GRATTAN FINANCIAL STRATEGIES, INC.

Item 1. Cover Page Form ADV Part 2A Last Updated: December 31st, 2025 Grattan Financial Strategies, Inc. SEC File Number: 801- 55656 CRD Number: 108449 8814 Huntington Drive San Gabriel, California 91775-1271 Main Tel (626) 451-0840 Toll Free (800) 450-0840 This brochure provides information about the qualifications and business practices of Grattan Financial Strategies, Inc. (“GFS”). If you have any questions about the contents of this brochure, please contact Daniel Grattan at (800) 450-0840 and/or via email at grattan@bbgrahamco.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. Additional information about GFS is also available on the SEC’s website at www.adviserinfo.sec.gov. Although GFS may use the term “registered investment adviser” or use the term “registered” through this Form ADV Part 2A, the use of these terms is not intended to imply a certain level of skill or training. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 1 of 17 ver. 12312025  Item 2. Material Changes since Last Update Material Changes since last update/amendment The Material Changes section of this brochure will be updated annually and/or when material changes occur since the previous release of GFS’ Brochure. A summary of changes is necessary to inform clients of any substantive changes to GFS’ policies, practices, or conflicts of interests so that they can determine whether to review the brochure in its entirety or to contact GFS with questions about the changes. Material Changes since last update on September 30th, 2025: None Full Brochure Available Clients who would like to receive a complete copy of our Firm Brochure, please contact us by telephone at (800) 450-0840 Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 2 of 17 ver. 12312025  Item 3. Table of Contents Form ADV Part 2A ITEM 1. COVER PAGE ....................................................................................................................................... 1 ITEM 2. MATERIAL CHANGES SINCE LAST UPDATE ................................................................................ 2 ANNUAL UPDATE/MATERIAL CHANGES ............................................................................................................................ 2 FULL BROCHURE AVAILABLE ............................................................................................................................................ 2 ITEM 4. ADVISORY BUSINESS ........................................................................................................................ 5 PRINCIPAL OWNERS ....................................................................................................................................................... 5 TYPES OF ADVISORY SERVICES OFFERED ............................................................................................................................ 5 INVESTMENT MANAGEMENT SERVICES.............................................................................................................................. 5 HOURLY CONSULTATION SERVICES ................................................................................................................................... 6 FINANCIAL PLANNING SERVICES ....................................................................................................................................... 6 TERMINATION OF ACCOUNT ............................................................................................................................................ 6 WRAP FEE PROGRAM .................................................................................................................................................... 7 ASSETS UNDER MANAGEMENT ........................................................................................................................................ 7 ITEM 5. FEES AND COMPENSATION ............................................................................................................. 7 INVESTMENT MANAGEMENT FEES ........................................................................................................................... 7 FINANCIAL PLANNING FEES ..................................................................................................................................... 7 HOURLY CONSULTING FEES .................................................................................................................................... 8 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ........................................ 8 ITEM 7. TYPES OF CLIENTS ............................................................................................................................ 9 REQUIREMENT FOR OPENING ACCOUNTS (MINIMUM INVESTMENT AMOUNT) ........................................................................ 9 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .......................... 9 METHODS OF ANALYSIS .................................................................................................................................................. 9 USE OF SIGNIFICANT INVESTMENT STRATEGY ..................................................................................................................... 9 EQUITY RISKS ............................................................................................................................................................. 10 FIXED INCOME RISKS .................................................................................................................................................... 10 ETF RISKS .................................................................................................................................................................. 11 ITEM 9. DISCIPLINARY INFORMATION ....................................................................................................... 12 DISCLOSURE EVENTS .................................................................................................................................................... 