GRANT PRIVATE WEALTH MANAGEMENT, INC.

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Office Address: 4683 Chabot Drive, Suite 101 Pleasanton, CA 94588 Tel: 925-378-5000 Fax: 925-378-2000 Grant@GrantPrivate.com Website: www.GrantPrivate.com June 5, 2025 This brochure provides information about the qualifications and business practices of Grant Private Wealth Management. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 925-378-5000. 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. Additional information about Grant Private Wealth Management (CRD # 292917) is available on the SEC’s website at www.adviserinfo.sec.gov 1 Grant Private Wealth Management  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material Material Changes since the Last Update changes occur since the previous release of the Firm Brochure. • Since the last filing on February 11, 2025, the following changes have occurred: Full Brochure Available The CETF designation has been added for Grant Ter-Avanesyan. This Firm Brochure being delivered is the complete brochure for the Firm. 2 Grant Private Wealth Management  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page .................................................................................... 1 disclosure brochure Annual Update .................................................................................................................................................................. 2 Material Changes since the Last Update................................................................................................................. 2 Full Brochure Available ................................................................................................................................................. 2 Firm Description .............................................................................................................................................................. 1 Types of Advisory Services .......................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions .............................................................................. 5 Wrap Fee Programs ........................................................................................................................................................ 5 Client Assets under Management ............................................................................................................................. 5 Method of Compensation and Fee Schedule ......................................................................................................... 5 Client Payment of Fees .................................................................................................................................................. 8 Additional Client Fees Charged .................................................................................................................................. 8 Prepayment of Client Fees ........................................................................................................................................... 8 External Compensation for the Sale of Securities to Clients .......................................................................... 8 Sharing of Capital Gains ................................................................................................................................................ 8 Description ......................................................................................................................................................................... 8 Account Minimums ......................................................................................................................................................... 9 Methods of Analysis ........................................................................................................................................................ 9 Investment Strategy ....................................................................................................................................................... 9 Security Specific Material Risks ............................................................................................................................... 10 Criminal or Civil Actions ............................................................................................................................................. 12 Administrative Enforcement Proceedings .......................................................................................................... 12 Self- Regulatory Organization Enforcement Proceedings ............................................................................ 12 Broker-Dealer or Representative Registration ................................................................................................. 12 Futures or Commodity Registration ...................................................................................................................... 12 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 13 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 13 Code of Ethics Description ......................................................................................................................................... 13 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 14 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 14 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 14 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 15 Aggregating Securities Transactions for Client Accounts ............................................................................. 17 3 Grant Private Wealth Management  Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 17 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 17 Content of Client Provided Reports and Frequency ........................................................................................ 17 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 17 Advisory Firm Payments for Client Referrals .................................................................................................... 