GRANDVIEW ASSET MANAGEMENT LLC

Item 1: Cover Sheet FORM ADV PART 2A INFORMATIONAL BROCHURE GRANDVIEW ASSET MANAGEMENT LLC 4200 Crums Mill Road, 2nd Floor Harrisburg, PA 17112 www.grandviewassetmanagement.com Bruce A. Smith 717-541-1000 March 12, 2025 This brochure provides information about the qualifications and business practices of GrandView Asset Management LLC. If you have any questions about the contents of this brochure, please contact us at 717- 541-1000 or via email at bsmith@grandviewadvisor.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Our registration does not imply a certain level of skill or training. Additional information about GrandView Asset Management LLC (CRD# 172357) is also available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2: Statement of Material Changes GrandView Asset Management LLC is required to disclose any material changes to this ADV Part 2A here in Item 2. There have been no material changes since the most recently delivered Firm Brochure. 2  Item 3: Table of Contents TABLE OF CONTENTS Item 1: Cover Sheet ................................................................................................................................... 1 Item 2: Statement of Material Changes ..................................................................................................... 2 Item 3: Table of Contents .......................................................................................................................... 3 Item 4: Advisory Business ........................................................................................................................ 4 Item 5: Fees and Compensation ................................................................................................................ 6 Item 6: Performance-Based Fees ............................................................................................................... 8 Item 7: Types of Clients ............................................................................................................................ 8 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 8 Item 9: Disciplinary Information ............................................................................................................. 14 Item 10: Other Financial Industry Activities and Affiliations ................................................................... 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............ 16 Item 12: Brokerage Practices .................................................................................................................... 16 Item 13: Review of Accounts .................................................................................................................... 19 Item 14: Client Referrals and Other Compensation .................................................................................. 19 Item 15: Custody ....................................................................................................................................... 19 Item 16: Investment Discretion ................................................................................................................. 19 Item 17: Voting Client Securities .............................................................................................................. 20 Item 18: Financial Information ................................................................................................................. 20 3  INFORMATIONAL BROCHURE GRANDVIEW ASSET MANAGEMENT LLC Item 4: Advisory Business GrandView Asset Management LLC (“GrandView”) has been in business since 2006, but became an independently registered investment adviser in July 2014. The firm is owned by Bruce A. Smith. GrandView provides personalized investment management and financial planning services. The firm provides financial advice to individuals, families, trusts, charitable organizations and foundations, pensions and corporations. Financial Planning In most cases, the client will supply GrandView information including income, investments, savings, insurance, age, and many other items that are helpful to the firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, we will discuss your financial needs and goals with you, and compare your current financial situation with the goals you state. Once these are compared, we will create a financial and/or investment plan to help you meet your goals. The plan is intended to be a suggested blueprint of how to meet your goals. Not every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by you, it is very important that you accurately and completely communicate to us the information we need. Also, your circumstances and needs may change as your engagement with us progresses. It is very important that you continually update us with any changes so that if the updates require changes to your plan, we can make those changes. Otherwise, your plan may no longer be accurate. Asset Management If you wish us to manage your investment accounts, we will ask you to provide us with investment guidelines, so that we can create asset allocations that meet your needs. Some examples of guidelines include your risk tolerance, or a maximum amount of assets to be held in non-U.S. investments, or a limit on the amount of stocks in your portfolio. GrandView can assist you in developing these guidelines. Each client will have a written investment policy statement to guide both you and us in the management of your assets. Asset management services may be provided on a “discretionary” or on a “non-discretionary” basis. When GrandView is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management 4  Agreement that outlines the responsibilities of both the client and GrandView. When a client engages us to provide investment management services on a non-discretionary basis, we monitor the accounts in the same way as for discretionary services. The difference is that changes to your account will not be made until we have confirmed with you (either verbally or in writing) that our proposed change is acceptable to you. Wrap Program The GrandView Wrap Program (the “Program”) is a wrap fee program sponsored by GrandView Asset Management LLC (“GrandView”) which has been an independently registered investment adviser since July 2014. GrandView’s wrap fee program is only offered to clients who have their assets managed of a discretionary basis. For those clients, GrandView may include certain transactional costs in the client’s management fee. This arrangement is referred to a “Wrap Program”. Fees included in the wrap fee include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark-downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than Schwab Advisor Services. Because GrandView will be managing the assets of wrap fee program clients the same way as other non-wrap fee program clients, the use of external portfolio managers within the wrap program is expected to be limited. Therefore, there is no difference between how GrandView manages wrap fee accounts and how GrandView manages other accounts. Because of the nature of a wrap fee program, where wrap fees are not tied to an account’s frequency of trading and apply to generally all assets in the account, this fee arrangement is not appropriate for all accounts. For example, a wrap fee arrangement would not be appropriate for an account that holds primarily cash and cash equivalents, fixed income securities or no-transaction-fee mutual funds for a substantial period of time. GrandView does not include any custodial accounts in the wrap fee program. Clients whose accounts will be rarely traded should carefully consider whether the Wrap Program is appropriate. Clients are not required to participate in the Wrap Program. GrandView receives a portion of the wrap fee for our services. GrandView does not engage other portfolio managers to manage assets within the wrap fee program. GrandView is the sole portfolio manager in the wrap program, which means that GrandView receives a portion of the wrap fee for our services. Transaction fees are paid to various broker-dealers, mutual funds, and ETFs. The remainder of the wrap fee is the management fee payable to GrandView. GrandView does have an incentive to recommend Schwab to clients in order to reduce the fixed fee for transactions. GrandView attempts to mitigate this conflict by requiring that the firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own, evaluating all aspects, including the wrap program asset-based transaction pricing when considering what broker- dealers to recommend. GrandView will receive no additional compensation for offering the wrap fee program. Please see the separate Wrap Fee Brochure for a more complete description of the Wrap Program. 