GRAVITALIX FINANCIAL

Gravitalix Financial, LLC Form ADV Part 2A Brochure Item 1 - Cover Page Part 2A of Form ADV (the “Brochure”) Gravitalix Financial, LLC 3301 North University Drive, Suite 100 Coral Springs, FL 33065 Telephone Number: +1 (646)-732-0299 April 2026 This Brochure provides information about the qualifications and business practices of Gravitalix Financial, LLC (“Gravitalix”). Gravitalix is registering as an investment adviser with the United States Securities and Exchange Commission (“SEC”). Registration does not imply a certain level of skill or training but only indicates that Gravitalix is registering its business with state and federal regulatory authorities, including the SEC. If you have any questions about the contents of this Brochure, please contact us at +1 (646)-732-0299. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. information about Gravitalix is available on the SEC’s website at Additional www.adviserinfo.sec.gov.  Gravitalix Financial, LLC Form ADV Part 2A Brochure Item 2 - Summary of Material Changes Since Gravitalix’s initial Brochure filing in January 2026, there have been no material changes. This Brochure is meant to help Clients understand the nature of the advisory services offered by Gravitalix, whether the advisory services offered by Gravitalix are suitable for the Client, and the potential conflicts of interest associated with Gravitalix’s services. 2  Gravitalix Financial, LLC Form ADV Part 2A Brochure Item 3 - Brochure Table of Contents Item 1 - Cover Page ...................................................................................................................................... 1 Item 2 - Summary of Material Changes ........................................................................................................ 2 Item 3 - Brochure Table of Contents ............................................................................................................ 3 Item 4 – Advisory Business .......................................................................................................................... 4 Item 5 – Fees and Compensation .................................................................................................................. 5 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 8 Item 7 - Types of Clients .............................................................................................................................. 8 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 9 Item 9 - Disciplinary Information ............................................................................................................... 21 Item 10 - Other Financial Industry Activities and Affiliations ................................................................... 21 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 22 Item 12 - Brokerage Practices ..................................................................................................................... 23 Item 13 - Review of Accounts .................................................................................................................... 24 Item 14 - Client Referrals and Other Compensation ................................................................................... 24 Item 15 – Custody ....................................................................................................................................... 25 Item 16 - Investment Discretion.................................................................................................................. 26 Item 17 - Voting Client Securities .............................................................................................................. 26 Item 18 - Financial Information .................................................................................................................. 27 3  Gravitalix Financial, LLC Form ADV Part 2A Brochure Item 4 – Advisory Business Firm Description Gravitalix, LLC (“Gravitalix” or the “Firm”), a Delaware limited partnership formed in 2025 maintaining its principal office at 3301 North University Drive, Suite 100, Coral Springs, Florida, 33065. Gravitalix is wholly owned by Neil Steinhard, an individual. Gravitalix is an investment advisory business established in 2025 focusing primarily on Digital Assets related strategies, including optional yield-focused strategies described in this Brochure. Digital Assets “Digital Assets” means fungible cryptocurrency tokens, such as Ether, Bitcoin, native tokens, USD-backed stablecoins (“Stablecoins”), altcoins, security tokens, trade tokens, digital assets, synthetic assets, cryptocurrencies and any stored value within distributed ledger technologies, as well as non-fungible tokens (“NFTs”). Gravitalix offers a variety of Digital Asset products and investment strategies to Clients seeking exposure to Digital Assets, including strategies designed to hold Digital Assets, strategies