18 Account Statements ...................................................................................................................................................... 18 Discretionary Authority for Trading...................................................................................................................... 18 Proxy Votes ...................................................................................................................................................................... 18 Balance Sheet .................................................................................................................................................................. 19 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 19 ..................................................................... 20 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 19 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 21 Supervised Person brochure Principal Executive Officer – Grant K. Ter-Avanesyan ................................................................................... 21 Item 2 - Educational Background and Business Experience ....................................................................... 21 Professional Certifications ......................................................................................................................................... 21 Item 3 - Disciplinary Information ........................................................................................................................... 23 Item 4 - Other Business Activities Engaged In ................................................................................................... 23 Item 5 - Additional Compensation .......................................................................................................................... 23 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 26 Item 6 - Supervision ..................................................................................................................................................... 23 Item 2 - Educational Background and Business Experience ....................................................................... 26 Item 3 - Disciplinary Information ........................................................................................................................... 26 Item 4 - Other Business Activities Engaged In ................................................................................................... 26 Item 5 - Additional Compensation .......................................................................................................................... 26 Item 6 - Supervision ..................................................................................................................................................... 26 4 Grant Private Wealth Management  Item 4: Advisory Business Firm Description Grant Private Wealth Management, Inc. doing business as Grant Private Wealth Management (“GPWM”) was founded in 2018. Grant K. Ter-Avanesyan is 50% owner and Lyudmila Ter- Avanesyan is 50% owner. GPWM is a fee-based investment management firm. GPWM does not sell annuities or insurance products, but the President offers insurance through an affiliated entity. GPWM does not act as a custodian of Client assets. An evaluation of each Client's initial situation is provided to the Client, often in the form of a net worth statement, risk analysis or similar document. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the Client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the Client on an as-needed basis and may charge fees of their own. Types of Advisory Services Conflicts of interest will be disclosed to the Client in the event they should occur. ASSET MANAGEMENT GPWM offers discretionary and non-discretionary asset management services to advisory Clients. GPWM will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. The Client will authorize GPWM discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Discretionary When the Client provides GPWM discretionary authority the Client will sign a limited trading authorization or equivalent. GPWM will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-discretionary When the Client elects to use GPWM on a non-discretionary basis, GPWM will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, GPWM will obtain prior Client approval on each and every transaction before executing any transaction. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, GPWM offers the packages below. The client will compensate GPWM on an hourly or ongoing basis described in detail under “Fees and Compensation” section of this brochure. One-time financial plan: • Services for one-time consultations include but are not limited to: • • • 401(k) Asset Allocation Assistance Benefits and Social Security Estate Preservation Insurance Evaluation - 1 - Grant Private Wealth Management  • • • • • • • • • • • • • • Business Succession Planning Charitable Planning Company Stock Option Analysis Debt Management Deferred Compensation Defined Benefit Plans Education Planning Life Events Long-Term Care Planning for the Support of Parents/Relatives Retirement Planning Tax Planning Strategies Trust Plan Review Wealth Transfer Financial plans will be completed and delivered inside of ninety (90) days dependent upon timely client delivery of required documentation. Clients may terminate advisory services with thirty (30) days written or verbal notice. Services offered for Hourly Consultation • • • • • • • • • • • • • • • This is not a detailed financial review and will not result in an extensive financial plan. A written summary upon request (additional fees may apply). • Appropriate topics for discussion include, but are not limited to: • • • • • • • • • • • • Emergency, Retirement and Goal savings Estate preservation needs Insurance Evaluation Life Events Long-Term Care Planning for the Support of Parents/Relatives Retirement Planning Reviewing your benefits Risk Management Tax Planning Strategies Trust Plan Review Wealth Transfer 401(k) Asset Allocation Assistance Asset