12 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................... 12 BROKER/DEALER AFFILIATION ....................................................................................................................................... 12 INSURANCE PRODUCTS ................................................................................................................................................. 13 SELECTION OF OTHER INVESTMENT ADVISERS .................................................................................................... 13 DISCLOSURE OF MATERIAL CONFLICTS ................................................................................................................ 13 ITEM 11. CODE OF ETHICS, PARTICIPATION/INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..................................................................................................................................... 13 CODE OF ETHICS .......................................................................................................................................................... 13 PARTICIPATION/INTEREST IN CLIENT TRANSACTIONS .......................................................................................... 14 ITEM 12. BROKERAGE PRACTICES ............................................................................................................ 15 RESEARCH AND OTHER SOFT DOLLAR BENEFITS ................................................................................................ 15 Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 3 of 17 ver. 12312025  BROKERAGE FOR CLIENT REFERRALS ............................................................................................................................... 15 DIRECTED BROKERAGE ................................................................................................................................................. 15 AGGREGATION OF CLIENT ORDERS ................................................................................................................................. 15 ITEM 13. REVIEW OF ACCOUNTS ................................................................................................................ 15 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION .............................................................. 16 RECEIPT OF ECONOMIC BENEFIT (NON-CLIENT) ................................................................................................................. 16 DIRECT/INDIRECT COMPENSATION FOR CLIENT REFERRALS ................................................................................................. 16 ITEM 15. CUSTODY ......................................................................................................................................... 16 ITEM 16. INVESTMENT DISCRETION ........................................................................................................... 16 ITEM 17. VOTING CLIENT SECURITIES ....................................................................................................... 16 ITEM 18. FINANCIAL INFORMATION ............................................................................................................ 17 PRE-PAYMENT OF FEES ................................................................................................................................................ 17 MATERIAL IMPACT OF DISCRETIONARY AUTHORITY ........................................................................................................... 17 CUSTODY DISCLOSURE.................................................................................................................................................. 17 BANKRUPTCY DISCLOSURE ............................................................................................................................................ 17 PRIVACY POLICY ............................................................................................................................................ 17 PRIVACY POLICY NOTICE ............................................................................................................................................... 17 Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 4 of 17 ver. 12312025  Item 4. Advisory Business Grattan Financial Strategies, Inc. (“GFS”) is a privately owned registered investment adviser firm incorporated in the state of California in December 1989, providing investment advisory and financial planning services to individuals, high net worth individuals, pension and profit-sharing plans including 401-K plans, trusts, estates, and charitable organizations, and corporations and other business entities (e.g. partnerships) (herein referred to as “Client” or “Clients”). Principal Owners For the purpose of this section, GFS lists its principal owners as any person directly owning 25% or more of GFS as disclosed on Schedule A of Part 1A as of date of the last update filing. GFS’ principal owners are as follows: • Georgene M. Grattan is a direct owner of GFS with 51% ownership; Chris M. Grattan is 25% shareholder in GFS; and Daniel V. Grattan is 24% shareholder in GFS. Georgene M. Grattan Name: Date of Birth: 8/16/1939 Education: University of Detroit 1957-1961, Accounting and Marketing, Sienna Heights College (MBA) Masters Business administration, College of Financial Planning, Certified Financial Planner (CFP) 1961 Background: Grattan Financial Strategies, Inc.; Chairperson of the Board (10/1989-present) B.B Graham & Company; Registered Representative (08/2004-present) Chris M. Grattan Faith Tech: Ministry, Pasadena City College, Investment Management (1/15/1997) Name: Date of Birth: 12/20/1964 Education: Background: Grattan Financial Strategies, Inc. Executive V.P. & Senior Portfolio Manager (11/15/1991-Present) B.B. Graham & company Registered Representative (08/2024-Present) Daniel V. Grattan Oakland University, Business Management (Economics & Finance) (1979-1983) Name: Date of Birth: 3/13/1961 Education: Background: Grattan Financial Strategies, Inc.; Chief Information Officer/CCO (09/1999-present) B.B Graham & Company; Registered