SEC Page 26 of 26 

Item 1 - Cover Page Glass Lakes Capital Management LLC Registered Investment Adviser CRD # 290064 6580 W. 95th Street/Suite 100 Overland Park, KS 66212 913-647-9555 www.glasslakes.com Form ADV Part 2A-Appendix 1 Wrap Fee Investment Program Brochure May 15, 2026 This wrap fee investment program brochure provides information about the qualifications and business practices of Glass Lakes Capital Management LLC. Please contact Joel Hamilton at 913-647-9555 if you have any questions about the content of this wrap fee program brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities administrator. Additional information about Glass Lakes Capital Management LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD (“CRD”) number, which is 290064. Although the firm and its associates may be notice-filed (“registered”) and/or licensed within a particular jurisdiction it does not imply an endorsement by any regulatory authority nor infers a certain level of skill or training on the part of the firm or its associated personnel. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 1 of 25  Item 2 - Material Changes This Form ADV Part 2A-Appendix 1 wrap fee investment program brochure has been revised pursuant to Glass Lakes Capital Management LLC’s registration as an investment adviser with the SEC, superseding previous versions. This document has been modified to address disclosure requirements for an SEC-registered firm and therefore clients and prospective clients are encouraged to review the document in its entirety. Updates include our reportable assets under management, fee schedule, and custody matters (Item 4), amended risk statements (Item 6), and how we manage accounts (Item 7), among others. While this registration transition does not change the scope of services we provide or our fiduciary obligation to clients, certain regulatory oversight and disclosure requirements regarding activities involving investment advisers now fall under SEC rules rather than state-level jurisdictions where we have operated in the past. The firm may at any time update this document and either send a copy of its updated brochure or provide a summary of material changes to its brochure and an offer to send an electronic or hard copy form of the updated brochure. Clients are also able to download this brochure from the SEC’s website at www.adviserinfo.sec.gov or contact our firm at 913-647-9555 to request a copy at any time. As with all firm documents, clients and prospective clients are encouraged to review this brochure in its entirety and are encouraged to ask questions at any time prior to or throughout the engagement. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 2 of 25  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 and Compensation .......................................................................................................... 4 Item 5 - Account Requirements and Types of Clients ......................................................................................... 9 Item 6 - Portfolio Manager Selection and Evaluation ......................................................................................... 9 Item 7 - Client Information Provided to Portfolio Managers ............................................................................ 17 Item 8 - Client Contact with Portfolio Managers .............................................................................................. 19 Item 9 - Additional Information ......................................................................................................................... 19 Important Information Throughout this document Glass Lakes Capital Management LLC shall also be referred to as “the firm,” “firm,” “our,” “we” or “us.” The client or prospective client may be also referred to as “you,” “your,” etc., and refers to a client engagement involving a single person as well as two or more persons, and may refer to natural persons and legal entities. The term “advisor” and “adviser” are used interchangeably where accuracy in identification is necessary (i.e., internet address, etc.). Our firm maintains a business continuity and succession plan that is integrated within the organization to ensure it appropriately responds to events that pose a significant disruption to its operations. A statement concerning the current plan is available under separate cover. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 3 of 25  Item 4 - Services, Fees and Compensation Description of Firm Glass Lakes Capital Management LLC is a Kansas limited liability company formed in August of 2017. The firm’s original registration as a Kansas investment adviser occurred in 2017, followed by the firm’s registration with the SEC in 2026. Our firm and its associates are notice-filed or exempt from notice filing or registration in state jurisdictions where our investment advisory business activities are conducted.1 Our firm is not a subsidiary of, nor does it control, another financial services industry entity. Joel T. Hamilton, CFA, CFP® is the firm’s Principal and Chief Compliance Officer (supervisor). He is also Managing Member and maintains majority interest in the firm. Additional information about Mr. Hamilton and his professional experience may be found in his accompanying Form ADV Part 2B brochure supplement. As of April 8, 2026, our firm had over $178.3 million of reportable client assets under our management2 on a discretionary basis. Our wrap fee investment program is designed for investors that intend to maintain at least $50,000 of investible assets with our firm and whose investment profile necessitates active portfolio management. The program incorporates financial planning, portfolio management and brokerage transactional services for a single asset-based fee. Our firm serves as program sponsor and provides its expertise involving financial planning and portfolio management. Brokerage and custody services are provided through the Charles Schwab & Co., Inc. (“Schwab”), member FINRA/SIPC.3 Schwab offers independent investment advisers various services which may include custody of securities, trade execution, clearance and settlement of transactions, and in which our firm receives benefits from Schwab through our participation in their services offerings which will be described in further detail in later sections of this brochure. We also provide financial planning and portfolio management services which do not involve wrapped (unbundled) fees. Additional information about these other services is described in greater detail within our separate Form ADV Part 2A firm brochure, and interested parties should contact our firm for further information. An initial interview is conducted by a representative of the firm to determine the scope of services to be provided. During or prior to this meeting the prospective client will be provided with our Form ADV Part 3 (Form CRS), Form ADV Part 2A-Appendix 1 wrap fee investment program brochure, privacy policy statement, as well as the Form ADV Part 2B brochure supplement about their investment adviser representative. In addition, the firm will ensure it has disclosed any material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and objective advice, such as information found in Item 9 of this wrap fee brochure. If the client wishes to engage our firm for its services, they must first execute our engagement agreement. Thereafter further discussion and analysis will be conducted to determine financial need, goals, holdings, etc. Depending on the scope of the engagement, the client may be asked to provide copies of the following documents early in the process: 1 State jurisdictions where a firm is currently notice filed can be determined via the SEC’s website at www.adviserinfo.sec.gov. 2 The term “assets under management” and rounding per the SEC’s General Instructions for Part 2 of Form ADV. 3 Our firm is not, nor required to be, a FINRA or SIPC member. Information about the Financial Industry Regulatory Authority (FINRA) may be found at www.finra.org. You may learn more about the Securities Investor Protection Corporation (SIPC) and how it serves member firms and the investing public by going to their website at http://www.sipc.org. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 4 of 25  • wills, codicils, and trusts • insurance policies, including information about riders, loans and amendments • mortgage information • tax returns • student loans • divorce decree or separation agreement • current financial specifics including W-2s, 1099s, K-1 statements, etc. • information on current retirement plans and other benefits provided by an employer • statements reflecting current investments in retirement and non-retirement accounts • employment or other business agreements, and • completed risk profile questionnaires or other forms provided by our firm. It is important that we are provided with an adequate level of information and supporting documentation throughout the term of the engagement including but not limited to source of funds, income levels, and an account holder or an attorney-in-fact authority to act on behalf of the account, among other information that may be necessary for our services. The information and/or financial statements provided to us need to be accurate. Our firm may, but is not obligated to, verify the information that has been provided to us which will then be used in the advisory process. It is essential that the client inform our firm of significant issues that may call for an update to their financial plan or investment portfolio. Events such as changes in employment or marital status, an unplanned windfall, etc., can have an impact on a client’s circumstances and goals. Our firm needs to be aware of such events so that adjustments may be made as necessary. Financial Planning Component We can provide wrap fee clients advice on various planning topics such as cash flow and budgeting, education funding, retirement planning, risk management, estate planning, among others. The financial planning component may be as broad-based or narrowly focused as desired by the client. Portfolio Management Component The investment strategies and types of investments that may be recommended for your wrap fee investment program account are found in Item 6 of this brochure. Our wrap fee program services are typically provided on a discretionary basis (defined in Item 7), and the process normally includes: • determination of risk tolerance • investment strategy • investment guideline development • asset allocation • asset selection • regular monitoring, and • periodic rebalancing. We will prepare written guidelines that reflect your investment objectives, time horizon, tolerance for risk, as well as any reasonable constraints you may have for your account (e.g., restricting certain types of stocks, no options, etc.). Please note that any restriction you may place on the management of your account may Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 5 of 25  influence the strategy, investment vehicle selection and, potentially, investment results within your portfolio. These guidelines will be designed to be specific enough to provide future guidance while concurrently allowing flexibility to respond to changing market conditions. You will be asked to review the final investment plan, and we ask that you promptly notify us if there are changes in your financial situation or investment objectives so that we may review and/or revise previous recommendations. Wrap Fees Assessed We require a minimum account size of $50,000 to open and maintain a wrap fee investment program account. We do not assess account opening and/or administration fees to initiate the wrap fee program. For the benefit of discounting our asset-based fee, we will aggregate accounts within the same household unless instructed by the client not to do so. Our wrap fee accounts are assessed an annualized asset-based fee up to 1.75% (175 basis points) depending on account size, advisory services required, and as agreed with you in advance. One basis point equals 1/100 of one percent. The wrap fee is paid to our firm quarterly, in advance or in arrears per the engagement agreement, and will be based on the account’s value each billing period as calculated using the following formula: (quarterly account market value) x (applicable number of basis points) ÷ 4 (quarters). Example: A wrap fee account maintaining $1,000,000 of investible assets being assessed a one percent asset-based fee will pay a quarterly fee of $2,500. Formula: ($1,000,000 x 100 bps) = $10,000 (annualized fee) ÷ 4 (quarters) = $2,500 (quarterly fee). In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such an opinion at their own expense as to the valuation of “hard-to-price” securities if they believe it to be necessary. The firm does not bill accounts off-cycle; we only bill on a quarterly basis. Therefore, on any deposits or withdrawals exceeding $50,000 per day we will credit or debit the account for partial periods on a prorated based during the following quarter billing cycle. Fee payments will generally be assessed within the first 15 calendar days of each billing cycle. Your written authorization is required in order for the custodian of record to deduct our advisory fee from your account. By signing our firm’s engagement agreement, as well as the custodian account opening documents, you will be authorizing the custodian to withdraw advisory fees from your account. The custodian will remit our fees directly to our firm. Fees deducted from your account will be noted on statements that you will receive directly from our custodian of record. We encourage you to verify the accuracy of fee calculations; the custodian may not verify the accuracy of advisory fee assessments for each account or on a consistent basis. Alternatively, you may request to directly pay our advisory firm its portfolio management fee in lieu of having the advisory fee withdrawn from your investment account. A client’s direct payment must be received by our firm within 15 days of our invoice.4 Our firm does not accept cash, money orders or similar forms of payment for its engagements. Please refer to Items 5, 6 and 9 of this brochure for additional information about our fees in relationship to our brokerage and operational practices, and their inherent conflicts of interest. 4 Our invoice will include the total fee assessed, covered time period, calculation formula utilized, and reference to the assets under management in which the fee had been based. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 6 of 25  Either party may terminate the agreement at any time by communicating their intent to terminate in writing. A new client may terminate an agreement with our firm within five business days after the signing of our engagement agreement without penalty or charge. Our firm will not be responsible for investment allocation, advice or transactional services (except for limited closing transactions) upon receipt of a termination notice. It will also be necessary that we inform the custodian of record that the relationship between parties has been terminated. When a wrap fee program client terminates their agreement after the five business-day rescission period, that client will be assessed fees on a prorated basis for services incurred from either (i) as a new client, the date of the engagement to the date of the firm’s receipt of the written notice of termination, or (ii) all other accounts, the last billing period to the date of the firm’s physical or constructive receipt of written termination notice. Our firm will return any prepaid, unearned fees within 30 days of termination notice. We will coordinate remuneration of prepaid asset-based fees to a client’s investment account. Return of prepaid fees will never involve a personal check, cash or money order from our firm or from an associate of our firm. If we are unable to deduct our fees from the client’s account at the custodian of record, then our earned fees will be due upon the client’s receipt of our invoice. Services Purchased Separately The total costs associated with the wrap fee investment program account may be more or less than purchasing brokerage and advisory services separately. The factors that bear upon the relative costs include the number of and timing of transactions, portfolio management, custody fees, regulatory compliance and administrative charges, research costs, and promotional materials. These and other factors may affect the cost of obtaining these services separately. Comparable services may be provided by other advisers, potentially for a lower fee. Additional Client Fees The fees not included in the advisory fee for our wrap fee program services are charges imposed directly by a mutual fund, index fund, or exchange traded fund which is found in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. If a sub-adviser is used within a wrap fee program account, their fee (in addition to our advisory fee) will range from 0.01% to 0.75% (1 to 75 bps). 5 Per annum interest at the current statutory rate based on the state in which the client resides may be assessed on fee balances due more than 30 days, and we may refer past due accounts to collections or legal counsel for processing. We reserve the right to suspend some or all services once an account is deemed past due. Compensation Matters Appropriately registered associates of our firm will receive a portion of the fee for recommending and servicing the wrap fee program account, in addition to firm personnel serving as portfolio manager. Therefore, the person recommending the wrap fee program to you may receive a portion of the compensation because of your participation, both as a firm representative as well as portfolio manager. 5 Combined asset-based fees will not exceed three percent (3.00% of assets under management) which is considered an excessive fee. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 7 of 25  The amount of this compensation may potentially be more than what would be received if you participated in other advisory programs or paid separately for investment advice, brokerage, and/or other advisory or brokerage services. You should compare costs between this program and others offered through our firm and other firms to make a final determination. Since the firm absorbs certain transaction costs in wrap fee accounts, the firm has a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee program arrangement which is contrary to the type of active trading inherent to a wrap fee account. Our firm policy prohibits associates from accepting or receiving additional economic benefit, such as sales awards or other prizes, for providing advisory services to our clients. We do not receive SEC Rule 12b-1 fees (“trails”) from a mutual fund company that may be recommended to a client. Account Custody Wrap fee investment program accounts will be maintained by Schwab; an unaffiliated, qualified custodian. Assets are not maintained by our firm or any associate of our firm. In keeping with this policy involving our clients’ accounts, our firm:  restricts the firm or an associate from having general power of attorney over a client account  restricts the firm or an associate from serving as trustee over a client account (unless it is an immediate family member)  does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm  prohibits the firm or an associate from having the client’s bank or investment account access information (i.e., passwords and user identification)  will not collect advance fees of $1,200 or more for services that are to be performed six months or more into the future, and  prohibits associates from having authority to directly withdraw securities or cash assets from a client account. Although we may be deemed to have limited (aka. constructive or indirect) custody of an account since we may request the withdrawal of advisory fees from an investment account, we will do so only on the following terms: o our firm will possess written authorization from the client to deduct advisory fees from an account held by their custodian of record o we will send the client’s qualified, unaffiliated custodian a notice of the amount of the fee to be deducted from the client’s account, and o the client must be able to receive an account statement directly from the account custodian.  does not allow standing letters of authority (SLOAs) unless the: o client provides written instruction to their qualified custodian that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed o client authorizes the firm in writing on their qualified custodian’s form any power to direct transfers to the third party either on a specified schedule or from time to time o client’s qualified custodian performs appropriate verification of the client’s instructions, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer o client can terminate or change the instruction to the client’s qualified custodian Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 8 of 25  o firm has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction o third party is not a related party to our firm and is located at a different address than the firm o client’s qualified custodian sends the client a written initial notice confirming the instruction, and o client is annually provided notice reconfirming their instructions. The custodian of record will provide account transaction confirmations and account statements, which include debits and credits, as well as our firm’s advisory fee for that period. Statements are provided on at least a quarterly basis or as transactions occur within an account. We urge all our clients to inform us if they are not receiving their trade confirmations or account statements from their custodian. Our firm will not create a separate account statement for a client nor serve as the sole recipient of a client account statement. Item 5 - Account Requirements and Types of Clients Glass Lakes Capital Management LLC provides its services to individuals, high net worth individuals, and charitable organizations. Our firm does not require minimum income, asset levels or other similar preconditions for our portfolio management services described in our separate Form ADV Part 2A firm brochure. We typically serve individual and high net worth individuals via our wrap fee investment program; however, we will include other entities should their investment guidelines permit us to do so. We have established a minimum account size of $50,000 for our wrap fee program for those whose investment profile necessitates active portfolio management. Participation in the program is initiated by submitting our client engagement agreement and wrap fee investment program addendum, in addition to the custodian’s account application and any other supplemental documents they may require. Glass Lakes Capital Management LLC will make the final determination as to the client’s suitability for the wrap fee investment program which will be based on our review account documentation, risk tolerance and asset allocation. Schwab will execute and clear all purchase and sale orders directed, maintain wrap fee investment program account assets, and provide other functions such as crediting of interest and dividends on accounts, crediting of principal on called or matured securities, as well as other customary custodial functions. Schwab serves as general administrator of accounts, which includes charging and collecting advisory fees and processing, deposits to and withdrawals from program accounts, etc. Schwab will forward confirmation of each purchase and sale directly to the client as well as providing a copy to our firm. Additionally, they will forward account statement to clients for each period in which account activity occurs, and at least quarterly regardless of account activity. Item 6 - Portfolio Manager Selection and Evaluation Selection and Review of Portfolio Manager We will ensure due diligence is completed on any portfolio manager to include determining whether that manager is registered/notice-filed (or required to be) within the jurisdiction the client resides. At least annually thereafter our review will be performed from both a compliance and performance perspective to determine that the selected portfolio manager remains an appropriate fit. We also review each portfolio manager’s performance over an extended period, as well as at least quarterly to discuss any potential concerns or recommended changes to the program’s managers. The firm will also be responsible for determining if a portfolio investment manager should be replaced due to poor performance, regulatory or compliance matters, etc. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 9 of 25  The benchmarks for account performance are based on each client’s responses to firm suitability information and their stated investment guidelines. Using these responses, we are able to deploy the appropriate investment strategy, as well as develop a diversified portfolio using this strategy. Our firm maintains current client profiles and will recommend adjustments to portfolios when the firm believes it to be necessary. Our firm produces its own quarterly performance reports which are calculated using time-weighted and internal rate of return methodologies. These reports are provided in printed and digital format and are reviewed for accuracy by the assigned investment adviser representative prior to their delivery. Our reports are intended to inform clients about investment performance over the current period, as well as over the longer term since the account’s inception; both on an absolute basis and as compared to a known benchmark. We do not back-test or certify reports from an external party. Clients are urged to carefully review and compare account statements that they have received directly from their custodian of record with any report they may receive from our firm or any other source that contains investment performance information. The wrap fee program portfolio manager is an associate of Glass Lakes Capital Management, LLC. An inherent conflict of interest exists since the associate, and the firm, may both benefit from a greater percentage of the advisory fee when the investment management of the account is not outsourced to another (external) portfolio manager. Considering this conflict, our firm will ensure it utilizes the same due diligence and selection and/or termination criteria for its own portfolio manager that it would had an external source been engaged, in addition to further scrutiny to ensure appropriate portfolio selection, fees and other compensation are within the account investment policy statement, firm procedures and regulatory guidelines. Performance-Based Fees and Side-By-Side Management Our advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any portion of managed funds, also known as performance-based fees. Our fees will also not be based on side-by-side management, which refers to a firm simultaneously managing accounts that do pay performance-based fees (such as a hedge fund) and those that do not. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We utilize what we believe to be an appropriate blend of fundamental and technical analyses. We evaluate various economic factors including interest rates, the current state of the economy, or the future growth of an industry sector. We then study historical market patterns and trends to assist us in determining the direction of market as well as specific securities. Our research is often drawn from sources such as:  financial periodicals  reports from economists and other industry professionals  company press releases  corporate rating services  inspection of corporate activities, and  regulatory filings, such as annual reports, prospectuses, etc. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 10 of 25  Investment Strategies We recognize that each client's needs and goals are different; subsequently, portfolio strategies and underlying investment vehicles may vary. Our portfolios contain investment vehicles that are globally diversified, tax-efficient and low-cost whenever practical. It is common to find a broad range of ETFs within a portfolio, as well as incorporating individual stocks and bond positions when appropriate. We frequently utilize a Core + Satellite investment strategy; blending passive and active investing, where passive investments are used as the basis or “core” of a portfolio and actively managed investments are added as “satellite” positions. The portfolio core holdings are indexed to potentially more efficient asset classes, while outlying selections are generally limited to active holdings in an attempt to outperform a particular category (sector), or a selection of particular positions to increase core diversification, or to improve portfolio performance. For example, the core of a portfolio may be built with indexed mutual funds or ETFs; satellite holdings would include active investments (e.g., equities) with unique strategies that are believed capable of adding value beyond a stated benchmark over a full market cycle. Risk of Loss Our firm believes its strategies and investment recommendations are designed to produce the appropriate potential return for the given level of risk; however, there is no guarantee that a planning goal or investment objective will be achieved. Past performance is not necessarily indicative of future results. Investing in securities involves risk of loss that clients should be prepared to bear. While the following list is not exhaustive, we provide some examples of such risk in the following paragraphs, and we believe it is important that our clients review and consider each prior to investing. Active Management A portfolio that employs active management strategies may, at times, outperform or underperform various benchmarks or other strategies. To meet or surpass these benchmarks, active portfolio management may require more frequent trading or “turnover.” This may result in shorter holding periods, higher transactional costs and/or taxable events generally borne by the client, thereby potentially reducing or negating certain benefits of active asset management. Catastrophic Risk Natural or man-made catastrophes can disrupt financial markets and impact securities prices. Examples include terrorist attacks, natural disasters, war, etc. Investment companies can use "exigent circumstances" or "force majeure" as a defense against claims of loss by investors. Company Risk When investing in securities, such as stocks, there is always a certain level of company or industry-specific risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification. Core + Satellite Strategies Strategies involving Core + Satellite investing may have the potential to be affected by “active risk” (or “tracking error risk”), which might be defined as a deviation from a stated benchmark. Since the core portfolio attempts to closely replicate a stated benchmark, the source of the tracking error or deviation may Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 11 of 25  come from a satellite portfolio or position, or from a “sample” or “optimized” index fund or ETF that may not as closely align the stated benchmark. Country/Regional Risk World events such as political upheaval, financial troubles, or natural disasters will adversely affect the value of securities issued in foreign countries or regions. This risk is especially high in emerging markets where securities may be substantially more volatile and less liquid than securities in more developed countries. Because an ETF may invest a large portion of its assets in securities located in any one country or region, including emerging markets, its performance may be hurt disproportionately by the poor performance of its investments in that area. Currency Risk The risk of loss from fluctuating foreign exchange rates when a portfolio has exposure to foreign currency or in foreign currency traded investments is known as currency risk. Emerging Markets Securities Some of the underlying assets in an ETF or mutual fund may involve emerging market securities which can be considered speculative and subject to heightened risks, in addition to the general risks of investing in foreign securities. Unlike more established markets, emerging markets may have governments that are less stable, markets that are less liquid, and economies that are less developed. In addition, the securities markets of emerging market countries may consist of companies with smaller market capitalizations and may suffer periods of relative illiquidity; significant price volatility; restrictions on foreign investment; and possible restrictions on repatriation of investment income and capital. Foreign investors may be required to register the proceeds of sales, and future economic or political crises could lead to price controls, forced mergers, expropriation or confiscatory taxation, seizure, nationalization, or creation of government monopolies. Equity (Stock) Risk Common stocks are susceptible to general stock market fluctuations and to volatile increases or decreases in value as market confidence in and perceptions of their issuers change. If an investor held common stock or common stock equivalents of any given issuer, they may be exposed to greater risk than if they held preferred stocks and debt obligations of the issuer. Preferred stocks can be affected by interest rate and liquidity risks (described in adjacent paragraphs). Also note that their dividend payment is not guaranteed; some are subject to a call provision, meaning the issuer can redeem its preferred shares on demand, and usually when interest rates have fallen. ETF Risks ETF risks include risks due to their underlying securities (e.g., stocks, bonds, etc.), and can be affected by risks such as market, currency, interest rate, etc., that are described in adjacent paragraphs. The liquidity of the underlying stocks in the index can affect “ETF liquidity.” Liquidity risk can result from an insufficient number of “active participants” performing their duties as intermediaries and liquidity providers in the ETF market. “Spread risk” may also occur, which is the difference between the bid and the ask price of a security. Since ETF transactions are priced throughout the day and are traded on exchanges like stocks, widening spreads may occur and have an impact on certain portfolios or transactions. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 12 of 25  As with any security, if the ETF “fails,” the investor may lose their gains and invested principal. ETFs can carry additional expenses based on their share of operating expenses and certain brokerage fees. Indexed ETFs have the potential to be affected by “active risk;” a deviation from its stated index. While many ETFs are known for their potential tax-efficiency and higher “qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be a holding within an ETF), may be considered “non-qualified” under certain tax code provisions. A holding’s QDI will be considered when tax-efficiency is an important aspect of the client’s portfolio. Leveraged and/or inverse ETFs attempt to achieve multiples of the performance of an index or benchmark through the opposite (inverse) of the performance of the tracked index or benchmark. This strategy attempts to profit from, or hedge exposures to, downward drifting markets. There is risk involving this strategy and part of the concern is because leveraged and inverse exchange-traded funds "reset" daily, which means they are designed to achieve their stated objectives on a daily basis. It is due to the compounding effect of daily adjustments that ETF performance over longer periods of time can differ significantly from the performance (or inverse of the performance) of an underlying index or benchmark during the same period. This effect is potentially magnified during volatile markets. If effects contrary to the ETF strategy occur, losses may be significant; therefore, leveraged and/or inverse ETFs will be considered for portfolios either properly hedged or for clients able to sustain potentially higher risks. Failure to Implement Each financial planning client is free to accept or reject any or all the recommendations made by our firm. While no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients who choose not to take the steps recommended in their financial plan may face an increased risk that their stated goals and objectives will not be achieved. Fixed Income Risks Various forms of fixed income instruments, such as bonds, money market or bond funds/ETFs may be affected by various forms of risk, including:  Call Risk - During periods of falling interest rates, issuers of callable bonds may call (redeem) securities with higher coupons or interest rates before their maturity dates. The owner of the bond would then lose any potential price appreciation above the bond’s call price and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the owner’s income. Call risk is generally low for short-term bonds, moderate for intermediate-term bonds, high for long-term bonds, and high for high-yield bonds.  