designed to seek capital appreciation, and Gravitalix Yield Strategies designed to seek yield on Digital Assets, each subject to the risks and conflicts described in this Brochure. Types of Advisory Services Gravitalix provides discretionary and non-discretionary portfolio management services to individual and institutional clients (each, a “Client”) with respect to Digital Assets. Gravitalix offers discretionary and non-discretionary asset management and investment advisory services in the form of: 1. Separately Managed Accounts (“SMAs”) • Individuals, trusts, family offices and institutions that open an SMA receive discretionary or non-discretionary advisory services from Gravitalix, as specified in the applicable advisory agreement (“Advisory Agreement”). SMAs may include exposure to Digital Assets and, if the Client explicitly elects, to Gravitalix Yield Strategies (defined below). Each Advisory Agreement specifies whether Gravitalix’s investment advice is discretionary or non-discretionary. As detailed in the Advisory Agreement with respect to SMAs, Gravitalix employees collect information about a Client’s financial situation and goals with respect to exposure to Digital Assets and use such information to provide investment advisory services. Gravitalix’s investment advisory services are not designed to provide Clients with a comprehensive financial plan and generally focus on the Client’s Digital Assets held with Gravitalix. 4  Gravitalix Financial, LLC Form ADV Part 2A Brochure Gravitalix’s services with respect to SMAs are highly dependent on receiving accurate information from Clients. Gravitalix may collect information about a Client’s financial situation from its online platform or from other communications with Gravitalix’s employees via phone, videoconference or email. If Clients provide Gravitalix with inaccurate information or fail to timely update applicable information, the quality and effectiveness of Gravitalix’s investment advisory services may be materially impacted. Not every piece of information Gravitalix collects is factored into investment advice proposed to a Client. Gravitalix may agree to limitations and restrictions on its discretionary authority to act with respect to an SMA. Where SMAs are managed on a non-discretionary basis (hereinafter a “Non- Discretionary SMA”), Gravitalix may only effect a transaction with the Client’s prior consent and approval. Gravitalix does not provide advisory services to assets that fall outside of the focus and scope of the applicable Advisory Agreement. Pursuant to the Advisory Agreements, each Client designates Gravitalix as its attorney-in-fact to execute, certify, acknowledge, file, record and swear to all instruments, agreements, and documents necessary or advisable to carry out its investment activities; such Advisory Agreements also describe the limitations, if any, placed on Gravitalix’s investment discretion. Gravitalix does not participate in a wrap fee program. As of November 30, 2025, Gravitalix has approximately $542,500,000 in regulatory assets under management, managed on a discretionary or non-discretionary basis. Item 5 – Fees and Compensation SMA Platform Fees Gravitalix charges an annual asset-based platform and advisory fee (the “Platform Fee”) for SMAs, which is based on the average daily balance of the assets under Gravitalix’s management as of the last day of the month, as documented in the each Client’s Advisory Agreement. The Platform Fee ranges between twenty basis points (0.20%) for basic custody to up to two hundred basis points (2.00%) for other products (defined below at “Item 7 - Types of Clients”), billed monthly in arrears depending upon the size and composition of such Client’s portfolio and the type of services rendered. The Platform Fee compensates Gravitalix for portfolio management and monitoring, access to Gravitalix’s digital asset investment platform and technology, reporting and Client support, and related advisory and non-advisory services. SMA Platform Fees are calculated as a prorated amount of the Client’s daily balance as of 23:59:59 Coordinated Universal Time (UTC). The Digital Assets in each SMA are valued using the “closing price” of each Digital Asset in USD as reported by coinmarketcap.com or other pricing sources pursuant to Gravitalix’s valuation policy on each calendar day, over a month, and typically charged as of the last business day of each month. Fees and Compensation for Gravitalix Yield Strategies In addition to standard Platform Fees, Gravitalix may be compensated for Yield Strategies in 5  Gravitalix Financial, LLC Form ADV Part 2A Brochure one or more of the following ways, as specified in each Client’s Advisory Agreement or other program documents: Asset-Based Platform Fee on Yield Strategies Platform Fees may apply to assets allocated to Yield Strategies at the same or a different rate than other assets in the SMA. In such cases, gross yield (after third-party/platform