Representative (08/2004-present) GFS is not a publicly held company and no part of GFS is owned by an individual or company through any subsidiaries or “intermediate subsidiaries.” Types of Advisory Services Offered Investment Management Services GFS offers discretionary and non-discretionary investment advisory services to its clients. GFS’ investment advice is tailored to meet its clients' needs and investment objectives. If you retain GFS for investment advisory services , GFS will review each client’s financial circumstances to determine their investment goals, investment objectives, risk tolerance, time horizon, and other relevant information at the beginning of our advisory relationship. GFS will use the information it gathered to develop a strategy that Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 5 of 17 ver. 12312025  enables GFS to give the client tailored investment advice and/or to make investments on the client’s behalf. Most positions in client accounts are considered long-term investments and are monitored on an ongoing basis by GFS (see Item 13 Review of Accounts for further details). GFS’ advisory services to clients primarily focuses on the following investment vehicles: (i) equity securities: exchange-listed securities, securities traded over-the-counter; (ii) corporate debt securities (0ther than commercial paper), Certifications of deposit, Municipal securities; (iii) investment company securities: life insurance, variable annuities, mutual fund shares; and (iv) United States government securities. GFS provides discretionary investment advisory services primarily with respect to the purchase and sale of No-Load Mutual Funds and Load-Waived Mutual funds, as well as the sale of previously purchased Load Mutual Funds, while transactions in other securities may be effected at the client’s direction. When GFS recommends mutual funds to clients, no-load funds will be recommended. If mutual fund A shares (i.e., shares with a front-end load) are purchased in a client’s account, they are purchased at Net asset value (NAV) which is the difference between a company’s assets and its liabilities which is determined by subtracting its liabilities from its assets at the end of each business day. GFS does not engage in the sale of Option Contracts, Future Contracts, or Interests in Limited Partnerships. Hourly Consultation Services In addition to offering investment management and financial planning services, GFS may also offer general consulting services on an hourly basis. For consultation services as provided by GFS, Client may agree to pay GFS an hourly fee of $500.00 per hour. This hourly consultation service may take the form of general consulting and/or general investment advice for individuals and/or institutions. It may also take the form of investment advice for individuals or institutions that do not meet the minimum requirement for the investment management service. Additionally, it may also take the form of corresponding and/or coordinating with attorneys, CPAs, and/or other professionals, as well as document production and other administrative services. Financial Planning Services GFS may also offer Clients financial planning services to include comprehensive or segmented (limited) financial plans, investment plans, and/or individual consultations regarding a Client's financial affairs. The design and implementation of a financial plan may begin with the process of gathering data regarding income, expenses, taxes, insurance coverage, retirement plans, wills, trusts, investments, and/or other relevant information pertaining to a Client's overall financial situation. This information is carefully analyzed taking into account a Client's goals and stated objectives and a series of recommendations and/or alternative strategies will be developed and designed to achieve optimum overall results. Fees for such services will be on a flat fee (per plan) or an hourly rate (see Item 5 Fees and Compensation below for detail). When a client employs GFS for the completion of a Comprehensive Plan, the plan will generally include an analysis of current financial circumstances to identify alternative strategies and assist the client in establishing an implementation schedule. The Plan will typically examine and evaluate securities, other assets, employee benefits, gift and estate tax consequences, income tax, and risk management. Clients may impose restrictions on investing in certain securities or types of securities (i.e., to avoid particular industries such as tobacco or alcohol). Termination of Account Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 6 of 17 ver. 12312025  Clients who wish to terminate their account must notify GFS verbally within five (5) business days of its execution with written notice to follow within the next twenty-four (24) hours. If services are terminated within (5) business days of executing the client agreement, services will be terminated without penalty. After the initial five (5) business days, the client may be responsible for payment of fees for the number of days services are provided by GFS prior to receipt of the notice of termination. GFS shall refund any/all pre-paid unearned fees on a pro-rata basis. GFS may tailor its advisory services to the specific needs and objectives of each advisory client. Clients may also impose restrictions on investing in certain securities or types of securities. Most of which is generally covered in the client’s investment advisory agreement or financial planning agreement. Wrap Fee Program GFS does not participate in a wrap fee program at this time. Assets under Management As of December 31, 2025, the amount of client assets under advisement is calculated as follows: $158,046,348 (526 Accounts) $194,736,038 (32 Accounts) Discretionary: Non-discretionary: Total $352,782,386 (558 Accounts) GFS’ method for computing the amount of “client assets you manage” is the same method for computing “assets under management.” The amount as disclosed above is rounded to the nearest $100,000. The date of the calculation above is not more than ninety (90) days before the date GFS last