Allocation Benefits and Social Security Big Purchase Planning Business Succession Planning Cash Flow and Spending Management Charitable Planning Company Stock Option Analysis Debt Management Debt Repayment Deferred Compensation Defined Benefit Plans Education Planning On-going services: When ongoing services are required GPWM will provide services to help the client clearly identify goals, set a framework for success, and ensure that you have an accountability partner to help keep you on track to a successful financial future. • Clients that participate in the on-going services program can expect the following: • • • A 90-minute meeting in person, via telephone or online interface such as Skype or FaceTime to determine financial goals and values, what the client’s current financial picture looks like (including assets, debts, income and spending), and what current limitations or hurdles the client may be facing. A 90-minute meeting to deliver financial planning recommendations, action items, and a prioritized “to-do” list. A 60-minute check-in phone call within one month of recommendation delivery. Ongoing check-ins via phone, email or in person meeting for accountability, encouragement and to address changes along the way. - 2 - Grant Private Wealth Management  • • • • • • • • • • • • Topics, areas and issues addressing your analysis and recommendations may include the • following: • • • • • • • • • • • • Emergency, Retirement and Goal savings Estate preservation needs Insurance Evaluation Life Events Long-Term Care Planning for the Support of Parents/Relatives Retirement Planning Reviewing your benefits Risk Management Tax Planning Strategies Trust Plan Review Wealth Transfer 401(k) Asset Allocation Assistance Asset Allocation Benefits and Social Security Big Purchase Planning Business Succession Planning Cash Flow and Spending Management Charitable Planning Company Stock Option Analysis Debt Management Debt Repayment Deferred Compensation Defined Benefit Plans Education Planning Under California Code of Regulations, 10 CCR Section 260.235.2, it requires that the conflict of interest, which exists between the interests of the investment advisor and the interests of the client when offering financial planning services, be disclosed. The client is under no obligation to act upon the investment advisor’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through GPWM. ERISA PLAN SERVICES GPWM provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. Limited Scope ERISA 3(21) Fiduciary. GPWM may act as a 3(21) advisor: GPWM may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor GPWM has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using GPWM can help the plan sponsor delegate liability by following a diligent process. 1. • Fiduciary Services are: • Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. GPWM acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are - 3 - Grant Private Wealth Management  • automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. • Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. • Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands GPWM’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, GPWM is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. GPWM will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. GPWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between GPWM and Client. 3. GPWM has no responsibility to provide services related to the following types of assets • (“Excluded Assets”): • Employer securities; • Real estate (except for real estate funds or publicly traded REITs); • Stock brokerage accounts or mutual fund windows; • Participant loans; • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or not Other hard-to-value or illiquid securities or property. be included in calculation of Fees paid to GPWM on the ERISA Excluded Assets will Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. SEMINARS AND WORKSHOPS GPWM holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and - 4 - Grant Private Wealth Management  Client Tailored Services and Client Imposed Restrictions no specific investment or tax advice is given. The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be Wrap Fee Programs assigned without written Client consent. Client Assets under Management GPWM does not sponsor any wrap fee programs. GPWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $133,883,000 $0 Date Calculated: December 31, 2024 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT GPWM offers direct asset management services to advisory Clients. GPWM charges an annual investment advisory fee based on the total assets under management as follows: Portfolio Value For Fixed Income only* Fee for Asset Allocation Equity/Blended The first $0 - $999,999 Next $1,000,000 - $2,999,999 Next $3,000,000 - $4,999,999 Next $5,000,000 - $9,999,999 Next $10,000,000 - And above 1.50% 1.30% 1.20% 1.10% Negotiable 1.00% 0.90% 0.80% 0.70% Negotiable *GPWM recommends that Clients with a Fixed Income only allocation have minimum investment proceeds of $250,000. This is a blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. GPWM may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example, a Client with $2,475,000 under management with an equity/blended allocation would pay $34,175 on an annual basis. First $999,999 x .0150 = $15,000 Next $1,475,001 x .0130= $19,175 The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous quarter. If cash and/or - 5 - Grant Private Wealth Management  securities are deposited into or withdrawn from an existing account mid billing period a prorated fee will be charged for that portion. If margin is utilized, the fees will be billed based on the net asset value of the account. Lower fees for comparable services may be available from other sources. For accounts opened or closed mid-billing period, any unpaid earned fees will be due to GPWM. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30) days written notice. • Clients can choose to pay for assets under management fee via the following methods: • Check – to be remitted by Client to GPWM Directly deducted from Client’s accounts by the custodian on behalf of GPWM For fees that are directly deducted from the account by the custodian: • GPWM will provide the Client with an invoice concurrent to instructing the custodian to deduct the fee stating the amount of the fee, the formula used to calculate the fee, the amount of assets under management the fee is based on and the time period covered by the fee; • GPWM will obtain written authorization signed by the Client allowing the fees to be deducted; and • The Client will receive quarterly statements directly from the custodian which disclose the fees deducted FINANCIAL PLANNING AND CONSULTING Various financial planning services are offered based on a negotiable fixed fee or hourly basis as described in detail below depending on planning service selected, the prior relationship, number of goals and complexity of the plan such as the number of investments held, types of investments and number of areas reviewed. Prior to the planning process the client will be provided the estimated plan fee. Lower fees for comparable services may be available from other sources. One-time financial plan Financial Planning Services are offered based either for an hourly fee of $250 per hour or for a flat fee between $1,500 and $15,000. Services for financial plans are completed and delivered inside of ninety (90) days, contingent upon timely delivery of all required documents. Fees for financial plans are due upon delivery of the completed plan. Hourly Consultation $250 per hour For clients who desire a single meeting that focuses on a particular financial issue. • • • A written summary will be sent to you after the meeting for an additional $125. This is not a detailed financial review and will not result in an extensive financial plan. Topics of discussion may include: - 6 - Grant Private Wealth Management  Type of Service Est. completion time Written summary of meeting ............................................................................. 30 - 45 minutes Employee retirement investment choices (401k, PERS, 403b etc.) ..... 45 minutes to one hour College Savings Strategies .................................................................................... 45 minutes to one hour Debt Management .................................................................................................... 1 – 1 ½ hours Basic Retirement Forecasting ............................................................................. 1 – 1 ½ hours Other ............................................................................................................................. 1 – 2 hours Services are completed and delivered inside of ninety (90) days, contingent upon timely delivery of all required documents. Fees for hourly consultations are due upon delivery of the completed services. Ongoing consultation GPWM will charge an annual fee of no more than $10,000 for ongoing consulting services. Fees will be due quarterly in equal installments; the first payment will be due at the end of the first quarter and will be invoiced accordingly. Services for the first quarter will be prorated for the amount of time actually spent providing services. For example, if the cost of services is going to be $10,000 annually and services start on March 1 the first payment would be $833.33 at the end of March. Subsequent payments would be $2,500 at the end of each quarter. Services to be provided and the anticipated fee range are detailed in the written Financial Planning Agreement. Services will continue from year to year unless cancelled in writing by either party. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GPWM. GPWM reserves the right to waive the fee should the Client implement the plan through GPWM. ERISA PLAN SERVICES The annual fees are based on the market value of the Included Assets and will not exceed .90%. The annual fee is negotiable. Fees may be charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any time other than the first day of a quarter or month, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, GPWM shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the billing cycle. The fee schedule, which includes compensation of GPWM for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. GPWM does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, GPWM will disclose this compensation, the services rendered, and the payer of compensation. GPWM will offset the compensation against the fees agreed upon under this Agreement. - 7 - Grant Private Wealth Management  SEMINARS AND WORKSHOPS Client Payment of Fees GPWM does not charge a fee for attendance to these seminars. Investment management fees are billed quarterly in arrears, meaning that we invoice you after the billing period. Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans are due upon delivery of the completed plan. GPWM, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of Additional Client Fees Charged assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling, margin interest and miscellaneous fees. For more details on the Prepayment of Client Fees brokerage practices, see Item 12 of this brochure. GPWM does not require any prepayment of fees of more than $1,200 per Client and six months or more in advance. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to GPWM. External Compensation for the Sale of Securities to Clients Fees for ERISA 3(21) services may be billed in advance. GPWM does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of GPWM. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. GPWM does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for GPWM to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description GPWM generally provides investment advice to individuals, high net worth individuals, trusts, estates, or corporations or business entities. Client relationships vary in scope and length of service. - 8 - Grant Private Wealth Management  Account Minimums GPWM does not require a minimum to open an account. However, GPWM recommends that Clients with a Fixed Income only allocation have minimum investment proceeds of $250,000. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis, charting, and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. In developing a financial plan for a Client, GPWM’s analysis may include cash flow analysis, investment planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. The main sources of information include financial newspapers and magazines, annual Investment Strategy reports, prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to GPWM. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases, short-term purchases, and trading on margin. - 9 - Grant Private Wealth Management  Security Specific Material Risks • Market Risk All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with GPWM: • : The prices of securities held by mutual funds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to Interest-rate Risk tolerate potentially sharp declines in market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less Inflation Risk attractive, causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than • Currency Risk a dollar next year, because purchasing power is eroding at the rate of inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Fixed Income Risk: 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. 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 - 10 - Grant Private Wealth Management  • because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal Investment Companies Risk: interest rate is the sum of a real interest rate and an expected inflation rate. • Derivatives Risk: When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Foreign Securities Risk: Funds in a Client’s portfolio may use derivative instruments. The value of these derivative instruments derives from the value of an underlying asset, currency or index. Investments by a fund in such underlying funds may involve the risk that the value of the underlying fund’s derivatives may rise or fall more rapidly than other investments, and the risk that an underlying fund may lose more than the amount that it invested in the derivative instrument in the first place. Derivative instruments also involve the risk that other parties to the derivative contract may fail to meet their obligations, which could cause losses. • Long-term purchases Funds in which Clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Short-term purchases : Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. : Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles - 11 - Grant Private Wealth Management  • Trading risk may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. : Investing involves risk, including possible loss of principal. There is no • Trading on Margin: assurance that the investment objective of any fund or investment will be achieved. • Leveraged Risk In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the Client will be required to deposit additional cash or make full payment of the margin loan to bring account back up to maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought in by the brokerage firm. : The risks involved with using leverage may include compounding of returns (this works both ways – positive and negative), possible reset periods, volatility, use of derivatives, active trading and high expenses. • The specific risks associated with financial planning include: o Risk of Loss o lifestyle and therefore plan Client fails to follow the recommendations of GPWM resulting in loss Client has changes in financial status or recommendations are no longer valid. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings GPWM and its management have not been involved in any criminal or civil action. GPWM and its management have not been involved in administrative enforcement Self- Regulatory Organization Enforcement Proceedings proceedings. GPWM and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of GPWM or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration GPWM is not registered as a broker- dealer and no affiliated representatives of GPWM are Futures or Commodity Registration registered representatives of a broker-dealer. Neither GPWM nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. - 12 - Grant Private Wealth Management  Material Relationships Maintained by this Advisory Business and Conflicts of Interest President, Grant K. Ter-Avanesyan, is also a licensed insurance agent. Approximately 10% of Grant K. Ter-Avanesyan’s time is spent in this practice. He will offer Clients services from this activity. As an insurance agent, he may receive separate yet typical compensation. In addition to his activity as an insurance agent, Grant K. Ter-Avanesyan may receive referral fees for recommending Oli Insurance Services, Inc. for Property and Casualty, Annuity and/or life insurance to Clients or Prospects. Grant K. Ter-Avanesyan may also receive referral fees for referring clients of GPWM to providers for mortgage, real estate, estate planning and accounting services. Approximately 5% of his time is spent on this activity. These practices represent a conflict of interest because it gives an incentive to recommend products or services based on the compensation amount received. This conflict is mitigated disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products or services. Clients have the option to purchase these products or services through another insurance agent or insurance company of their choosing. In addition, Grant K. Ter-Avanesyan Is the owner of Leo Development a real estate development company. Through Leo Development, Grant K. Ter-Avanesyan owns GrandCo LLC which is also a real estate development company. Clients of GPWM will not be offered services from either of these real estate development companies, therefore, there is no Recommendations or Selections of Other Investment Advisors and Conflicts of conflict of interest. Interest GPWM does not select or recommend other investment advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or independent The affiliated persons (affiliated persons contractors) of GPWM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of GPWM affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of GPWM. The Code reflects GPWM and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. GPWM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of GPWM may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. - 13 - Grant Private Wealth Management  GPWM’s Code is based on the guiding principle that the interests of the Client are our top priority. GPWM’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. GPWM will provide a copy of the Code of Ethics to any Investment Recommendations Involving a Material Financial Interest and Conflict of Client or prospective Client upon request. Interest GPWM and its affiliated persons do not recommend to Clients securities in which we have a Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of material financial interest. Interest GPWM and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide GPWM with copies of their brokerage statements. The Chief Compliance Officer of GPWM is Grant Ter-Avanesyan. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive Client Securities Recommendations or Trades and Concurrent Advisory Firm preferential treatment over associated persons’ transactions. Securities Transactions and Conflicts of Interest GPWM does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide GPWM with copies of their brokerage statements. The Chief Compliance Officer of GPWM is Grant Ter-Avanesyan. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. - 14 - Grant Private Wealth Management  Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions • Directed Brokerage 1 ("Schwab"), a FINRA GPWM recommends that clients establish brokerage accounts with the Schwab 2 Institutional division of Charles Schwab & Co., Inc. registered 3 broker-dealer and SIPC member, to maintain custody of clients’ assets and to effect trades for their accounts. GPWM is independently owned and operated and not affiliated with Schwab. GPWM has evaluated Schwab and believes that it will provide our clients with a blend of execution services, commission costs and professionalism that will assist our firm in meeting our fiduciary obligations to clients. Schwab provides GPWM with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Institutional. These services are not contingent upon our firm committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to our firm other products and services that benefit GPWM but may not directly benefit our clients’ accounts. Many of these products and services may be used to service all or some substantial number of our client accounts, including accounts not maintained at Schwab. • Schwab’s products and services that assist us in managing and administering our clients’ accounts include software and other technology that: • • • • provide access to client account data (such as trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; provide research, pricing and other market data; facilitate payment of our fees from clients’ accounts; and assist with back-office functions, recordkeeping and client reporting. • Schwab Institutional also offers other services intended to help us manage and further develop our business enterprise. These services may include: compliance, legal and business consulting; 1 2 For information regarding Schwab, please refer to their website: https://www.schwab.com/. FINRA is the largest independent regulator for all securities firms doing business in the United States. For more information, please refer to FINRA’s website: http://www.finra.org/. 3 For information regarding SIPC, please refer to their website: http://www.sipc.org/. - 15 - Grant Private Wealth Management  • • publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to GPWM. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to our firm. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend or require that clients custody their assets at Schwab, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. • Limited Brokerage Discretion We reserve the right to decline acceptance of any client account for which the client directs the use of a broker other than Schwab if we believe that this choice would hinder our fiduciary duty to the client and/or our ability to service the account. In directing the use of Schwab (or any other broker), it should be understood that GPWM will not have authority to negotiate commissions or to necessarily obtain volume discounts, and best execution may not be achieved. In addition, a disparity in commission charges may exist between the commissions charged to the client and those charged to other clients (who may direct the use of another broker other than Schwab). Clients should note that, while GPWM has a reasonable belief that Schwab is able to obtain best execution and competitive prices, our firm will not independently seek best execution price capability through other brokers. GPWM may, however, request that it be provided written authority to determine the broker-dealer to be used for the purchase or sale of certain fixed income securities for the client’s account and the costs that will be incurred by the client for these transactions. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as desired. Such amendments shall also be in writing. • Best Execution When GPWM exercises this limited brokerage discretion in order to purchase or sell such securities, GPWM will select those broker-dealers that will provide quality services at competitive transaction costs. The reasonableness of brokerage costs, commissions and mark ups/mark downs is based on the broker-dealer's ability to provide professional services, competitive execution and other services that will assist GPWM in providing investment management services to clients. Client trades in these instruments may be blocked with transactions for other advisory clients to achieve better pricing and commission costs. Investment advisors who manage or supervise client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the - 16 - Grant Private Wealth Management  • Soft Dollar Arrangements transaction is effected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by GPWM from or through a broker-dealer in exchange for directing client transactions to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, GPWM receives economic benefits as a result of commissions generated from securities transactions by the broker-dealer from the accounts of GPWM. These benefits include both proprietary research from the broker and other research written by third parties. Aggregating Securities Transactions for Client Accounts A conflict of interest exists when GPWM receives soft dollars. This conflict is mitigated by disclosures, procedures, and by the fact that GPWM has a fiduciary responsibility to act in the best interest of its clients and the services received are beneficial to all clients. GPWM is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of GPWM. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Officer of GPWM. Account reviews are performed more frequently when market conditions dictate. Financial plans generated are updated as requested by the Client and pursuant to a new or amended Review of Client Accounts on Non-Periodic Basis agreement, GPWM suggests updating at least annually. Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, Content of Client Provided Reports and Frequency new investment information, and changes in a Client's own situation. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by GPWM’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their - 17 - Grant Private Wealth Management  clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability to us of Schwab’s products and services is not based on us giving particular Advisory Firm Payments for Client Referrals investment advice, such as buying particular securities for our clients. GPWM does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by GPWM. GPWM is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of GPWM. Item 16: Investment Discretion Discretionary Authority for Trading GPWM may require discretionary authority to manage securities accounts on behalf of Clients. GPWM has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize GPWM discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. GPWM allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to GPWM in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. GPWM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes GPWM does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, GPWM will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. - 18 - Grant Private Wealth Management  Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because GPWM does not serve as a custodian for Client funds or securities and GPWM does not require prepayment of fees of more than Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet $1,200 per Client and six months or more in advance. Commitments to Clients GPWM has no condition that is reasonably likely to impair our ability to meet contractual Bankruptcy Petitions during the Past Ten Years commitments to our Clients. GPWM has not had any bankruptcy petitions in the last ten years. - 19 - Grant Private Wealth Management  S U P E R V I S E D P E R S O N B R O C H U RE Item 1 Cover Page F O R M A D V P A R T 2 B Grant K. Ter-Avanesyan Office Address: 4683 Chabot Drive, Suite 101 Pleasanton, CA 94588 Tel: 925-378-5000 Fax: 925-378-2000 Grant@GrantPrivate.com Website: www.GrantPrivate.com June 5, 2025 This brochure supplement provides information about Grant K. Ter-Avanesyan and supplements the Grant Private Wealth Management’s brochure. You should have received a copy of that brochure. Please contact Grant K. Ter-Avanesyan if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Grant K. Ter-Avanesyan (CRD #5414528) is available on the SEC’s website at www.adviserinfo.sec.gov. - 20 - Grant Private Wealth Management  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Grant K. Ter-Avanesyan • Item 2 - Educational Background and Business Experience Year of birth: 1985 • Educational Background: • Westminster College; Bachelor of Business Administration; 05/2015 Cannon Financial Institute; Estate Planning; 2016 Position Held From Date To Date Name of Firm or Company Business Experience: 04/2022 PRESENT Leo Development Managing Member 08/2021 PRESENT Glava Realty Agent 09/2020 PRESENT Grant K. Ter-Avanesyan Consultant 03/2018 PRESENT Grant Private Wealth Management, Inc. CFO/Investment Advisor Representative 02/2018 PRESENT Grant K. Ter-Avanesyan Insurance Agent 11/2017 PRESENT Owner IHSS In Home Supportive Services 03/2017 09/2023 Owner/Landlord Grant K. Ter-Avanesyan Properties 07/2007 02/2018 Financial Representative Fidelity Brokerage Services, LLC 02/2018 Strategic Advisers Inc. 07/2007 Professional Certifications Investment Advisor Representative Employees have earned certifications and credentials that are required to be explained in further detail. ® , CFP ® and federally registered CFP (with flame marks”) are professional certification marks granted ™ The CERTIFIED FINANCIAL PLANNER design) marks (collectively, the “CFP in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). ® ® certification is a voluntary certification; no federal or state law or regulation The CFP requires financial planners to hold CFP certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with Clients. ® marks, an individual must satisfactorily fulfill the To attain the right to use the CFP following requirements: - 21 - Grant Private Wealth Management  • • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; ® • Examination – Pass the comprehensive CFP Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and Client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Standards of Professional Conduct • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and , a set of ® Ethics – Agree to be bound by CFP Board’s documents outlining the ethical and practice standards for CFP professionals. ® • marks: Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP Standards of Code of Ethics Continuing Education – Complete 30 hours of continuing education hours every two Professional Conduct years, including two hours on the and other parts of the , to maintain competence and keep up with developments in the Standards of Professional Conduct. • financial planning field; and Standards ® professionals provide financial professionals must Ethics – Renew an agreement to be bound by the ® The prominently