5  Assets under Management As of December 31, 2024, GrandView managed approximately $339,960,044 in assets of which $335,695,138 are on a discretionary basis. Item 5: Fees and Compensation Fees Charged A. All investment management clients will be required to execute an Investment Management Agreement that will describe the type of management services to be provided and the fees, among other items. Clients are advised that they may pay fees that are higher or lower than fees they may pay another advisor for the same services, and may in fact pay lower fees for comparable services from other sources. Clients are under no obligation at any time to engage or to continue to engage, GrandView for investment services. Financial Planning Hourly: For clients needing advice with a limited scope, financial planning services can be done on an hourly basis. Hourly rates range from $150 – $350 for all investment professionals at GrandView. The professional working on the assignment, as well as, the hourly rates is dependent upon a number of factors, most importantly the complexity of the assignment and the availability of professionals. An estimate of total hours to complete the assignment will be determined at the start of the engagement. Generally, fifty percent (50%) of this estimate will be payable upon signing the Financial Planning Agreement. The hourly rates stated are guidelines. Fees may be higher or lower than this range, based on the nature of the engagement. Fees are negotiable, and will depend on the anticipated complexity of your plan. Fixed Fee: For clients requiring a complete financial plan, services will be provided on a fixed fee basis. Fixed fees will typically range from $2,500 to $50,000, depending upon the nature and complexity of the assignment. For example, a client with complex estate planning issues, multiple sources of investment income, and special needs heirs will have a more complex plan (and therefore a higher fixed fee) than a client with no estate planning issues, a single heir and a single source of income. The fixed fee range stated is a guide. Fees are negotiable, and may be higher or lower than this range, based on the nature of the assignment. Some clients may also engage GrandView on a project basis to provide advice on isolated matters, such as an evaluation of a client’s employer-sponsored retirement plan. Asset Management Generally, fees for asset management range between 1.00% and 1.50% per annum of the market value of a client’s assets managed by GrandView. The fees stated are a guide. Fees are negotiable and may be higher or lower than the range listed above, based on the nature of the account. Factors affecting fee percentages include the size of the account, complexity of asset structures, and other factors. Fee Payment B. Financial Planning: Generally, fifty percent (50%) of the anticipated financial planning fee will be payable upon signing the Financial Planning Agreement, with the remainder due upon completion of the financial plan. For hourly engagements, the final amount due will be based upon actual hours expended. 6  For fixed fee engagements, the final amount due will be fifty percent (50%) of the fixed fee. Asset Management: For clients whose assets are managed by the firm, investment advisory fees will be debited directly from each client’s account. The advisory fee is paid quarterly, in advance, and the value used for the fee calculation is the net value as of the last market day of the previous quarter. This means that if your annual fee is 1.50%, then each quarter we will multiply the value of your account by 1.50% then divide by 4 to calculate our fee. No adjustments are made to the advisory fee for inflows or outflows made during a billing quarter. To the extent there is cash in your account, it will be included in the value for the purpose of calculating fees only if the cash is part of an investment strategy. Once the calculation is made, we will instruct your account custodian to deduct the fee from your account and remit it to GrandView. While almost all of our clients choose to have their fee debited from their account, we will invoice clients upon request. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee. Other Fees C. There are a number of other fees that can be associated with holding and investing in securities. You will be responsible for fees including transaction fees for the purchase or sale of a mutual fund or Exchange Traded Fund, or commissions for the purchase or sale of a stock. To the extent you participate in GrandView’s Wrap Program, you will not be responsible for these fees, as they will be paid by GrandView as part of your management fee. Expenses of a fund will not be included in management fees, as they are deducted from the value of the shares by the mutual fund manager. When selecting mutual funds that have multiple share classes for recommendation to clients, GrandView will take into account the internal fees and expenses associated with each share class, and it is GrandView policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise. For complete discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued by that fund. GrandView can provide or direct you to a copy of the prospectus for any fund that we recommend to you. Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial issues. Pro-rata Fees D. If you become a client during a quarter, you will pay a management fee for the number of days left in that quarter. If you terminate our relationship during a quarter, you will be entitled to a refund of any management fees for the remainder of the quarter. Once your notice of termination is received, we will assess pro-rated fees for the number of days between the end of the prior billing period and the date of termination to be paid in whatever way you direct (check, wire). GrandView will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning they will no longer be visible to GrandView and will become a retail account with the custodian. Compensation for the Sale of Securities. E. To permit GrandView clients to have access to as many investment solutions as possible, certain professionals of GrandView may be registered representatives of Purshe Kaplan Sterling Investments, 7  Inc. (“PKS”), a FINRA member broker-dealer. The relationship with PKS allows those professionals to provide additional products to clients’ portfolios that would not otherwise be available. Because PKS supervises the activities of those professionals as registered representatives of PKS, the relationship may be deemed material. However, PKS is not affiliated with GrandView or considered a related party. PKS does not make investment decisions for client accounts. Registered representative status enables these professionals to receive customary commissions for the sales of various securities, including those he recommends to clients. In addition, when mutual funds are utilized, depending on the share class selected, the registered representatives also receive additional ongoing 12b-1 fees from the mutual fund company for mutual fund purchases during the period you maintain the mutual fund investment. Commissions charged and 12b-1 fees received for these products will not offset management fees owed to GrandView. Receipt of commissions and 12b-1 fees for investment products that are recommended to clients gives rise to a conflict of interest for the representative, in that the individual who will receive the commissions is also the individual that is recommending that the client purchase a given product. There is an additional conflict of interest when registered representative is selecting a more expensive 12b-1 fee paying mutual fund share class when a lower-cost share class is available for the same fund. These conflicts are disclosed to clients verbally and in this brochure. Clients are advised that they may choose to implement any investment recommendation through another broker-dealer that is not affiliated with GrandView. GrandView attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring employees to acknowledge their fiduciary responsibility toward each client. Item 6: Performance-Based Fees GrandView will not charge performance-based fees. Item 7: Types of Clients Clients advised may include individuals, families, trusts, charitable organizations and foundations, pensions and corporations. GrandView requires each client to place at least $20,000 with the firm. This minimum may be waived in the discretion of GrandView. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss It is important for you to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. Determining which areas of the market provide the best investment opportunities can be a daunting task and sometimes economic climates break with tradition, making Investment decisions even more arduous. These situations have historically offered opportunities for patient shareholders to increase their exposure in great companies. The credit crisis has underscored the value of a strong balance sheet, a once underappreciated quality. Our goal with the Market Strength Allocation Select Portfolio is to invest in undervalued companies with strong market positions that have the following qualities: 1. Strong balance sheets; 2. Skilled management; 8  3. Highly liquid; 4. Ability to generate earnings growth; and 5. Record of financial strength and profit growth. Through our selection process we seek to find the companies that we believe have the best prospects for above-average capital appreciation. In general, growth stocks are those with high relative price-to-book ratios while value stocks are those with low relative price-to-book ratios. It is important to note that stocks with growth potential may have balance sheets and fundamentals that are not as strong as other stocks in the portfolio, which increase the risk and volatility of the portfolio. Such stocks may also have higher Price/Earnings ratios and Beta ratios which can offer more growth but include additional risk to the portfolio. These stocks have potential for growth but offer just as much downside to the portfolio. GrandView employs a four-step process for picking the investments for a clients’ portfolio. The steps are as follows: 1) Identify the universe The first step in our selection process is to identify each universe from which we will select the stocks for the five market segments. Each universe contains stocks selected specifically for each component of the allocation. 2) Screen for financial strength The next step in our process is to evaluate companies based on multiple factors. These factors are designed to identify those stocks which exhibit strong fundamental characteristics and to eliminate those that do not meet our investment criteria. 3) Examine historical financial results The next step in our process is to look for those companies that have earned a net cash flow return on investment that is above the average of their peers. Historically, companies that have increased their cash flows at a higher rate have rewarded shareholders with superior total returns. 4) Select companies with attractive valuations The final step in our process is to select companies based on the fundamental analysis of our team of research analysts. The stocks selected for the portfolio are those that meet our investment objective, trade at attractive valuations and, in our opinion, are likely to exceed market expectations of future cash flows. Upon completion of the investment policy statement, we will periodically recommend securities transactions in your portfolio to meet the guidelines of the asset allocation strategy. It is important to remember that because market conditions can vary greatly, your asset allocation guidelines are not necessarily strict rules. Rather, we review accounts individually, and may deviate from the guidelines as we believe necessary. The specific securities we recommend for your account will depend on market conditions and our research at the time. Generally, we recommend a mix of stocks, bonds, ETFs, and mutual funds. When used, specific funds are chosen based on where its investment objective fits into the asset allocation recommended by GrandView, its risk parameters, past performance, peer rankings, fees, expenses, and any other aspects of the fund GrandView deems relevant to that particular fund. We base our conclusions on predominantly publicly available research, such as regulatory filings, press releases, competitor analyses, and in some cases research we receive from our custodian or other market analyses. We will 9  also utilize technical analyses, which means that we will review the past behaviors of the security and the markets in which it trades for signals as to what might happen in the future. Most mutual funds offer different share classes with vary fee structures, including share classes with sales load, sales charges, or 12b-1 fees. 12b-1 fees are deducted from the mutual funds’ assets on an ongoing basis and are paid to broker-dealers and registered representatives whose clients own those shares to cover fund distribution and shareholder services. This receipt of fees presents a potential conflict of interest, as GrandView has an incentive to recommend more expensive share classes to clients based on the compensation received, rather than based upon the client’s needs. However, it is GrandView policy that when specific funds offer more than one share class, GrandView will select the lowest-cost share class available to the client, absent circumstances that dictate otherwise. Additionally, as assets are transitioned from a client’s prior advisors to GrandView, clients may hold legacy securities and may place restrictions on individual security types. Legacy securities are those that a client owned prior to or separate from its GrandView portfolio. If a client transitions mutual fund shares to GrandView that are not the lowest-cost share class, and GrandView is not recommending disposing of the security altogether, GrandView will attempt to convert such mutual fund share classes into the lowest- cost share classes the client is eligible for, taking into account any adverse tax consequences associated with such conversion. Depending on a client’s given circumstances, GrandView may recommend that a client roll over retirement plan assets to an Individual Retirement Account (IRA) managed by us. As a result, GrandView may earn fees on those accounts. This presents a conflict of interest, as GrandView has a financial incentive to recommend that a client roll over retirement assets into an IRA we will manage. This conflict is disclosed to clients verbally and in this brochure. Clients are also advised that they are under no obligation to implement the recommendation to roll over retirement plan assets. GrandView attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring employees to acknowledge their fiduciary responsibility toward each client. Risk of Loss There are always risks to investing. Clients should be aware that all investments carry various types of risk including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following: • Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • Risks Related to Equity Investments. An investment in a managed account should be made with an understanding of the risks involved with owning common stocks, such as an economic recession and the possible deterioration of either the financial condition of the issuers of the equity securities or the general condition of the stock market. • Foreign Securities Risk. An investment in a portfolio containing equity securities of foreign issuers is subject to additional risks, including currency fluctuations, political risks, withholding, the lack of adequate financial information, and exchange control restrictions impacting foreign issuers. Risks associated with investing in foreign securities may be more pronounced in emerging markets where the securities markets are substantially smaller, less liquid, less regulated and more volatile than the U.S. and developed foreign markets. • Regulatory Risk. Changes in laws and regulations from any government can change the value of a 10  given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • Tax Risks Related to Short Term Trading: Clients should note that GrandView may engage in short-term trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. GrandView endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • Financial Risk. The amount of debt or leverage determines the financial risk of a company. • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • Short Sales. “Short sales” are a way to implement a trade in a security GrandView feels is overvalued. In a “long” trade, the investor is hoping the security increases in price. Thus, in a long trade, the amount of the investor’s loss (without margin) is the amount paid for the security. In a short sale, the investor is hoping the security decreases in price. However, unlike a long trade where the price of the security can only go from the purchase price to zero, in a short sale, the prince of the security can go infinitely upwards. Thus in a short sale, the potential for loss is unlimited and unknown, where the potential for loss in a long trade is limited and knowable. GrandView utilizes short sales only when the client’s risk tolerances permit. • Risks specific to private placements, sub-advisors and other managers. If we invest some of your assets with another advisor, including a private placement, there are additional risks. These include risks that the other manager is not as qualified as we believe them to be, that the investments they use are not as liquid as we would normally use in your portfolio, or that their risk management guidelines are more liberal than we would normally employ. • Information Risk. All investment professionals rely on research in order to make conclusions about investment options. This