fees) is generally credited to the Client’s account, and Gravitalix’s compensation is limited to the applicable Platform Fees. In certain Yield Strategies that utilize lending or trading arrangements with third-party counterparties, Gravitalix and/or its affiliates may receive a share of revenue, a spread, or other platform-level compensation from such counterparties. Where applicable, Clients will be credited with a stated yield or rate for their participation, and Gravitalix and/or its affiliates may retain all or a portion of any additional compensation received from such counterparties. These arrangements create conflicts of interest, as Gravitalix may have an incentive to allocate Client assets to strategies or counterparties that are expected to generate higher platform compensation. Gravitalix seeks to address these conflicts through disclosure, supervisory oversight, and policies and procedures designed to allocate opportunities fairly and consistently among Clients. Yield-Linked or Performance-Based Compensation (Qualified Clients only) For “qualified clients,” as defined in Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), Gravitalix may use yield-linked or performance-based compensation structures, for example: • Crediting the Client with a stated, non-binding Client Yield or Client Rate (for example, an annualized percentage applied to the Client’s daily eligible balance) and retaining all or part of any excess yield generated above that Client Rate; and/or • Charging a performance fee or incentive fee on realized or unrealized gains attributable to a Yield Strategy over a measurement period. These arrangements create conflicts of interest because Gravitalix may have an incentive to: • direct assets into strategies that may be expected to produce higher yield or performance, favor accounts paying performance-based or yield-linked compensation, and • increase risk in those accounts to maximize potential compensation. • Gravitalix has adopted policies and procedures designed to treat Clients fairly and equitably and to mitigate these conflicts, including procedures for allocation of investment opportunities, independent review of performance-fee account trading, and supervision of Yield Strategies. However, such conflicts cannot be entirely eliminated. Other Fees and Expenses Clients may also bear transaction fees associated with the trading of Digital Assets, as discussed 6  Gravitalix Financial, LLC Form ADV Part 2A Brochure in Item 12 – Brokerage Practices. Gravitalix’s Management Fees and Platform Fees do not include fees or expenses associated with brokerage, custody, transaction, blockchain network fees (such as gas fees for Ethereum- based transactions), or similar fees assessed by any third-party service provider. For SMAs, transaction fees are added and itemized separately in each Client’s SMA statement. Clients should be aware that blockchain network fees can be substantial and highly variable depending on network congestion and may significantly impact the cost-effectiveness of transactions, particularly for smaller account sizes. Clients pay fees and incur expenses whether they make or lose money on their investments. Fees and expenses reduce any amount the Client makes on their investments over time. The more assets there are in a Client’s account, the more such Client pays in fees, and Gravitalix may, from time to time, have an incentive to encourage Clients to increase assets managed by Gravitalix. On the last business day of each month, Gravitalix assesses fees. Platform Fees are either deducted from the Client’s SMA subject to the Client’s prior agreement, or billed and processed separately. If an SMA Client prepays an Platform Fee and then terminates its Advisory Agreement before the end of the billing period, prepaid fees will be returned to each Client on a prorated basis based on the termination date of the SMA. Clients may be required to maintain a minimum USD-backed Stablecoin balance in their SMA in order to cover the cost of any ongoing fee obligations. If a Client’s balance in its SMA is insufficient to cover Gravitalix’s fees for that month, Gravitalix may deduct fees from other assets in the SMA. If those assets are insufficient to cover fees, fees continue to accrue and are added to the following month’s fees. Gravitalix automatically debits the prorated amounts of the fees from the assets in a Client’s SMA on a monthly basis in arrears, as detailed in the Advisory Agreement. Clients that have unpaid fee obligations may be prevented from withdrawing assets from their SMA until after the fee obligation is satisfied. For all Clients, Gravitalix’s Management Fees or Platform Fees, as the case may be, are calculated based on the valuation of Digital Assets in Client accounts as of 23:59:59 UTC using the “closing price” of each Digital Asset in USD as provided by CoinMarketCap or other pricing sources pursuant to Gravitalix’s valuation policy. Clients