Credit Risk - The potential risk that an issuer would be unable to pay scheduled interest or repay principal at maturity, sometimes referred to as “default risk.” Credit risk may also occur when an issuer’s ability to make payments of principal and interest when due is interrupted. Bondholders are creditors of an issuer and have priority over assets before equity holders (e.g., stockholders) when receiving a payout from liquidation or restructuring. When defaults occur due to bankruptcy, the type of bond held will determine seniority of payment.  Interest Rate Risk - The risk that the value of the fixed income holding will decrease because of an increase in interest rates. The longer the maturity of the bond, the more sensitive its value is to changes in interest rates. Bond prices and interest rate changes are inversely correlated. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 13 of 25   Prepayment Risk - The prepayment risk is the premature return of principal on a fixed-income security. When principal is returned early on a security, future interest payments will not be paid on that part of the principal. The owner of the security would lose any price appreciation above the principal and be forced to reinvest the unanticipated proceeds possibly at lower interest rates, resulting in a decline of dividends, income, and returns. The risk of prepayment is most prevalent in fixed-income securities such as callable bonds and mortgage-backed securities.  Reinvestment Risk - With declining interest rates, investors may have to reinvest interest income or principal at a lower rate.  State Government and Municipal Securities Risk - State government and municipal securities are subject to various risks based on factors such as economic and regulatory developments, changes or proposed changes in the federal and state tax structure, deregulation, court rulings and other factors. Repayment of state and municipal securities depends on the ability of the issuer or project backing such securities to generate taxes or revenues. There is also a risk that the interest on an otherwise tax- exempt municipal security may be subject to federal income tax. Unfavorable developments in any economic sector may have far-reaching ramifications on the overall state and municipal market.  US Government Securities Risk - US government securities are subject to varying interest rates and inflation risks. Not all US government securities are backed by the full faith and credit of the US government. Certain securities issued by agencies and instrumentalities of the US government are only insured or guaranteed by the issuing agency or instrumentality, which must rely on its own resources to repay the debt. As a result, there is a risk these entities will default on a financial obligation. Foreign Securities Risk Investments in securities of foreign companies (including direct investments as well as investments through American Depository Receipts – aka. ADRs) can be more volatile than investments in US-based companies. Diplomatic, political, or economic developments, including nationalization or appropriation, could affect investments in foreign companies. Foreign securities markets generally have less trading volume and less liquidity than US markets. In addition, the value of securities denominated in foreign currencies, and of dividends from these securities, can change significantly when foreign currencies strengthen or weaken relative to the US dollar. Financial statements of foreign issuers are governed by different accounting, auditing, and financial reporting standards than the financial statements of US issuers and may be less transparent and uniform than in the United States. Thus, there may be less information publicly available about foreign issuers than about most US issuers. Transaction costs generally are higher than those in the US and expenses for custodial arrangements of foreign securities may be somewhat greater than typical expenses for custodial arrangements of similar US securities. Some foreign governments levy withholding taxes against dividend and interest income. Although in some countries a portion of these taxes are recoverable, the non-recovered portion will reduce the income received from the securities comprising an account’s portfolio. These risks may be heightened with respect to emerging market countries since political turmoil and rapid changes in economic conditions are more likely to occur in these countries. Fundamental Analysis The challenge involving fundamental analyses is that information obtained may be incorrect; the analysis may not provide an accurate estimate of earnings, which may be the basis for a security’s value. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 14 of 25  If a security’s price adjusts rapidly to new information, a fundamental analysis may result in unfavorable performance. Inflation Risk Also called purchasing power risk, is the chance that the cash flows from an investment won’t be worth as much in the future because of changes in purchasing power due to inflation. Legal or Legislative Risk Legislative changes or court rulings may adversely impact the value of individual investments, market sectors, or the overall market. Liquidity Risk Liquidity risk is the inability to readily buy or sell an investment for a price close to the true underlying value of the asset due to a lack of buyers or sellers. While certain types of fixed income are generally liquid (e.g., bonds), there are risks which may occur such as when an issue trading in any given period does not readily support buys and sells at an efficient price. Conversely, when trading volume is high, there is also a risk of not being able to purchase a particular issue at the desired price. Market Risk This is also called systematic risk. In cases where markets are under extreme duress, many securities lose their ability to provide diversification benefits. Money Market Funds A money market fund is managed to maintain a stable net asset value (NAV) of $1 per share, the value of the fund may fluctuate, and you could lose money (termed “breaking the buck”). Money market funds are a type of mutual fund investing in high-quality, short-term debt securities, pay dividends that generally reflect short-term interest rates and seek to maintain a stable NAV per share (typically $1). An investment in a money market mutual fund is typically not insured or guaranteed by the Federal Deposit Insurance Corporation, National Credit Union Association, or any governmental agency. Mutual Funds As with ETFs, the risk of owning an open-ended, closed-ended, and fund-of-fund mutual funds is reflected in the underlying security(ies). Mutual funds are affected by risks such as market, interest rate, currency, credit, political, active risk, etc., as described in adjacent paragraphs. It is important to note that even “conservative” funds, such as a money market fund or fixed income fund, can and have lost their value below the principal amount invested. Mutual funds typically carry additional expenses based on their share of operating expenses and trading (brokerage) fees, which may result in the potential duplication of certain fees paid by the investor. Indexed mutual funds can also be adversely affected by “QDI ratios” that are described above. There are essentially nine main types of mutual fund shares classes, as well as sub-classes for some of these. Some mutual funds are sold through brokerage firms and assess a commission (“load) in addition to their underlying fees earlier noted, while others are offered through investment advisers, retirement plans and other institutions. “No load” funds are also available to the public through brokerage firms, and they usually incur trading (brokerage) fees. Our investment advisory firm and its personnel are not associated with a broker/dealer and are not compensated by a “loaded” fund. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 15 of 25  Operational Risk The potential for loss from inadequate or failed internal processes, systems, actions of people, or external events. Many industries institute policies and procedures to respond and initiate alternative or supporting operations following significant business disruption, while others do not. The level of operational risk and appropriate response are not uniform in definition, requirement, or measurement, including within the financial services sector. Political Risk The risk of financial and market loss because of political decisions or disruptions in a particular country or region and may also be known as "geopolitical risk." Research Data When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice on or investment management of an account. Sequence of Return Risk The risk of receiving lower or negative returns due to early withdrawals from an investment account. Settlement Risk Also called delivery risk. The risk that one party will fail to deliver the terms of an investment contract with another party (contra-party) at the time of settlement. Settlement risk can be a risk associated with default, along with any timing differences in a settlement between the two parties. Small- and Mid-Capitalization Company Risk The small- and mid-capitalization companies in which an account may invest may be more vulnerable to adverse business or economic events than larger, more established companies. Investments in these small- and mid-sized companies may pose additional risks, including liquidity risk, because these companies tend to have limited product lines, markets, and financial resources, and may depend upon a relatively small management group. Small- and mid-cap stocks, therefore, may be more volatile than those of larger companies. These securities may be traded over the counter or listed “off-exchange.” Sub-Advisers We will review with the client the Form ADV Part 2A of any recommended external investment adviser to ensure the client is familiar with the investment strategy and types of investment vehicles they employ so that they align with the client’s investment objectives, as well as discuss the risks these may impose on the account. Our firm does not control the daily business and compliance operations of the external advisers that the firm may recommend or utilize to manage a client portfolio, and the firm may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputation deficiencies. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 16 of 25  Technical Analysis The risk of investing based on technical analyses is that it may not consistently predict a future price movement; the current price of a security may reflect all known information. This may occur due to analyst bias or misinterpretation, a sector analysis error, late recognition of a trend, etc. Voting Client Securities Account holders may periodically receive proxies or other similar solicitations sent directly from their custodian or transfer agent. If we receive a duplicate copy, note that we do not typically forward these or any correspondence relating to the voting of your securities, class action litigation, or other corporate actions. Our firm does not vote proxies on behalf of an account holder, including accounts that we have discretionary authority. We do not offer guidance on how to vote proxies, nor will we offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. We will answer limited questions with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer or their legal representative. Each account holder will maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities that are beneficially owned by you shall be voted, as well as making all other elections relative to mergers, acquisitions, tender offers or other legal matters or events pertaining to your holdings. Clients should consider contacting the issuer or their legal counsel involving specific questions they may have with respect to a particular proxy solicitation or corporate action. Item 7 - Client Information Provided to Portfolio Managers Information Provided to Portfolio Managers Under our wrap fee program engagement, we will gather information about your financial situation, investment objectives, and any reasonable restrictions you may want to impose on the management of the account. We will then provide this data to your portfolio manager who will invest on behalf of the account in accordance with the strategies set forth within stated investment guidelines. Account Investment Authority We will account for any reasonable restrictions involving the management of the client’s account (i.e., no sin stocks, avoiding international holdings, etc.). It remains the client’s responsibility to notify us if there is any change in their situation and/or investment objective so that we may reevaluate previous investment recommendations or portfolio holdings. Our clients retain the right to amend our account authority, in writing. We typically serve wrap fee accounts on a discretionary basis. Via limited power of attorney, clients grant our firm the authority to implement investment decisions, such as the purchase or sale of a security on behalf of an account, without requiring the client’s prior authorization for each transaction to meet stated investment objectives. This authority will be provided by the client through the execution of both our engagement agreement and the custodian’s account opening documents. Note that the custodian will specifically limit our firm’s authority within an account for the placement of trade orders and our request for the deduction of our advisory fees. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 17 of 25  On a case-by-case basis, our firm may manage a client portfolio on a nondiscretionary basis. This type of account authority requires the client’s ongoing prior approval involving the investment and reinvestment of account assets, and portfolio rebalancing. The client will be required to execute our firm’s client services agreement that describes our limited account authority, as well as the custodian of record’s account opening document that includes their limited power of attorney form or clause. Considering trading pre- approval requirements, the client must make themselves available and keep our firm updated on their contact information so that instructions can be efficiently effected on their behalf. Nondiscretionary accounts are generally unable to be aggregated (see Item 12) and may therefore be assessed higher trading fees or receive less favorable prices than those accounts where trade aggregation has occurred. Sub-advisers generally provide their services on a discretionary basis. If a client requires their account to be managed on a nondiscretionary basis, it is important to note that most sub-advisers retain the right to refuse to manage the account. We will inform clients in advance of the recommended sub-adviser’s requirements involving account trading authority. Note that our firm also typically has discretionary authority over a client account under this type of engagement. Privacy Policy Statement We respect the privacy of all clients and prospective clients (collectively termed “customers” per federal guidelines), both past and present. It is recognized that clients have entrusted our firm with non-public personal information, and it is important that both access persons and customers are aware of firm policy concerning what may be done with that information. The firm collects personal information about customers from the following sources: • information provided to us complete their plan or investment recommendation • information provided via engagement agreements and other documents completed in connection with the opening and maintenance of an account • information customers provide verbally, and • information received from service providers, such as custodians, about client transactions. The firm does not disclose non-public personal information about our customers to anyone, except in the following circumstances when: • required to provide services our customers have requested, • our customers have specifically authorized us to do so, • required during a firm assessment (i.e., independent audit), or • permitted or required by law (i.e., periodic regulatory examination). To ensure security and confidentiality, our firm maintains physical, electronic, and procedural safeguards to protect the privacy of customer information. Within the firm, access to customer information is restricted to personnel that need to know that information. All access persons and service providers understand that everything handled in firm offices is confidential and they are instructed not to discuss customer information with someone else that may request information about an account unless they are specifically authorized in writing by the customer to do so. This includes providing information about a family member’s account. The firm will provide customers with its privacy policy at any time, in advance, if firm privacy policies are expected to change. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 18 of 25  Item 8 - Client Contact with Portfolio Managers Clients are invited to attend general communications sessions offered by our portfolio manager. When desiring personal communication with a portfolio manager, we ask that clients schedule these sessions in advance so that we may effectively assist all parties and follow up as necessary. Item 9 - Additional Information Disciplinary Information Neither the firm nor its management has been involved in any material criminal or civil action in domestic, foreign or military jurisdictions, administrative enforcement action, or self-regulatory organization proceeding that would reflect poorly upon our offering advisory business or its integrity. Other Financial Industry Activities and Affiliations Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of interest between the firm and its clients, or that may be contrary to law. Glass Lakes Capital Management LLC will provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of interest involving its business relationships that might reasonably compromise its impartiality or independence. Our firm and its management are not registered nor have an application pending to register as a Financial Industry Regulatory Authority (FINRA) or National Futures Association (NFA) member firm or associated person of such a firm. We are not required to be registered with such entities, nor do they supervise our firm, its activities or our associates. Neither the firm nor its management is or has a material relationship with any of the following types of entities:  accountant or accounting firm  another financial planning firm  bank, credit union or thrift institution, or their separately identifiable departments or divisions  insurance company or insurance agency  lawyer or law firm  pension consultant  real estate broker, dealer or adviser  sponsor or syndicator of limited partnerships  trust company  issuer of a security, to include investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) The sub-advisers that we recommend to a client are required to be registered with the SEC or a state securities commissioner as an investment adviser (most often they are SEC-registered investment advisers). Both our firm and the external investment manager are paid an advisory fee by the client, as noted in Item 4, for engaging in the selected investment strategy and will be memorialized in the client agreement. We believe we mitigate compensation conflicts of interest since the external investment manager’s fees are separate from our firm’s advisory fee, and our clients retain the right to reject using any external investment manager for their portfolio. Based on our fee structure, our firm does not earn higher or additional fees from a client if a particular investment manager is chosen over another. As a fiduciary, we will act in the best Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 19 of 25  interests of our clients when recommending an external investment manager. However, there is the potential for clients’ fees assessed via these engagements to be higher than had a client obtained them directly from the other investment manager or if the client purchases similar underlying investments on their own. It should be noted that certain investment managers and/or underlying investments may not be available to self-directed investors or at the same cost. Clients are encouraged to review all our service offerings, and their stated fees prior to the engagement, and each client has the right to purchase recommended or similar investments through their own provider. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Glass Lakes Capital Management LLC is a fiduciary; subsequently, our firm and its associates will act in the utmost good faith, performing in a manner believed to be in the best interest of our clients. We believe that our business methodologies, ethics rules, and adopted policies are designed to eliminate or at least minimize material conflicts of interest, and to appropriately manage any material conflicts of interest that may remain. It is important to point out that no set of rules can anticipate or relieve all material conflicts of interest. Our firm will disclose to its advisory clients any material conflict of interest relating to the firm, its representatives, or any of its employees which could reasonably be expected to impair the rendering of unbiased and objective advice. Code of Ethics We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and professionally responsible manner in all professional services and activities. Firm policies include prohibitions against insider trading, circulation of industry rumors, and certain political contributions, among others. We periodically review and amend our Code of Ethics to ensure that they remain current, and we require firm personnel to annually attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request. CFA Principles An associate that is a Chartered Financial Analyst (CFA) also adheres to the CFA Institute’s Code of Ethics and Standards of Professional which you may find at www.cfainstitute.org. CFP® Principles Firm associates that are CERTIFIED FINANCIAL PLANNER® Practitioners also adhere to the Certified Financial Planner Board of Standards, Inc.’s Code of Ethics & Professional Responsibility which you may find at www.cfp.net. Firm Recommendations and Conflicts of Interest Our associates are prohibited from borrowing from or lending to a client unless the client is an approved financial lending institution (e.g., bank, broker/dealer, etc.). Neither our firm nor its associates are authorized to recommend to a client, or effect a transaction for a client, involving any security in which our firm or a “related person” (associates, their immediate family members, etc.) has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 20 of 25  Our firm does not trade in its own account (proprietary trading). Our firm’s related persons may buy or sell securities that are the same as, similar to, or different from, those we recommend to clients for their accounts. A recommendation made to one client may be different in nature or in timing from a recommendation made to a different client. Clients often have different objectives and risk tolerances. At no time will our firm or any related party receive preferential treatment over our clients. We mitigate this conflict by ensuring that we have policies and procedures in place to ensure that the firm or a related person will not receive preferential treatment over a client. In order to reduce or eliminate certain conflicts of interest involving personal trading (e.g., trading ahead of client recommendations or trades, etc.), firm policy requires that we restrict or prohibit certain related parties’ transactions. Any exceptions must be approved in writing by our Chief Compliance Officer, and personal trading accounts are reviewed on a quarterly or more frequent basis. Please refer to Item 6 of the accompanying Form ADV Part 2B for further details. Review of Accounts Scheduled Reviews Portfolios are reviewed on a macro-level on a quarterly or more frequent basis by the client’s investment adviser representative. Client-level reviews are recommended on at least an annual basis. Reviews will be conducted by the client’s investment adviser representative and typically involve analysis and possible revision of your previous plan or investment allocation. A copy of revised plans or asset allocation reports will be provided to the client upon request. Unscheduled Reviews Clients should contact our firm for additional reviews when it is anticipated, or they have experienced changes in their financial situation (i.e., changes in employment, an inheritance, the birth of a new child, etc.), or if the client prefers to change requirements involving an investment account. Non-periodic reviews are conducted by the client’s investment adviser representative. A copy of revised plans or asset allocation reports will be provided to the client upon request. Additional portfolio reviews by the client’s investment adviser representative may be triggered by news or research related to a specific holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector. A portfolio may be reviewed for an additional holding or when an increase in a current position is under consideration. Account cash levels above or below what we deem appropriate for the investment environment, given the client's stated tolerance for risk and investment objectives, may also trigger a review. Client Referrals and Other Compensation Economic Benefit from Our Custodian We seek to use a custodian who will hold client assets and execute transactions on terms that are overall advantageous when compared to other available providers and their services. We do not receive referrals from our custodian, nor are client referrals a factor in our selection of our custodian. Our firm considers a wide range of factors, including, among others, these:  combination of transaction execution services along with asset custody services (generally without a separate fee for custody)  capability to execute, clear and settle trades (buy and sell securities for an account) Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 21 of 25   capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)  breadth of investment products made available (stocks, bonds, mutual funds, ETFs, etc.)  availability of investment research and tools that assist us in making investment decisions  quality of services  competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them  reputation, financial strength and stability of the provider  their prior service to us and our other clients, and  availability of other products and services that benefit us, as discussed below. Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory firms similar to ours. They provide our firm and its clients with access to its institutional brokerage - trading, custody, reporting and related services - many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available to us on an unsolicited basis (we don’t have to request them) and at no charge to us as long as we keep a certain level of our clients’ assets in accounts at Schwab. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in adjacent paragraphs generally benefit our clients. Schwab also makes available to our advisory firm other products and services that benefit us but may not directly benefit each client’s account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  provides access to client account data (such as duplicate trade confirmations and account statements)  facilitates trade execution and allocates aggregated trade orders for multiple client accounts  provides pricing and other market data  facilitate payment of our fees from our clients’ accounts, and  assists with back-office functions, recordkeeping and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise, such as:  educational conferences and events  technology, compliance, legal, and business consulting  publications and conferences on practice management and business succession, and  access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, they may arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Some of the noted tools and services made available by Schwab may Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 22 of 25  benefit our advisory firm but may not directly benefit a client account. While our firm does not think these services are considered "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934, certain jurisdictions where we serve client accounts believe they fall under this definition. However, the availability of these services benefits our firm because we do not have to produce or purchase them if clients maintain assets in accounts at our recommended custodian. There is a conflict of interest since our firm has an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than the client’s interest in receiving favorable trade execution. It is important to mention that the benefit received by our firm through participation in a custodian’s program does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a whole, not just those services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the custodian we may select. Our firm conducts periodic assessments of any recommended service provider which generally involves a review of the range and quality of services, reasonableness of fees, among other items, in comparison to industry peers. It is important to mention that the benefit received by our firm through participation in any custodian’s program does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a whole, not just those services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the custodian we may select. Our firm conducts periodic assessments of any recommended service provider which generally involves a review of the range and quality of services, reasonableness of fees, among other items, in comparison to industry peers. “Best execution” means the most favorable terms for a transaction based on all relevant factors, including those listed in the earlier paragraphs. We recognize our obligation in seeking best execution for our clients; however, it is our belief that the determinative factor is not always the lowest possible cost but whether the selected custodian’s transactions represent the best “qualitative execution” while taking into consideration the full range of services provided. Our firm will seek services involving competitive rates, but it may not necessarily correlate to the lowest possible rate for each transaction. We have determined that having our clients’ accounts trades completed through our recommended custodian is consistent with our obligation to seek best execution of client trades. A review is regularly conducted regarding recommending a custodian to our clients in light of our duty to seek best execution. Our internal policy and operational relationship with our recommended custodian require client accounts custodied with them to have trades executed per their order routing requirements. We do not direct which executing broker should be selected for client account trades, whether that is an affiliate of our custodian or another executing broker of our custodian’s choice. As a result, the client may pay higher commissions or other transaction costs (involving unbundled portfolio management services), experience greater spreads, or receive less favorable net prices on transactions than might otherwise be the case. In addition, since we routinely recommend a custodian to our advisory clients, and that custodian may choose to use the execution services of its broker affiliate for some or all of our client account transactions, there is an inherent conflict of interest involving our recommendation since our advisory firm receives the various products and/or services from our custodian as previously described. Note that we are not compensated for trade routing/order flow, nor are we paid commissions on such trades. We do not receive interest on an account’s cash balance. In addition, wrap fee accounts are unable to direct brokerage and, as a result, may experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case if they had the opportunity to direct brokerage. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 23 of 25  Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. This may also be termed “blocked” or “batched” orders. Aggregated orders are effected to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple client accounts should there be differences in prices, brokerage commissions or other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm may, but is not obligated, aggregate orders, and our firm does not receive additional compensation or remuneration because of aggregated transactions. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that the firm determines to aggregate client orders for the purchase or sale of securities, including securities in which a related person may invest, the firm will generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. Note that when trade aggregation is not allowed or infeasible and necessitates individual transactions (e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may have assessed higher costs or less favorable prices than those where aggregation has occurred. Advisory Firm Payments for Client Referrals Please refer to Items 4 and 6 for information with respect to our offerings/services and the potential conflicts of interest they present. Our firm does not participate in or receive economic benefit from any sales awards or other similar prizes involving its investment advisory activities. If we receive or offer an introduction to a client, we do not pay or earn referral fees, nor are there established quid pro quo arrangements. Each client retains the option to accept or deny such referral or subsequent services. An associate of the firm may hold individual membership or serve on boards or committees of professional industry associations. Generally, participation in any of these entities require membership fees to be paid, adherence to ethical guidelines, as well as in meeting experiential and educational requirements. A benefit these entities may provide to the investing public is the availability of online search tools that allow interested parties (prospective clients) to search for individual participants within a selected state or region. These passive websites may provide means for interested people to contact a participant via electronic mail, telephone number, or other contact information, to interview the participating member. The public may also choose to telephone staff to inquire about an individual within their area and would receive the same or similar information. A portion of these participant’s membership fees may be used so that their name will be listed in some or all these entities’ websites (or other listings). Prospective clients locating our advisory firm or an associate via these methods are not actively marketed by the noted associations, nor will they be the recipient of a testimonial or endorsement. Clients who find our firm in this way do not pay more for their services than clients referred to us in any other fashion. The firm does not pay these entities for prospective client referrals, nor is there a fee-sharing arrangement reflective of a solicitor engagement. Financial Information Our advisory firm will not take physical custody of client assets, nor do we have the type of account authority to have such control. Fee withdrawals must be made through an unaffiliated, qualified intermediary (e.g., custodian of record) per our prior written agreement with the client. Engagements with our firm do not require that we collect fees from a client of $1,200 or more for our advisory services that we have agreed to perform six months or more into the future. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 24 of 25  Neither our firm nor its management serve as general partner for a partnership or trustee for a trust in which the firm’s advisory clients are either partners of the partnership or beneficiaries of the trust (unless the beneficiary is an immediate family member). The firm and its management do not have a financial condition likely to impair its ability to meet commitments to clients, nor has the firm and its management been the subject of a bankruptcy petition. Due to the nature of our firm’s advisory services and operational practices, an audited balance sheet is not required nor included in this brochure. Glass Lakes Capital Management LLC Form ADV Part 2 – 20260515 Wrap Brochure SEC Page 25 of 25