research is always a mix of both internal (proprietary) and external (provided by third parties) data and analyses. Even an adviser who says they rely solely on proprietary research must still collect data from third parties. This data, or outside research is chosen for its perceived reliability, but there is no guarantee that the data or research will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the adviser to reach satisfactory investment conclusions. • Small Companies. Some investment opportunities in the marketplace involve smaller issuers. These companies may be starting up or are historically small. While these companies sometimes have potential for outsized returns, they also have the potential for losses because the reasons the company is small are also risks to the company’s future. For example, a company’s management may lack experience, or the company’s capital for growth may be restricted. These small companies also tend to trade less frequently that larger companies, which can add to the risks associated with their securities because the ability to sell them at an appropriate price may be limited as compared to the markets as a whole. Not only do these companies have investment risk, if a client is invested in such small companies and requests immediate or short-term liquidity, these securities may require a significant discount to value in order to be sold in a shorter time frame. • Concentration Risk. While GrandView selects individual securities, including mutual funds, for 11  client portfolios based on an individualized assessment of each security, this evaluation comes without an overlay of general economic or sector specific issue analysis. This means that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub-sector (among other types of potential concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for example, the client’s equity portfolio may be affected negatively, including significant losses. • Transition risk. As assets are transitioned from a client’s prior advisers to GrandView there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the asset allocation strategy selected by GrandView. However, this transition process may take some time to accomplish. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into recommendations of GrandView may adversely affect the client's account values, as GrandView’s recommendations may not be able to be fully implemented. • Restriction Risk. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions may make managing the accounts more difficult, thus lowering the potential for returns. • Risks Related to Investment Term. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain its value. • Risks Related to Investment Liquidity. Some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses. • General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. o Equity Securities. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. o Mutual Funds. The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. When selecting mutual funds that have multiple share classes for recommendation to clients, GrandView will take into account the internal fees and expenses associated with each share class, as it is our policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise. o Exchange Traded Funds (ETFs). The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs 12  have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. o Real Estate Investment Trust (REIT). A REIT is an entity, typically a trust or corporation that accepts investments from a number of investors, pools the money, and then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income, and the relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. Such investment focus can be beneficial if the properties are successful but lose significant principal if the properties are not successful. REITs may also employ significant leverage for the purpose of purchasing more investments with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure they understand the role of the REIT in their portfolio. o Fixed Income. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by the Fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. o MLPs: GrandView may recommend that portions of client portfolios be allocated to master limited partnerships, otherwise known as “MLPs”. An MLP is a publicly traded entity that is designed to provide tax benefits for the investor. In order to preserve these benefits, the MLP must derive most, if not all, of its income from real estate, natural resources and commodities. While MLPs may add diversification and tax favored treatment to a client’s portfolio, they also carry significant risks beyond more traditional investments such as stocks, bonds and mutual funds. One such risk is management risk-the success of the MLP is dependent upon the manager’s experience and judgment in selecting investments for the MLP. Another risk is the governance structure, which means the rules under which the entity is run. The investors are the limited partners of the MLP, with an affiliate of the manager typically the general partner. This means the manager has all of the control in running the entity, as opposed to an equity investment where shareholders vote on such matters as board composition. There is also a significant amount of risk with the underlying real estate, resources, or commodities investments. Clients should ask GrandView any questions regarding the role of MLPs in their portfolio. o International Investing: Investing outside of the United States, especially in emerging markets, can have special or enhanced risks. The most obvious are political risk (changes in local politics can have a vast impact on the markets in that country as well as regulations affecting given issuers) and currency risk (changes in exchange rates between the dollar and the local denominations can materially affect the value of the security even if the underlying fundamentals and market price are stagnant). There are other risks, including enhanced liquidity risk, meaning that while domestic equities and mutual funds are generally easily liquidated (though there may be a risk of loss due to the timing of the sale), equities in other jurisdictions may be subject to the circumstances of lower overall market volume and fewer companies on an emerging exchange. In addition, there may be less information and less transparency in a foreign market or from a foreign company. Foreign markets impose 13  different rules than domestic markets, which may not be to an investor's advantage. Also, companies in foreign jurisdictions are generally able to avail themselves of local laws and venues, meaning that legal remedies for U.S. investors may not be as easily obtained as in the U.S. o Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, GrandView will consider investment in a corresponding exchange traded securities and/or private funds that provides cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications with codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Cryptocurrency is currently considered to be a speculative investment. Please Note: Investment in cryptocurrencies is subject to the potential for liquidity constraints, extreme price volatility and complete loss of principal. Item 9: Disciplinary Information There are no disciplinary items to report. Item 10: Other Financial Industry Activities and Affiliations A. Broker-dealer To permit GrandView clients to have access to as many investment solutions as possible, certain professionals of GrandView may be registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), a FINRA member broker-dealer. The relationship with PKS allows those professionals to provide additional products to clients’ portfolios that would not otherwise be available. Because PKS supervises the activities of those professionals as registered representatives of PKS, the relationship may be deemed material. However, PKS is not affiliated with GrandView or considered a related party. PKS does not make investment decisions for client accounts. Registered representative status enables these professionals to receive customary commissions for the sales of various securities, including those he recommends to clients. Commissions charged for these products will not offset management fees owed to GrandView. B. Futures Commission Merchant/Commodity Trading Advisor Neither the principal of GrandView, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons Special Needs Advisors, LLC GrandView is under common control with Special Needs Advisors, LLC, which provides financial and other related planning services to families which include children with special needs regarding non-investment related matters such as estate planning, tax planning, insurance planning, etc. Special Needs Advisors, LLC is not a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. 