should be aware that Digital Asset valuations can be highly volatile and may vary significantly across different pricing sources, which could affect the fees charged. Clients can review fees paid on their monthly statements. Fees and other compensation may be negotiable under certain circumstances at the sole discretion of Gravitalix and arrangements with any particular Client may vary. Although Gravitalix believes its fees are competitive, lower fees for comparable services may be available from other investment advisers. Neither Gravitalix nor its employees accept any compensation for the sale of specific investment 7  Gravitalix Financial, LLC Form ADV Part 2A Brochure products, including asset-based sales charges. Gravitalix employees receive a salary and a discretionary bonus. Item 6 – Performance-Based Fees and Side-By-Side Management Gravitalix may charge performance-based fees, including yield-linked or incentive fees, for eligible SMAs (“qualified clients,” as that term is defined in the Advisers Act) that receive discretionary advisory services pursuant to an Advisory Agreement. This may include performance-based or yield-linked fees on Gravitalix Yield Strategies, as described in Item 5. Since Gravitalix may advise Clients that do not pay performance-based fees, as well as Clients that do, Gravitalix may have an incentive to: (i) favor Clients that pay performance-based or yield-linked fees over Clients that do not; (ii) allocate higher-risk or more aggressive investment opportunities, including certain Yield Strategies, to performance fee accounts to maximize performance fees; and (iii) take greater risks with performance fee accounts than would be appropriate for the Client’s stated risk tolerance. Gravitalix has adopted written policies and procedures designed to treat all Clients fairly and equitably, including procedures for fair allocation of investment opportunities, independent review of performance fee account trading, and restrictions on preferential treatment. These policies are designed to prevent performance- based conflicts from influencing the allocation of investment opportunities among its Clients. However, Clients should be aware that these conflicts cannot be entirely eliminated. Item 7 - Types of Clients Gravitalix’s Clients include individuals, institutions, trusts, and other legal entities. The SMAs will have an investment minimum of $5,000. Gravitalix’s Yield Strategies may require a minimum overall account balance (for example, $5,000 or equivalent) for participation and minimum per-asset or per-strategy balances for specific Yield Strategies. Gravitalix may reduce or suspend a Client’s participation if balances fall below required minimums. A. SMA Clients Gravitalix provides discretionary investment advisory services to Clients in the form of SMAs based on information provided by Clients regarding, among other things, liquid net worth (investable assets), risk tolerance, investment goals and investment experience during any financial consultation call, email or from an onboarding questionnaire. This advice pertains solely to the Client’s investments in Digital Assets with Gravitalix and is not intended to be holistic financial advice pertaining to any other asset classes. SMAs do not currently support crypto forks or airdrops. Forks and airdrops may adversely impact the value of the original Digital Assets and the successor Digital Assets held in the SMA. With regard to Digital Assets held in SMAs, Gravitalix has sole discretion to decide whether or not to support forks and airdrops for those Digital Assets, and Gravitalix in its sole discretion may (i) not accommodate the new Digital Asset; (ii) only accommodate the new Digital Asset 8  Gravitalix Financial, LLC Form ADV Part 2A Brochure after a significant period; or (iii) with advance written consent from the Client, have a contractual right to claim the new Digital Asset for its own account, provided that any such arrangement shall be disclosed in the Advisory Agreement. Gravitalix does not currently have any systems in place to participate in Digital Asset forks or airdrops. As a result, Clients may not benefit from Digital Assets provided through forks or airdrops, and Digital Assets subject to forks or airdrops may be rendered useless or of little value. Gravitalix will use commercially reasonable efforts to notify Clients of material forks or airdrops that may affect their holdings. Furthermore, some Digital Asset tokens include participation in governance activities, such as the ability to vote on topics that directly or indirectly may affect return on investment through on-chain governance. Gravitalix’s infrastructure does not currently support the ability to participate in such Digital Asset governance activities. As such, Clients may be unable to participate in such governance activities for Digital Assets held in their SMA. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss A. SMA Clients Investment Strategies Gravitalix offers Non-Discretionary and Discretionary SMAs to Clients, which may include exposure to a variety of Digital Assets and to select staking, yield, and lending products. For more detail on the risks involved in investing in Digital Assets, please see the section below entitled “Risk Factors.” Yield Strategies Yield Strategies (Program Overview) In addition to “core” Digital Asset portfolio strategies, Gravitalix may offer Gravitalix Yield Strategies to Clients who explicitly elect to participate. I. Optional, opt-in program. Gravitalix Yield Strategies are optional and require explicit Client election. No Client is automatically enrolled. Clients must complete a separate consent process before any assets are allocated to Yield Strategies. II. Supported assets. Yield Strategies are available only for certain supported Digital Assets selected by Gravitalix, which may change over time. Flexible Yield vs. Term Yield. Gravitalix generally distinguishes between: • Flexible Yield Strategies (“Flexible Yield”) that seek yield while permitting Client withdrawal requests on a more flexible basis (subject to liquidity and other risks); and • Term Yield Strategies (“Term Yield”) that require a Client to commit assets for a pre- agreed term (for example, 1, 3, 6, or 12 months) and that may restrict withdrawals until maturity. 9  Gravitalix Financial, LLC Form ADV Part 2A Brochure Daily accrual and Non-binding Target Yields Gravitalix generally seeks to accrue yield daily on eligible balances in Yield Strategies based on one or more non-binding Target Yields set by Gravitalix. Target Yields are not guaranteed, may change frequently, and actual yields may be lower or negative after fees, losses, or other factors. Program Mechanics Gravitalix will typically allow Clients to allocate or reallocate assets to Yield Strategies on any business day, subject to cut-off times, minimums, available capacity, and restrictions or lock- ups in underlying strategies. For certain Term Yield strategies, investments and redemptions may only be permitted on specified dates (for example, the first and last business day of a calendar month). Withdrawals may be delayed or restricted by market, liquidity, counterparty, protocol, or operational factors. Participation in Gravitalix Yield Strategies involves significant risk, including the risk of loss of some or all of the Digital Assets allocated to those strategies. Yield Strategies are investment strategies, not bank accounts, savings products, or deposits, and they are not insured by the FDIC, SIPC, or any governmental or private insurer. Gravitalix offers access to select opportunities to seek yield on Digital Assets to SMA Clients who wish to hold Digital Assets and earn yield on those assets. Gravitalix Yield Strategies are discretionary or non-discretionary portfolio strategies that use one or more of the “Portfolio Strategies” described below with the goal of generating yield and/or capital growth on Digital Assets. Yield Strategies may include on-chain over-collateralized lending within the SMA and/or centralized lender arrangements, as further described herein. Key features of Gravitalix Yield Strategies generally include: a) Opt-In / Eligibility b) Participation is optional and requires explicit Client consent. c) Gravitalix may require Clients to complete a risk assessment or knowledge questionnaire before investing in Yield Strategies. d) Gravitalix may impose minimum account size and strategy-level minimum investment amounts. e) Flexible Yield vs. Term Yield a. Flexible Yield Strategies (“Flexible Yield”) f) Designed to allow Clients to request withdrawals at any time, subject to processing times, liquidity of underlying positions, and other factors. Liquidity is not guaranteed. g) Yield generally accrues daily on eligible Digital Assets based on a non-binding, annualized Target Yield set by Gravitalix, applied to the Client’s daily balance in the strategy. h) Accrued yield is credited periodically (for example, daily or monthly) and may itself be 10  Gravitalix Financial, LLC Form ADV Part 2A Brochure allocated to the strategy, enabling potential compounding. i) Gravitalix may change Target Yields at any time. Actual realized yield may be lower than Target Yields, including zero or negative after considering fees, losses, and other factors. Term Yield Strategies (“Term Yield”) a) Require Clients to commit Digital Assets for a specified term (for example, 1, 3, 6, or 12 months). b) Assets committed to a Term Yield strategy are generally locked up for the full term and are not available for withdrawal until maturity, except as expressly permitted by Gravitalix in writing. Gravitalix may permit early withdrawals in limited circumstances (such as financial hardship or emergency), which may be subject to reasonable delays, penalties not to exceed 10% of the withdrawal amount, and/or forfeiture of accrued but unpaid yield. The specific terms of any early