require that CFP planning services at a fiduciary standard of care. This means CFP provide financial planning services in the best interests of their Clients. ® ® certification. CFP professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP ® ® ) Issued by The ETF Institute. The CETF • Prerequisites - Certified ETF Advisor (CETF designation is awarded by the first and only independent organization dedicated to providing certification, education, and training specifically for professionals in the exchange-traded fund (ETF) industry. The ETF Institute created this designation to establish a recognized industry standard, helping financial professionals deepen their ETF knowledge, advance their careers, and better serve investors. • Education Requirements - None • Examination Requirements Online self-study course Comprehensive online exam administered by The ETF Institute o o o 150 multiple-choice questions Three-hour time limit - 22 - Grant Private Wealth Management  o o Minimum passing score: 70% • Continuing Education Requirements - Exam topics include: ETF creation and redemption process, advantages and disadvantages of ETFs, ETF structures (e.g., Open-End Funds, Unit Investment Trusts, Grantor Trusts), futures-based, leveraged, and inverse ETFs, and best ETF trading practices Item 3 - Disciplinary Information 15 hours every two years None to report in the last 10 years. Criminal or Civil Action: Administrative Proceeding: Self-Regulatory Proceeding: Item 4 - Other Business Activities Engaged In None to report in the last 10 years. None to report in the last 10 years. President, Grant K. Ter-Avanesyan, is also a licensed insurance agent. Approximately 10% of Grant K. Ter-Avanesyan’s time is spent in this practice. He will offer Clients services from this activity. As an insurance agent, he may receive separate yet typical compensation. In addition to his activity as an insurance agent, Grant K. Ter-Avanesyan may receive referral fees for recommending Oli Insurance Services, Inc. for Property and Casualty, Annuity and/or life insurance to Clients or Prospects. Grant K. Ter-Avanesyan may also receive referral fees for referring clients of GPWM to providers for mortgage, real estate, estate planning and accounting services. Approximately 5% of his time is spent on this activity. These practices represent a conflict of interest because it gives an incentive to recommend products or services based on the compensation amount received. This conflict is mitigated disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products or services. Clients have the option to purchase these products or services through another insurance agent or insurance company of their choosing. In addition, Grant K. Ter-Avanesyan Is the owner of Leo Development a real estate development company. Through Leo Development, Grant K. Ter-Avanesyan owns GrandCo LLC which is also a real estate development company. Clients of GPWM will not be offered services from either of these real estate development companies, therefore, there is no Item 5 - Additional Compensation conflict of interest. Grant K. Ter-Avanesyan does not receive compensation for advisory services beyond what has been disclosed in the ADV 2A. He receives commissions on the insurance products he Item 6 - Supervision sells. He does not receive any performance-based fees. Grant K. Ter-Avanesyan is the Chief Compliance Officer, Chief Financial Officer, and owner of Grant Private Wealth Management; therefore, he is responsible for supervision, formulation and monitoring of investment advice offered to clients. He will adhere to the policies and procedures as describe in the firm’s Compliance Manual. - 23 - Grant Private Wealth Management  He can be contacted by telephone at 925-378-5000 or via email at Grant@GrantPrivate.com. - 24 - Grant Private Wealth Management  S U P E R V I S E D P E R S O N B R O C H U RE I T E M 1 C O V E R P A G E F O R M A D V P A R T 2 B Lyudmila Ter-Avanesyan Office Address: 4683 Chabot Drive, Suite 101 Pleasanton, CA 94588 Tel: 925-378-5000 Fax: 925-378-2000 info@GrantPrivate.com Website: www.GrantPrivate.com June 5, 2025 This brochure supplement provides information about Lyudmila Ter-Avanesyan and supplements the Grant Private Wealth Management brochure. You should have received a copy of that brochure. Please contact Lyudmila Ter-Avanesyan if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Lyudmila Ter-Avanesyan (CRD # 6123243) is available on the SEC’s website at www.adviserinfo.sec.gov. - 25 - Grant Private Wealth Management  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure – Lyudmila Ter-Avanesyan • Item 2 - Educational Background and Business Experience Year of birth: 1985 • Educational Background: University of Buffalo; Business Administration; 2008 Position Held From Date To Date Name of Firm or Company Business Experience: 08/2021 PRESENT Glava Realty Agent 03/2018 PRESENT Grant Private Wealth Management, Inc. Investment Advisor Representative 03/2017 PRESENT Lyudmila Ter-Avanesyan Owner/Landlord Item 3 - Disciplinary Information 09/2011 02/2018 Fidelity Brokerage Services, LLC Registered Representative None to report in the last 10 years. Criminal or Civil Action: Administrative Proceeding: Self-Regulatory Proceeding: Item 4 - Other Business Activities Engaged In None to report in the last 10 years. None to report in the last 10 years. Lyudmila Ter-Avanesyan does not maintain other business activities that would result in a Item 5 - Additional Compensation conflict of interest. Lyudmila Ter-Avanesyan does not receive any performance-based fees. Lyudmila Ter-Avanesyan does not receive compensation for advisory services beyond what Item 6 - Supervision has been disclosed in the ADV 2A. Lyudmila Ter-Avanesyan is the Chief Operations Officer and owner of Grant Private Wealth Management; therefore, she is responsible for supervision, formulation and monitoring of investment advice offered to clients. She will adhere to the policies and procedures as described in the firm’s Compliance Manual. She can be reached by telephone at 925-378-5000 or via email at Info@GrantPrivate.com. - 26 - Grant Private Wealth Management