14  To the extent requested, GrandView, may recommend the services of other professionals for certain non-investment implementation services. Such recommendations will also include the use of GrandView Asset Management, LLC for investment recommendation implementation, and will also include representatives of GrandView in their separate capacities as independent insurance agents and as registered representatives of PKS. This poses conflicts of interest. GrandView will attempt to mitigate these conflicts by disclosing the conflict to clients and noting in its policies and procedures each individual representative’s obligation to place client interests ahead of their own. Please also refer to Item 5.E. related to the conflicts of interest related to engaging individuals as registered representatives of a broker-dealer. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from GrandView. If you engage any professional recommended by GrandView, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Insurance Certain professionals of GrandView are separately licensed as independent insurance agents. As such, these professionals may conduct insurance product transactions for GrandView clients, in their capacity as licensed insurance agents, and will receive customary commissions for these transactions in addition to any compensation received in his capacity as employees of GrandView. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. These professionals therefore have incentive to recommend insurance products based on the compensation to be received, rather than on a client’s needs. The receipt of additional fees for insurance commissions is therefore a conflict of interest, and clients should be aware of this conflict when considering whether to engage GrandView or utilize these professionals to implement any insurance recommendations. GrandView attempts to mitigate this conflict of interest by disclosing the conflict to clients, and informing the clients that they are always free to purchase insurance products through other agents that are not affiliated with GrandView, or to determine not to purchase the insurance product at all. GrandView also attempts to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the clients of GrandView, which requires that employees put the interests of clients ahead of their own. Sublease GrandView subleases a portion of its office space to Carrie Wise Tax Services. Neither GrandView nor Carrie Wise Tax Services are under common control, and Grandview is not compensated for referring clients to Carrie Wise Tax services for tax services. GrandView also subleases a portion of its office space to DeSantis Krupp, LLC, a law firm which provides legal services including trust and tax planning services. Grandview Asset Management LLC and DeSantis Krupp, LLC are not under common control, and GrandView is not compensated for referring clients to DeSantis Krupp, LLC for legal services. However, the subtenants may share certain non-investment related expenses connected to their shared tenancy with GrandView. GrandView may recommend that clients in need of estate and tax planning utilize the services of Desantis Krupp, LLC and clients in need of tax services utilize Carrie Wise Tax Services, which may present a conflict of interest. GrandView attempts to mitigate this conflict by reminding clients they are under no obligation to engage the services of any such recommended professional. Additionally, clients retain absolute discretion in determining whether to engage Desantis Krupp, LLC or Carrie Wise Tax Services or any other professionals for tax or legal services and are free to accept or reject any recommendation from 15  GrandView. Employees are also bound to the firm’s Code of Ethics, which requires employees to act in the best interests of clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions A. of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. GrandView does not recommend to clients that they invest in any security in which GrandView, B. or any principal thereof has any financial interest. C. On occasion, an employee of GrandView may purchase for his or her own account securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. D. On occasion, an employee of GrandView may purchase for his or her own account securities which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. Item 12: Brokerage Practices Recommendation of Broker-Dealer A. GrandView does not maintain custody of client assets, though GrandView may be deemed to have custody if a client grants GrandView authority to debit fees directly from their account (see Item 15 below). Assets will be held with a qualified custodian, which is typically a bank or broker-dealer. GrandView recommends that investment accounts be held in custody by Schwab Advisor Services (“Schwab”), a qualified custodian. GrandView is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when GrandView instructs them to, which GrandView does in accordance with its agreement with you. While GrandView recommends that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. GrandView does not open the account for you, although GrandView may assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How we select brokers/custodians 16  We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including both quantitative (Ex: costs) and qualitative (execution, reputation, service) factors. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to GrandView as part of our evaluation of these broker-dealers. Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Effective October 7, 2019, Schwab eliminated commissions for online trades of U.S. equities, ETFs, and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). Products and services available to us from Schwab Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our 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 described below are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us as long as we keep a total of at least $10 million of the assets of our firm’s advisory clients in accounts at Schwab. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Here is a more detailed description of Schwab’s support services: Services that Benefit You. 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 this paragraph generally benefit you and your account. Services that May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ 17  accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping and client reporting. • • provide pricing and other market data; • • Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events technology, compliance, legal, and business consulting; access to employee benefits providers, human capital consultants and insurance providers. • • • publications and conferences on practice management and business succession; and • Schwab may provide some of these services itself. In other cases, it will 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. Our Interest in Schwab’s Services. The availability of the services described above (under the caption “Products and Services Available to Us from Schwab”) from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so long as we keep a total of at least $10 million of client assets in accounts at Schwab. In addition, Schwab has agreed to pay for up to $30,000 of certain marketing and technology products and services provided to us by third parties once the total of our clients’ assets maintained in accounts at Schwab reaches $150 million. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The $10 and $150 million minimums described above may give us an incentive to require that you maintain your account with Schwab based on our interest in receiving Schwab’s and services and Schwab’s payment for third party services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by the scope, quality and price of Schwab’s services and not Schwab’s services and Schwab’s payment for third party services that benefit only us. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to GrandView as part of our evaluation of these broker-dealers. Aggregating Trades B. Commission costs per client may be lower on a particular trade if all clients in whose accounts the trade is to be made are executed at the same time. This is called aggregating trades. For clients not working with GrandView through the wrap program, GrandView may place trades for the same security needed in multiple accounts by executing one trade, and then allocate the trades to each account after execution. If an aggregate trade is not fully executed, the securities will be allocated to client accounts on a pro rata 18  basis, except where doing so would create an unintended adverse consequence (For example, if a pro rata division would result in a client receiving a fraction of a share, or a position in the account of less than 1%.) Item 13: Review of Accounts All accounts will be reviewed by a senior professional on at least a quarterly basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. The annual report in writing provided by GrandView is intended to review asset allocation. All clients will receive statements and confirmations of trades directly from Schwab. Please refer to Item 15 regarding Custody. Item 14: Client Referrals and Other Compensation A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. Please refer to Item 12, where we discuss recommendation of Broker-Dealers. B. Compensation to Non-Advisory Personnel for Client Referrals. GrandView does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody There are two avenues through which GrandView has custody of client funds; by directly debiting its fees from client accounts pursuant to applicable agreements granting such right, and potentially by permitting clients to issue standing letters of authorization (“SLOAs”). SLOAs permit a client to issue one document that directs GrandView to make distributions out of the client’s account(s). Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee. We encourage clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on reports prepared by GrandView against the information in the statements provided directly from Schwab. Please alert us of any discrepancies. In addition to the account custodian’s custody procedures, clients issuing SLOAs will be requested to confirm, in writing, that the accounts to which funds are distributed are parties unrelated to GrandView. Item 16: Investment Discretion When GrandView is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes 19  are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You may receive at your request written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and GrandView. When a client engages GrandView to provide investment management services on a non-discretionary basis, the accounts are monitored by GrandView. The difference is that changes to your account will not be made until GrandView has confirmed with you (either verbally or in writing) that the proposed change is acceptable to you. Item 17: Voting Client Securities Copies of our Proxy Voting Policies are available upon request. From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. GrandView will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. GrandView will not give clients advice on how to vote proxies. Item 18: Financial Information GrandView does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients. 20  Item 1: Cover Sheet INFORMATIONAL BROCHURE WRAP FEE PROGRAM GRANDVIEW ASSET MANAGEMENT LLC 4200 Crums Mill Road, 2nd Floor Harrisburg, PA 17112 www.grandviewassetmanagement.com Bruce A. Smith 717-541-1000 March 12, 2025 This wrap fee program brochure provides information about the qualifications and business practices of GrandView Asset Management LLC. If you have any questions about the contents of this brochure, please contact us at 717-541-1000. Information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. GrandView Asset Management LLC is a registered investment adviser. Registration does not imply any certain level of skill or training. Additional information about GrandView Asset Management LLC (CRD# 172357) is also available on the SEC’s website at www.adviserinfo.sec.gov. i  Item 2: Material Changes GrandView Asset Management LLC is required to include in this Item 2 any material changes to this Wrap Brochure. There have been no material changes since the most recently delivered Firm Brochure. ii  Item 3: Table of Contents Table of Contents Item 1: Cover Sheet ...................................................................................................................................... i Item 2: Material Changes ............................................................................................................................ ii Item 3: Table of Contents ........................................................................................................................... iii Item 4: Services, Fees, and Compensation ................................................................................................. iv Item 5: Account Requirement and Type of Clients ................................................................................... vii Item 6: Portfolio Manager Selection and Evaluation ................................................................................ vii Item 7: Client Information provided to Portfolio Managers .................................................................... viiii Item 8: Client Contact with Portfolio Managers ...................................................................................... viiii Item 9: Additional Information ................................................................................................................. viii iii  WRAP FEE PROGRAM GRANDVIEW ASSET MANAGEMENT LLC Item 4: Services, Fees, and Compensation The GrandView Wrap Program (the “Program”) is a wrap fee program sponsored by GrandView Asset Management LLC (“GrandView”) which has been in business since 2006, but became an independently registered investment adviser in July 2014. The firm is owned by Bruce A. Smith. GrandView provides personalized investment management and financial planning services. The firm provides financial advice to individuals, families, trusts, charitable organizations and foundations, pensions, and corporations. As of December 31, 2024, GrandView managed approximately $339,960,044 in assets of which $335,695,138 are on a discretionary basis. A. Description of the Program Asset Management GrandView requires each client to place at least $20,000 with the firm. This minimum may be waived in the discretion of GrandView. GrandView’s wrap fee program is only offered to clients who have their assets managed on a discretionary basis. Asset management services within the Program may be provided on a “discretionary” basis. When GrandView is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive quarterly statements from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and GrandView. Schwab’s Brokerage Services. In addition to the foregoing portfolio management and other services, the Program includes the brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. GrandView is an independently owned and operated and not affiliated with Schwab. Schwab will act solely as a broker- dealer and not as an investment advisor to you. It will have no discretion over your account and will act solely on instructions it receives from us [or you]. Schwab has no responsibility for our services and undertakes no duty to you to monitor our management of your account or other services we provide to you. Schwab will hold your assets in a brokerage account and buy and sell securities and execute other transactions when we [or you] instruct them to. While we require that you use Schwab as custodian/broker to participate in our program, you will decide whether to do so and open your account with Schwab by entering into an account agreement directly with them. We do not open the account iv  for you. If you do not wish to place your assets with Schwab, then we cannot manage your account in the program. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account, as described below. Fees and Compensation Fees Charged All clients will be required to execute a written agreement that will describe the type of services to be provided and the fees, among other items. Our Wrap Fees Generally, our wrap fees range between 1.00% to 1.50% per annum of the market value of a client’s assets managed by GrandView. The fees stated are a guide. Fees are negotiable and may be higher or lower that the above range, based on the nature of the account. Factors affecting fee percentages include the size of the account, complexity of asset structures, and other factors. Because our wrap fees are not tied to an account’s frequency of trading and apply generally to all assets in the account, this fee arrangement is not appropriate for all accounts. For example, a wrap fee arrangement would not be appropriate for an account that holds primarily cash and cash equivalents, fixed income securities or no-transaction-fee mutual funds for a substantial period of time. GrandView does not include any custodial accounts in the wrap fee program. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. Investment advisory fees will be debited directly from each client’s account. The advisory fee is paid quarterly, in advance, and the value used for the fee calculation is the net value as of the last market day of the previous quarter. This means that if your annual fee is 1.50%, then each quarter we will multiply the value of your account by 1.50% then divide by 4 to calculate our fee. No adjustments are made to the advisory fee for inflows or outflows made during a billing quarter. To the extent there is cash in your account, it will be included in the value for the purpose of calculating fees only if the cash is part of an investment strategy. Once the calculation is made, we will instruct your account custodian to deduct the fee from your account and remit it to GrandView. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee. Fees We Pay Schwab. In addition to compensating us for our portfolio management, other investment advisory, and other services to you, the wrap fees you pay us also allow us to pay Schwab for the brokerage services it provides to you, as described above, as well as additional services Schwab provides us, as described below. We pay Schwab certain fees that it would otherwise charge you. These fees may include (a) flat dollar per trade fees for Schwab’s prime brokerage and trade away services (through which we can have trades for your account at Schwab executed by broker-dealers other than Schwab), (b) transaction-based fees imposed on Schwab by regulatory organizations and exchanges and fees to offset processing costs incurred by Schwab for the exchange of securities for equity, options, or other covered security sell transactions (sometimes referred to as Exchange Process Fees), and (c) short- v  term redemption fees on mutual funds (including, but not limited to, those available through Schwab’s Mutual Fund OneSource®). Effective October 7, 2019, Schwab eliminated commissions for online trades of U.S. equities, ETFs, and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. Relative Cost of Our Wrap Fee Program to You. The program may cost you more or less than purchasing our investment advice and Schwab’s brokerage services separately. The relative cost of our wrap fee program to you is influenced by various factors, including the cost of our investment advice and Schwab’s brokerage services if you purchased them separately, the types of investments held in your account, and the frequency and size of trades we make for your account. For example, if the number of transactions in your account is low enough, the wrap fee you pay us may exceed the stand-alone investment advisory fee and separate brokerage commissions that you otherwise would have paid. Our fees for stand-alone investment advisory services that are comparable to those we provide as part of the program fall in the same range as fees for account in the Program. We have agreed with Schwab that the wrap fee we charge you will not be more than the transaction- based fees we pay Schwab plus the stand-alone investment advisory fee we would otherwise separately charge you (i.e., we don’t markup Schwab’s fees). B, C Additional Fees, and Costs You May Pay. Our wrap fee does not cover the fees and costs listed below, which may apply to assets in your enrolled accounts to which our wrap fee also applies, and to transactions in your accounts. • Commissions and other fees for services provided by broker-dealers other than Schwab for transactions executed or effected by or through them that settle into or from your account at Schwab such as through our use of Schwab’s Prime Brokerage or Trade Away Services. You will be responsible for paying any commissions and other fees or compensation charged by broker- dealers other than Schwab. Because you will pay our wrap fee in addition to any commissions and/or other charges paid to broker-dealers other than Schwab who execute transactions for your account, we may have an incentive to execute transactions for your accounts through Schwab, and this incentive could, in some circumstances, conflict with our duty to seek best execution. • Fees charged by mutual fund companies, unit investment trusts (UITs), closed-end funds and other collective investment vehicles, including, but not limited to, sales loads (a portion of which are paid to Schwab) and/or charges and short-term redemption fees. • Short-term redemption fees charged by Schwab for funds other than those available through the Schwab Mutual Fund OneSource® service. • Markups and markdowns, bid-ask spreads, selling concessions and the like received by Schwab in connection with transactions it executes as principal by selling or buying securities to or from you for its own account. Principal transactions contrast with those in which Schwab acts as your agent in effecting trades between you and a third party. Schwab may make a profit or incur a loss on trades in which it acts as principal. Markups and markdowns and bid-ask spreads are not separate fees, but rather are reflected in the net price at which a trade order is executed. vi  • Transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, fees required by law, and any other fees or charges similar to those described above. • Custody, trading, and setup fees for alternative assets (such as non-standard assets, non-publicly traded limited partnership interests, foreign securities, non-marketable securities, etc.). A complete list of Schwab’s charges and fees is contained in the Charles Schwab Pricing Guide, which you will receive promptly following the opening of your account with Schwab. Pro-rata Fees If you become a client during a quarter, you will pay a management fee for the number of days left in that quarter. If you terminate our relationship during a quarter, you will be entitled to a refund of any management fees for the remainder of the quarter. Once your notice of termination is received, we will assess pro-rated fees for the number of days between the end of the prior billing period and the date of termination to be paid in whatever way you direct (check, wire). GrandView will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning they will no longer be visible to GrandView and will become a retail account with the custodian. Item 5: Account Requirement and Type of Clients Clients participating in the program may include individuals, families, trusts, charitable organizations and foundations, pensions, and corporations. GrandView requires each client to place at least $20,000 with the firm. This minimum may be waived in the discretion of GrandView. Item 6: Portfolio Manager Selection and Evaluation The wrap fee program offered by GrandView is sponsored by the firm, and GrandView is the only portfolio manager. The only fees covered under the wrap fee program are transaction fees associated with the purchase and sale of securities in an account managed by GrandView. All client accounts managed by GrandView, including wrap fee program clients, are managed with similar processes, although account recommendations may differ. Methods of Analysis, Investment Strategies and Risk of Loss It is important for you to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. Please refer to Item 8 of GrandView’s Informational Brochure, incorporated into this brochure, for a complete description of GrandView’s methods of analysis and investment strategies. Performance-Based Fees GrandView will not charge performance-based fees. Voting Client Securities Copies of our Proxy Voting Policies are available upon request. vii  From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. GrandView will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. GrandView will not give clients advice on how to vote proxies. Item 7: Client Information provided to Portfolio Managers Please see response to Item 6, above. Item 8: Client Contact with Portfolio Managers Clients may contact GrandView, the only portfolio manager, at any time. Item 9: Additional Information Disciplinary Information Neither the firm not any of its employees or principals has any disciplinary information to report. Other Financial Industry Activities and Affiliations Broker-dealer To permit GrandView clients to have access to as many investment solutions as possible, certain professionals of GrandView may be registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), a FINRA member broker-dealer. The relationship with PKS allows those professionals to provide additional products to clients’ portfolios that would not otherwise be available. Because PKS supervises the activities of those professionals as registered representatives of PKS, the relationship may be deemed material. However, PKS is not affiliated with GrandView or considered a related party. PKS does not make investment decisions for client accounts. Registered representative status enables these professionals to receive customary commissions for the sales of various securities, including those he recommends to clients. In addition, when mutual funds are utilized, depending on the share class selected, the registered representatives also receive additional ongoing 12b-1 fees from the mutual fund company for mutual fund purchases during the period you maintain the mutual fund investment. Commissions charged and 12b-1 fees received for these products will not offset management fees owed to GrandView. Receipt of commissions and 12b-1 fees for investment products that are recommended to clients