withdrawal penalties will be disclosed in the applicable Advisory Agreement or program materials prior to Client commitment. c) Yield typically accrues daily during the term and is paid at maturity and/or at predefined intervals, as disclosed at the time of investment. d) Term Yield strategies may offer higher Target Yields relative to Flexible Yield, but involve greater liquidity and lock-up risk. e) Deposit and Withdrawal Mechanics f) Subject to minimums, cutoff times, capacity constraints and other conditions, SMA Clients may generally allocate assets to Gravitalix Yield Strategies on any business day. g) For certain Term Yield Strategies or specific program designs, Clients may be limited to allocating and withdrawing on specified dates (for example, the first and last day of a calendar month) (each such date, a “Deposit Date” or “Withdrawal Date,” as applicable). h) Actual deposit and withdrawal mechanics, including settlement times and any notice periods, are described in the applicable offering or program materials. Some Gravitalix Yield Strategies may have limited capacity and there is no guarantee that all Clients will be able to access a particular Gravitalix Yield Strategy if available capacity is exceeded. To the extent that there is more demand for a particular Gravitalix Yield Strategy than supply for any Deposit Date (defined below), Client participation in such Gravitalix Yield Strategy will be allocated pro rata in accordance with Gravitalix ’s allocation policy. Portfolio Strategies Gravitalix uses a variety of strategies in its discretion to generate yield across the Gravitalix Yield Strategies and other SMA strategies, including: 1. Staking Strategies Staking Digital Assets (“Staking Strategies”) in proof-of-stake blockchains (“PoS”). PoS networks (the Ethereum network being the largest PoS network) allow users to put their assets 11  Gravitalix Financial, LLC Form ADV Part 2A Brochure to productive use to earn rewards, paid in-kind, in exchange for contributing their assets to the functioning of the blockchain network. The rewards generated through staking activity range depending on the market demand and supply for staked assets. 2. Lending Strategies Lending Digital Assets (“Lending Strategies”), which may occur via: a) Decentralized applications built on public blockchain networks that execute transactions autonomously via smart contracts (a “DAPP”); or b) Transfers to approved centralized lending counterparties, in each case in exchange for interest, paid in-kind in the form of the Digital Asset used to provide the loan or by a DAPP’s native Digital Asset. Rewards are generally paid in-kind and, from time to time, in the DAPP’s native token. Lending transactions executed via smart contracts are designed to minimize traditional counterparty risk but remain subject to smart contract risk, protocol risk, and other technology-related risks. 3. Liquidity Provision / Automated Market Making (“LP Strategies”) Automated market making strategies often referred to as liquidity provisioning (“LP Strategies”), where Client Digital Assets are provided as liquidity (the Client acting as a “Liquidity Provider”) for decentralized exchange applications (“DEXes”) built on public blockchain networks. Liquidity Providers provide the liquidity for DEX users to swap between Digital Asset trading pairs and, in exchange, receive rewards (usually a share of transaction fees) paid in-kind. LP Strategies remain subject to smart contract risk, protocol risk, and economic risks such as impermanent loss. 4. Staking and DeFi Yield Strategies via Qualified Custodian Gravitalix may allocate SMA assets to staking, over-collateralized on-chain lending, and liquidity provisioning, executed through Qualified Custodian–controlled wallets or regulated sub-custodians. Yield is earned in-kind in the form of native Digital Assets. Some Digital Assets may be illiquid or semi-liquid for some period of time (for example, Digital Assets that are not listed on a public exchange or are subject to lock-ups). Such Digital Assets may be highly volatile. For additional risks relating to investing in Digital Assets and participating in Yield Strategies, please see the section below entitled “Risk Factors.” Portfolio Management Gravitalix’s management team is responsible for Gravitalix’s investment strategies and portfolio management, as well as Gravitalix’s policies. The management team determines which portfolio strategies Gravitalix makes available to Clients and oversees each portfolio strategy, except to the extent described below. The management team may delegate part or all of its responsibilities to a subcommittee or portfolio managers. 