updated its brochure. Item 5. Fees and Compensation Investment Management Fees GFS manages individual advisory accounts as a percentage of assets under management on a sliding scale of 1.25% to 1.00% depending on the size of the account. Fees are billed quarterly in arrears and can be negotiated depending on the size of the account and other specific circumstances. Generally, fees for services are deducted from the client account. The client may instead pay the fee directly if the client chooses. Fees are calculated and deducted after each quarter has ended. Financial Planning Fees Clients of GFS are reviewed through the Financial Planning and Retirement Planning software and process to determine client goals and objectives, timeline, risk tolerance, and total needs. Recommendations are then formulated for direction of financial assets and other issues of client concerns. Comprehensive planning is offered along with individual needs analysis and are completed at the request of the client. The fees for these services are generally $500.00 - $2,000.00 and are dependent on the complexity of the issues to be addressed. These fees are negotiable and can be waived if continuing services are requested and performed for the client through a relationship of Asset Management, Asset Reporting or other services involving fees related to percentage of assets under management or other commissions generated by the client investment decisions. Fees for Financial and Retirement Planning are billed after service is rendered. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 7 of 17 ver. 12312025  Hourly Consulting Fees GFS may provide advice on an hourly basis for a fee. These fees can be billed at a minimum of $500.00 per hour and can be negotiated depending on the complexity of the issue. Fees are payable after the services are rendered. Additional Fees and Expenses As part of our investment advisory services to you, GFS may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker- dealer or custodian through whom your account transactions are executed. GFS does not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. GFS will absorb, as part of our management of your account the trade costs associated with Mutual Fund purchases and sales. To fully understand the total cost you will incur, you should review all fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the Brokerage Practices section of this brochure. Compensation for the Sale of Securities or Other Investment Products Persons providing investment advice on behalf of our firm are registered representatives with B.B. Graham & Company, Inc. (CRD #41533), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). In their capacity as registered representatives, these persons could be entitled to receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. However, it is our policy that we will not accept any commissions or 12b-1 fees where you are also being charged an advisory fee. Compensation earned by these persons in their capacities as registered representatives is separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs. When appropriate, GFS may recommend the purchase of "no-load" funds. You are under no obligation, contractually or otherwise, to purchase securities products through any person affiliated with GFS. Fees charged to clients may be higher or lower than the aforementioned fees depending on the nature of any pre-existing relationship, the complexity of the accounts, or terms and conditions of any outstanding or pre-existing verbal or written agreement to which GFS is a party. As a result of managing clients’ accounts, clients may also incur brokerage and other transaction-related fees. Clients are encouraged to carefully review Item 5 Fees and Compensation, Item 11 under Participation/Interest in Client Transactions and Item 12 Brokerage Practices for further details on all fees charged to clients. Item 6. Performance-Based Fees and Side-By-Side Management Neither GFS or any of its supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle). Therefore, there are no conflicts of interest that GFS or its supervised persons may face by managing these accounts at the same time, to include any incentive to favor accounts for which GFS or its supervised persons receive a performance-based fee. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 8 of 17 ver. 12312025  GFS and its supervised persons do not charge a minimum fee based on the amount of assets under advisement. No hourly or flat fees are charged to clients, at this time, for our Advisory services. Item 7. Types of Clients GFS is a registered investment adviser firm that provides investment advisory services to individuals, high net worth individuals, pension and profit-sharing plans including 401-K plans, trusts, estates and charitable organizations, and corporations and other business entities (e.g. partnerships)(collectively referred to as “Clients”). Requirement for Opening Accounts (Minimum Investment Amount) GFS’ fee range for each particular service is subject to negotiation and could vary depending upon various circumstances, including the scope of the services to be provided (the fee ranges for existing clients prior to current calendar year may differ from those indicated). GFS does not impose certain requirements for opening and/or maintaining an account, such as a minimum account size or minimum fees. Also please see Fees and Compensation above for further details on investment minimums. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis GFS’ securities analysis methods may include charting, fundamental analysis, and technical analysis. Fundamental analysis includes but is not limited to analyzing company financial statements and health, its management and competitive advantages, and its competitors and markets, the overall state of the economy, interest rates, production, and overall earnings. Technical analysis includes forecasting the direction of prices through the study of past market data, primarily price and volume. The Main sources of Information includes information from (i) financial newspapers and magazines such as Wall Street Journal, Steele Systems, S & P Reports; (ii) research materials prepared by others and those available for the industry and general public through the internet; (iii) corporate rating services; (iv) annual reports, prospectuses, and filings with the Securities and Exchange Commission; (v) company press releases; and RBC Clearing & Custody. Material risks associated with fundamental and/or technical analysis may be that the stock price of a company is not necessarily reflective of or otherwise directly correlated to such factors when determining value. As with most investment products, because investment portfolios include securities, investing in securities involves risk of loss that you as our client should be prepared to bear. Use of Significant Investment Strategy GFS’ investment strategy is to focus on long-term purchases (securities held at least one year) and short- term purchases (securities sold within a year). GFS is NOT involved in margin accounts, short sales, or option writing (covered or uncovered, or other spreading strategies). In the event that GFS employs a frequent trading strategy for its clients, it is important to note that such a strategy can have an affect on investment performance, particularly through increased brokerage and other transaction costs and taxes. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 9 of 17 ver. 12312025  GFS does not recommend any particular type of security as part of its overall investment advisory services. Equity Risks The material risks associated with these strategies are: Equity Market Risk Overall stock market risks may affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Management Risk Our judgments about the attractiveness, value and potential appreciation of a particular asset class or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The value of an individual security can be more volatile than the market as a whole or our intrinsic value approach may fail to produce the intended results. Our estimate of intrinsic value may be wrong or even if our estimate of intrinsic value is correct, it may take a long period of time before the price and intrinsic value converge. Small and Mid-Cap Company Risk Investments in small and mid-cap companies may be riskier than investments in larger, more established companies. The securities of these companies may trade less frequently and in smaller volumes than securities of larger companies. In addition, small and mid-cap companies may be more vulnerable to economic, market and industry changes. Because smaller companies may have limited product lines, markets, or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Short Sale Risk Short sales are speculative transactions and involve special risks. In order to initiate a short position, a security must be borrowed. Strategies that execute short sales may incur a loss if the price of the security sold short increases in value between the date of the short sale and the date when we purchase the security to replace the borrowed security. Losses are potentially unlimited in a short sale transaction. Fixed Income Risks The material risks associated with this strategy are: Fixed Income Market Risk Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of fixed income securities generally declines. On the other hand, if rates fall, the value of the fixed income securities generally increases. Management Risk Our judgments about the attractiveness, value, and potential appreciation of a particular asset class or individual security may be incorrect and there is no guarantee that individual securities Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 10 of 17 ver. 12312025  will perform as anticipated. The value of an individual security can be more volatile than the market as a whole, and our intrinsic value approach may fail to produce the intended results. Credit Risk There is a risk that issuers and counterparties will not make payments on the securities they issue. In addition, the credit quality of securities may be lowered if an issuer’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security which may affect liquidity and our ability to sell the security. Real Estate Risk Real Estate Investment Trusts (REITS), although not a direct investment in real estate, are subject to the risks associated with investing in real estate. The value of these securities will rise and fall in response to many factors including economic conditions, the demand for rental property and changes in interest rates. Structured Instrument Risk Structured instruments may be less liquid than other debt securities, and the price of structured instruments may be more volatile. Although structured instruments may be sold in the form of a corporate debt obligation, they may not have some of the protection against counterparty default that may be available with publicly traded debt securities. ETF Risks The material risks associated with this strategy are: International Limitations While the U.S. has a plethora of ETF products, some countries only have a few exchange traded funds in which to invest. And those regions that do offer market ETFs, usually only include large- cap products leaving a lack of mid and small-sized funds. Low Trading Volumes When ETFs have low trading volumes, the advantage of purchasing and ETF over and index or equity diminishes. The bid-ask spread can be too wide to be cost-effective. Market Makers tend to be tighter on securities that are more liquid (barring any unforeseen news or circumstances). Long Investment Horizon The intraday trading opportunities created by ETFs may not fit into a long-term investor’s strategy. This is more of an advantage for short-term ETF traders. So, as an investor, it will be important to layout your investing goals before you decide how to include ETFs in your portfolio. Inactivity Some ETFs are not as actively traded as others. It can be a sector-related issue or even a regional issue. When this situation occurs, it may be more effective to invest in managed fund where activity is higher. Tax Implications In the case of foreign ETFs, sometimes there may be a tax advantage by opting to invest in an international portfolio. Tax laws vary from country to country, so it may be beneficial for your tax return to find other foreign investments. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 11 of 17 ver. 12312025  There are many benefits to including ETFs in your portfolio, however it is important to understand that they are not the ideal investment for every situation. ETFs should be evaluated on a case-by- case basis for every investing strategy. Item 9. Disciplinary Information Disclosure Events There are no disclosure events involving a criminal or civil action in a domestic, foreign, or military court of competent jurisdiction in which GFS or its management personnel are involved. There are no disclosure events involving an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which GFS or its management personnel are involved. Regarding disclosure events involving a self-regulatory organization (SRO) proceeding in which GFS or its management personnel are involved, the following regulatory even is disclosed: Regulatory event C02050039 SRO: NASD Resolution Date 5/18/2005 In the 1990’s, a representative, Pamela Wilson, who was in an office of Grattan Financial Securities, Inc.* had a consulting arrangement with a Mr. Raymond Kotrozo. Unknown to Grattan Financial, Mr. Kotrozo had prior history with regulatory bodies. Because of Ms. Wilson’s relationship with Mr. Kotrozo, (the unlicensed consultant in her office) and Mrs. Wilson’s relationship with Grattan Financial, this was reported on Georgene M. Grattan’s U-4 as a matter of supervisory responsibility. Georgene M. Grattan was suspended for a period of 45 days in the capacity of General Securities Principal with the ability to retake the Series 24 at any time in the future. In addition, a monetary fine of $20,000 was imposed and was paid in full. Acceptance, Waiver and Consent (AWC) was signed 03/09/05, and accepted by NASD 05/18/05. *During this time there were two separate companies: Grattan Financial Securities, Inc. A Broker Dealer (closed in 2004); and Grattan Financial Strategies, Inc. a Registered Advisory firm) Item 10. Other Financial Industry Activities and Affiliations Broker/Dealer Affiliation Neither GFS nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. However, Georgene, Daniel and Chris Grattan are also registered representatives of B.B. Graham & Co., a FINRA member broker- dealer. Neither GFS nor any of its management 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. On occasion, GFS and its management persons may own securities products that he also recommends to clients which may present a potential conflict of interest. However, as a preventative measure, all client transactions will be conducted and implemented before any such transaction relating to any personal accounts of any affiliated persons of GFS. In addition to this measure, all of the aforementioned management persons of GFS will act in accordance with applicable securities laws and conduct their Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 12 of 17 ver. 12312025  business to ensure overall compliance with Insider Trading rules and the Securities Fraud Enforcement Act of 1988. In the event the client chooses to purchase investment products through GFS’ management persons, in their individual capacities as registered representatives, they may receive brokerage commissions to effect securities transactions. The brokerage commissions charged by GFS may be higher or lower than those charged by other broker-dealers. In addition, GFS, as well as GFS’ management persons (as applicable), relative to commission mutual fund purchases, may also receive additional ongoing 12b-1 trailing commission compensation directly from the mutual fund company during the period that the client maintains the mutual fund investment. Financial Planning Services As a Certified Financial Planner (CFP), Georgene M. Grattan directs clients of the Advisory firm of Grattan Financial Strategies, Inc. through the completion of a financial review. This may take the form of a comprehensive financial plan or shorter form as the need of the client dictates. Insurance Products GFS maintains certain relationships and/or arrangements that are material to its advisory business or to its clients that GFS or any of its management persons may have with any related person. Some of our financial professionals are also licensed as registered representatives of a broker-dealer or as licensed insurance agents. When acting in those capacities, they may recommend products or services (such as certain mutual fund share classes, annuities, or insurance policies) that pay them or our firm a commission or sales charge. This commission-based compensation creates an incentive to recommend a product that pays a higher commission, or to recommend a transaction at all, regardless of whether it is in your best interest. Although the most competitive prices are sought to facilitate the client’s goals, clients are under no obligation to purchase products GFS or its management persons may recommend, or to purchase products or services through GFS or its management persons. Selection of Other Investment Advisers On occasion, GFS may recommend or select other investment advisers for its clients and receive compensation directly or indirectly from those advisers that may create a conflict of interest. However, GFS does NOT receive compensation directly or indirectly from those advisers as a result of such a recommendation or selection by GFS. Disclosure of Material Conflicts All material conflicts of are disclosed regarding the Adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. Item 11. Code of Ethics, Participation/Interest in Client Transactions and Personal Trading Code of Ethics GFS’ Code of Ethics is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940. The Code is based upon the principle that GFS and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm, and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 13 of 17 ver. 12312025  The purpose of GFS’ Code of Ethics is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading, and