gives rise to a conflict of interest for the representative, in that the individual who will receive the commissions is also the individual that is recommending that the client purchase a given product. There is an additional conflict of interest when registered representative is selecting a more expensive 12b-1 fee paying mutual fund share class when a lower-cost share class is available for the same fund. These conflicts are disclosed to clients verbally and in this brochure. Clients are advised that they may choose to implement any investment recommendation through another broker-dealer that is not viii  affiliated with GrandView. GrandView attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring employees to acknowledge their fiduciary responsibility toward each client. Futures Commission Merchant/Commodity Trading Advisor Neither members of management, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Relationship with Related Persons Special Needs Advisors, LLC GrandView is under common control with Special Needs Advisors, LLC, which provides financial and other related planning services to families which include children with special needs regarding non-investment related matters such as estate planning, tax planning, insurance planning, etc. Special Needs Advisors, LLC is not a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. To the extent requested, GrandView, may recommend the services of other professionals for certain non-investment implementation services. Such recommendations will also include the use of GrandView Asset Management, LLC for investment recommendation implementation, and will also include representatives of GrandView in their separate capacities as independent insurance agents and as registered representatives of PKS. This poses conflicts of interest. GrandView will attempt to mitigate these conflicts by disclosing the conflict to clients and noting in its policies and procedures each individual representative’s obligation to place client interests ahead of their own. Please also refer to Item 5.E. related to the conflicts of interest related to engaging individuals as registered representatives of a broker-dealer. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from GrandView. If you engage any professional recommended by GrandView, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Insurance Certain professionals of GrandView are separately licensed as independent insurance agents. As such, these professionals may conduct insurance product transactions for GrandView clients, in their capacity as licensed insurance agents, and will receive customary commissions for these transactions in addition to any compensation received in his capacity as employees of GrandView. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. These professionals therefore have incentive to recommend insurance products based on the compensation to be received, rather than on a client’s needs. The receipt of additional fees for insurance commissions is therefore a conflict of interest, and clients should be aware of this conflict when considering whether to engage GrandView or utilize these professionals to implement any insurance recommendations. GrandView attempts to mitigate this conflict of interest by disclosing the conflict to clients, and informing the clients that they are always free to purchase insurance products through other agents that are not affiliated with GrandView, or to determine not to purchase the insurance product at all. GrandView also attempts to mitigate the conflict of interest by requiring employees to acknowledge ix  in the firm’s Code of Ethics, their individual fiduciary duty to the clients of GrandView, which requires that employees put the interests of clients ahead of their own. Sublease GrandView subleases a portion of its office space to Carrie Wise Tax Services. Neither GrandView nor Carrie Wise Tax Services are under common control, and Grandview is not compensated for referring clients to Carrie Wise Tax services for tax services. GrandView also subleases a portion of its office space to DeSantis Krupp, LLC, a law firm which provides legal services including trust and tax planning services. Grandview Asset Management LLC and DeSantis Krupp, LLC are not under common control, and GrandView is not compensated for referring clients to DeSantis Krupp, LLC for legal services. However, they the subtenants may share certain non-investment related expenses connected to their shared tenancy with GrandView. GrandView may recommend that clients in need of estate and tax planning utilize the services of Desantis Krupp, LLC and clients in need of tax services utilize Carrie Wise Tax Services, which may present a conflict of interest. GrandView attempts to mitigate this conflict by reminding clients they are under no obligation to engage the services of any such recommended professional. Additionally, clients retain absolute discretion in determining whether to engage Desantis Krupp, LLC or Carrie Wise Tax Services or any other professionals for tax or legal services and are free to accept or reject any recommendation from GrandView. Employees are also bound to the firm’s Code of Ethics, which requires employees to act in the best interests of clients. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. B. GrandView does not recommend to clients that they invest in any security in which GrandView or any principal thereof has any financial interest. C. On occasion, an employee of GrandView may purchase for his or her own account securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. D. On occasion, an employee of GrandView may purchase for his or her own account securities which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. x  Review of Accounts All accounts will be reviewed by a senior professional on at least a quarterly basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. The annual report in writing provided by GrandView is intended to review asset allocation. All clients will receive statements and confirmations of trades directly from Schwab. Please refer to Item 15 of the Information Brochure regarding Custody. Client Referrals and Other Compensation A. Other Products and Services Available to Us from Schwab. Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our 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 described below are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us as long as we keep a total of at least $10 million of the assets of our firm’s advisory clients in accounts at Schwab. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Here is a more detailed description of Schwab’s support services: Services that Benefit You. 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 this paragraph generally benefit you and your account. Services that May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both 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: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. • • provide pricing and other market data; • • Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events technology, compliance, legal, and business consulting; • • • publications and conferences on practice management and business succession; and xi  access to employee benefits providers, human capital consultants and insurance providers. • Schwab may provide some of these services itself. In other cases, it will 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. Our Interest in Schwab’s Services. The availability of the services described above (under the caption “Other Products and Services Available to Us from Schwab”) from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so long as we keep a total of at least $10 million of client assets in accounts at Schwab. In addition, Schwab has agreed to pay for up to $30,000 of certain marketing and technology products and services provided to us by third parties once the total of our clients’ assets maintained in accounts at Schwab reaches $150 million. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The $10 and $150 million minimums described above may give us an incentive to require that you maintain your account with Schwab based on our interest in receiving Schwab’s and services and Schwab’s payment for third party services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by the scope, quality and price of Schwab’s services and not Schwab’s services and Schwab’s payment for third party services that benefit only us. We have adopted policies and procedures designed to ensure, at account opening and thereafter, that our wrap fee program and our use of Schwab’s services is appropriate for each of our clients. B. Compensation to Non-Advisory Personnel for Client Referrals. GrandView does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Financial Information GrandView does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients. xii