12  Gravitalix Financial, LLC Form ADV Part 2A Brochure Gravitalix’s management team has experience managing Digital Assets at scale in various trading, lending and decentralized yield strategies and Gravitalix uses this experience and knowledge in the selection and evaluation of potential strategies, including Gravitalix Yield Strategies for SMAs. Gravitalix considers a variety of factors, including but not limited to (i) the historical return profiles of a particular strategy; (ii) the quality and resources of the team that built the DAPP or protocol; (iii) the length of time the DAPP or protocol has operated; (iv) the number and frequency of third-party audits of the DAPP or protocol by reputable smart contract auditing firms; (v) the history of hacks and bugs for the DAPP or protocol; (vi) the assets managed by the DAPP (referred to as “TVL”) or protocol and the exit liquidity in specific pools run by the DAPP or protocol; (vii) the governance mechanisms of the DAPP or protocol; (viii) any potential governance and centralization risks presented by the ratio of the market capitalization of the governance token to the TVL; and (ix) any operational risks of implementing the strategy. B. Risk Factors Investing involves risk that each Client should be prepared to bear. Gravitalix does not guarantee the future performance of any SMA or Gravitalix Yield Strategy, or any specific level of return. Clients may lose part or all of their investment. The following is a summary of certain material risks associated with Gravitalix’s advisory services and the Digital Assets and strategies used in Client accounts (including SMAs and Gravitalix Yield Strategies). This summary is not intended to be exhaustive. Additional risks and uncertainties that Gravitalix does not presently know of, or currently deems immaterial, may also adversely affect Clients and their investments. Generally Applicable Risks Dependence on Key Personnel. The success of Gravitalix’s investment strategies depends significantly on the skills, experience, and judgment of its principals and key personnel. If one or more key individuals were to become unavailable for any reason, Gravitalix’s ability to implement its strategies or manage risk could be adversely affected, which in turn could adversely impact Client accounts. Conflicts of Interest and Fiduciary Duties. Gravitalix manages multiple Clients and strategies, including SMAs and Gravitalix Yield Strategies. Gravitalix or its personnel may have financial or other interests that differ from, or conflict with, those of particular Clients. For example, Gravitalix may manage accounts that pay performance-based or yield-linked compensation alongside accounts that do not, and Gravitalix may have an incentive to favor one set of accounts over another. Gravitalix has adopted policies and procedures designed to identify, mitigate, and disclose material conflicts of interest, but such conflicts cannot be completely eliminated. Force Majeure and Extraordinary Events. Client investments may be adversely affected by events beyond the reasonable control of Gravitalix or its service providers, including but not limited to natural disasters, pandemics, war, terrorism, civil unrest, labor strikes, major power or technology failures, cyber incidents, and government actions (including sanctions, 13  Gravitalix Financial, LLC Form ADV Part 2A Brochure nationalizations, or trade restrictions). Such events may disrupt markets, delay or prevent transactions, impair operations or communications, or cause sustained losses. Market Risk. The value of investments in Client accounts will fluctuate due to general market conditions and other factors beyond Gravitalix’s control. These may include economic and political events, changes in interest rates, inflation, financial market volatility, changes in liquidity and credit availability, and investor sentiment. Market risk includes, among others: a) Market Decline Risk. Prolonged downturns or recessions can negatively affect the performance of Digital Assets and other investments. b) Concentration Risk. Concentrated exposures to a particular asset, sector, or strategy may increase volatility and the magnitude of losses. c) Volatility Risk. Historical performance and volatility are not reliable indicators of future results. Periods of extreme volatility may occur abruptly. d) Correlation Risk. Assets that have historically behaved differently may begin to move together, particularly in stressed markets, reducing the benefits of diversification. e) Liquidity Risk. In stressed markets or for certain Digital Assets and strategies, trading may become difficult or impossible without materially affecting prices. Inflation, Currency, and Interest Rate Risk. Inflation and changes in interest rates may adversely affect the real value of Client investments and the returns of Digital Assets quoted or settled in fiat currencies such as U.S. dollars. Interest-rate movements may also affect the valuation of certain yield and lending strategies and the cost of leverage. Investment Advice Risk. Gravitalix does not guarantee that any investment strategy or recommendation will achieve its objectives. All investment decisions involve judgment. Gravitalix’s advice is based