other forms of prohibited or unethical business conduct. As such, GFS and its employees are prohibited from engaging in fraudulent, deceptive, or manipulative conduct. GFS and its employees have an affirmative duty of utmost good faith to act solely in the best interest of its clients. GFS has adopted the following Code of Ethics in accordance with SEC rule 204A-1 or similar state rules: • Fiduciary Responsibility- GFS and its staff shall exercise the highest standard of care in protecting and promoting the interests of its clients and will provide a written disclosure containing any conflicts of interest that may compromise their impartiality or independence. As fiduciary, GFS shall not accept any referral fees or compensation that is contingent upon the purchase or sale of any financial product. Integrity- All professional services shall be rendered with the highest level of integrity. • • Objectivity- GFS and its staff shall provide advice that is objective and in the best interest of the client and without conflicts of interest. • Competence- GFS and its staff shall maintain the necessary knowledge and skills to provide our clients with competent advice and services. • Fairness- All professional services shall be performed by GFS and its staff in a manner that is fair and reasonable to its clients. • Confidentiality- GFS and its staff shall maintain and safeguard all confidential client information in accordance with applicable laws. • Diligence- GFS and its staff shall ensure the accuracy and completeness of records, information, and data collected, used, and managed, and will take necessary steps to correct any discrepancies. • Regulatory Compliance- GFS and its staff shall comply fully with appropriate laws and internal regulations. GFS will provide a complete copy of its Code of Ethics to any client or prospective client upon request. Participation/Interest in Client Transactions Neither GFS nor any of its related persons recommend to clients, or buys or sells for client accounts, securities in which GFS or a related person has a material financial interest including but not limited to incidents where GFS or a related person, as principal, buys securities from (or sells securities to) GFS clients; GFS or a related person acts as general partner in a partnership in which GFS solicit client investments; or GFS or a related person acts as an investment adviser to an investment company that GFS recommends to client. GFS or its related persons may invest in the same securities (or related securities, e.g., warrants, options, or futures) that GFS or its related persons may recommend to clients. Neither GFS nor any of its related persons recommend securities to clients, or buys or sells securities for client accounts, at or about the same time that GFS or any of its related persons buy or sell the same securities for GFS’ own (or the related person's own) account. GFS maintains processes related to its Code of Ethics to assure the best interest and best execution of client transactions. No trades for GFS will be placed ahead of client trades to knowingly receive a better price or execution. Daily trades are reviewed and signed by a principal of the firm to assure compliance. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 14 of 17 ver. 12312025  Item 12. Brokerage Practices Research and Other Soft Dollar Benefits Regarding research and other soft dollar benefits, GFS does not receive research (both proprietary and non-proprietary) or other products or services other than execution services from a broker/dealer or a third party in connection with client securities transactions (otherwise known as “soft dollar benefits”). Brokerage for Client Referrals GFS has limited discretion over the selection of brokers to be used and the commission rates to be paid. While commission rates are an important factor in broker selection, GFS may select brokers that charge commissions higher than those obtainable from other brokers. In selecting a broker for any transaction or series of transactions, GFS may consider a number of factors in addition to commission rates, including, for example net price, reputation, financial strength and stability, efficiency of execution and error resolution, block trading and block position capabilities, willingness to execute related or unrelated difficult transactions in the future, order of call, on-line access to computerized data regarding client accounts, the availability of stocks to borrow for short trades, custody, record keeping or other similar services, as well as other factors involved in the receipt of general brokerage services. Directed Brokerage Georgene M. Grattan, Chris M. Grattan, and Daniel V. Grattan are licensed through B.B. Graham & Company. Grattan Financial Strategies, Inc. executes trades exclusively through B.B. Graham & Company required through licensing agreement and compliance and because of convenience and related costs. In such arrangement, GFS may be unable to achieve most favorable execution of client transactions. It is important to note that directed brokerage arrangements may cost clients more money. For example, in a directed brokerage account, the client may pay higher brokerage commissions because GFS may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. However, the client has the expressed right to negotiate and complete trades based on the advice of GFS, Inc. wherever they wish. They are advised of their ability to transact business of selling or buying securities through a different relationship other than GFS, INC., and RBC Clearing & Custody. Aggregation of Client Orders GFS does not aggregate the purchase or sale of securities for various client accounts. Because GFS does not aggregate the purchase or sale of securities for client accounts, fee may be higher than similar elsewhere. Item 13. Review of Accounts Client accounts are reviewed on a regular basis by members of the GFS’ asset management team consisting of Georgene M. Grattan, Chris M. Grattan, and Daniel V. Grattan. Review and monitoring are conducted regularly and in line with the structure and agreement of the client contract. Triggering factors that may affect an account review could be any material change in a client’s account such as a change in company earnings, industry/company outlook as well as other factors such as economic news, industry news and changes in world events, and the general nature of business and political changes and events. Individual stock accounts are monitored more closely than mutual funds precisely because of the structure of the investment vehicle. All clients are encouraged to conduct an annual review of their financial objectives, account performance as well other relevant factors The nature and frequency of reports are determined by client need and the services offered. However, most of the clients are provided with transaction confirmation notices and regular summary account Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 15 of 17 ver. 12312025  statements sent directly from the designated broker-dealer/custodian for each client account. Clients receiving investment advisory services will receive written quarterly reports summarizing their overall account activity and investment performance, or more frequently if requested by the client or one of their other advisors. Item 14. Client Referrals and Other Compensation Receipt of Economic Benefit (non-client) GFS does not receive an economic benefit for providing investment advice or other advisory services from someone who is not a client. Direct/Indirect Compensation for Client Referrals Neither GFS nor any of its related persons directly or indirectly compensate any person who is not its supervised person for client referrals. Item 15. Custody Under certain circumstances, GFS serves as the trustee of select trust accounts and therefore is deemed to have “custody” of such client accounts within the meaning of Rule 206(4)-2 under the Advisers Act. For those client accounts where GFS is deemed to have custody, GFS will comply with applicable custody requirements and the client’s custodian will send the client periodic account statements (generally on a quarterly basis) indicating the amounts of any funds or securities in the client’s account as of the end of the statement period and any transactions in the account during the statement period. GFS encourages its clients to review the custodial reports they receive directly from their broker-dealers, banks, or other custodians, and to compare such reports to the reports, if any, they receive from GFS. Additionally, clients should contact GFS immediately if they do not receive account statements from their custodian on at least a quarterly basis. Item 16. Investment Discretion Upon receiving written authorization from a client, GFS may manage client assets on a limited discretionary basis. In this case, Client delegates to GFS limited discretionary trading authorization with respect to the purchase, exchange and sale of actively traded equity and equity-related securities in addition to the amount of securities to be bought or sold on behalf of the Client. Client may also hereby appoint one or more advisory representatives of GFS as a representative of GFS as agent and attorney in fact to purchase, sell and trade such securities, waivers, consents, and other instruments with respect to such securities. Clients requesting GFS’ advisory services are required to sign an advisory agreement for these services giving GFS the authority to manage the assets in the account with discretion. Item 17. Voting Client Securities GFS does not have the authority to vote client proxies and therefore is not required to take action or render advice with respect to voting of proxies solicited by or with respect to the issuers of securities in which assets of the clients account(s) may be invested from time to time. Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 16 of 17 ver. 12312025  Item 18. Financial Information Pre-Payment of Fees GFS does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Material Impact of Discretionary Authority GFS exercises discretionary authority over certain client funds or securities. However, GFS does not anticipate any financial condition that may be reasonably likely to impair its ability to meet contractual commitments to clients at this time. Custody Disclosure GFS maintains custody of select client funds or securities. Please see Custody section above for further details. Bankruptcy Disclosure GFS has not been the subject of a bankruptcy petition at any time during the past ten years. Privacy Policy Privacy Policy Notice Your privacy is important to us. Your personal information is kept secure. Under federal and state law, you have a right to know what information is being collected about you and how that information will be used. GFS collects nonpublic personal information about you from the following sources: • • • Information GFS receives from you on applications or other forms. Information about your transactions with GFS; and Information that you specifically have had your other professional advisors forward to GFS. GFS does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted or required by law, or as directed by you: • Under law, the information GFS collects is provided to companies that perform support services on our behalf as necessary to effect, administer, or process a transaction, or for maintaining and servicing your account; • As directed by you, GFS will be working with your other professional advisors and GFS will provide information in our possession that is reasonably requested by the other advisors. GFS does not give or sell information about you or your accounts to any other company, individual or group. GFS restricts access to nonpublic personal information about you to those employees who need to know that information to provide services to you. GFS maintains physical, administrative, and technical procedural safeguards to protect your nonpublic personal information. You do not need to call or do anything as a result of this notice. It is meant to inform you of how GFS safeguards your nonpublic personal information. Form ADV Part 2A/B for GFS Prepared by Financial Registrations, Inc. Page 17 of 17 ver. 12312025