on information supplied by Clients and from third-party sources that Gravitalix believes to be reliable but does not independently verify in all cases. If Client information is inaccurate, incomplete, or not promptly updated, the suitability and effectiveness of Gravitalix’s advice may be materially impacted. Model, Software, and Operational Risk. Gravitalix may use models, tools, software, and algorithms to support portfolio construction, rebalancing, and risk management. Any such systems may contain defects or errors, may rely on incorrect assumptions, or may fail to perform as intended. Operational risks include failures of internal processes, people, systems, or external service providers, and may result in delays, errors, or losses. Cybersecurity and Information Security Risk. Gravitalix and its service providers rely heavily on technology, networks, and information systems. These systems may be vulnerable to cybersecurity incidents, including unauthorized access, theft of data or Digital Assets, ransomware, denial-of-service attacks, or other disruptions. While Gravitalix maintains policies, procedures, and controls designed to reduce such risks, no system is completely secure, and a successful cyber incident could result in substantial losses, operational disruption, or regulatory and reputational harm. 14  Gravitalix Financial, LLC Form ADV Part 2A Brochure Regulatory and Legal Risk. Investment performance may be adversely affected by changes in laws, regulations, tax rules, enforcement priorities, or interpretations applicable to investment advisers, Digital Assets, trading venues, custodians, stablecoins, or other market participants. New regulations or guidance may require Gravitalix or its Clients to alter their strategies, cease certain activities, or incur additional compliance costs, any of which could negatively affect Client accounts. 1. Risks Specific to Digital Assets and the Digital Asset Industry Nature of Digital Assets. Digital Assets are a relatively new and evolving asset class. The price of a virtual currency is based on the perceived value of the virtual currency and subject to changes in sentiment, which make these products highly volatile. Their value is generally determined by supply and demand dynamics, market sentiment, the perceived utility of the asset, expectations regarding future adoption, and regulatory developments. There is no assurance that any Digital Asset will maintain its value or achieve widespread adoption. Volatility and Limited History. Many Digital Assets have limited operating and trading histories. Past price behavior, including periods of significant appreciation, is not indicative of future performance. Price swings of large magnitude over short periods are common and may result in rapid and substantial losses. Technology and Protocol Risk. Digital Assets and their networks rely on complex software, cryptographic protocols, and distributed systems. These may contain vulnerabilities, bugs, or design flaws that could lead to failures, exploits, or unexpected behavior. Advancements in technology (such as quantum computing) could undermine current cryptographic standards and compromise the security of certain Digital Assets or networks. Network and Consensus Risks (Including 51% Attacks and PoS Slashing). Digital Asset networks typically rely on consensus mechanisms such as proof-of-work or proof-of-stake. If a malicious actor gains significant control over network resources (e.g., hashing power or staked tokens), they may manipulate the network, reverse transactions, or disrupt operations. In proof- of-stake systems, validators may be penalized or “slashed” (forfeiting part of their stake) due to misbehavior, errors, or software failures, which could result in losses for Clients whose assets are staked. Sector Concentration / Lack of Diversification. Client accounts that focus primarily on Digital Assets may be less diversified than traditional portfolios and may be more susceptible to industry-specific events, such as exchange failures, protocol exploits, regulatory actions, or shifts in public perception about the viability of Digital Assets generally. Uninsured Nature of Digital Assets. Digital Assets held in Client accounts are not deposits and are not insured by the Federal Deposit Insurance Corporation (FDIC), the Securities Investor Protection Corporation (SIPC), or any similar governmental or private insurer. While certain custodians or service providers may hold commercial insurance, such coverage is limited and may not cover all types of losses or all Clients. Custodial Risk and Private Key Risk. Control over Digital Assets depends in part on the 15  Gravitalix Financial, LLC Form ADV Part 2A Brochure security of private keys or key shares. The loss, theft, destruction, or unauthorized use of private keys or key material (including within multi-party computation arrangements) can result in the permanent and irretrievable loss of associated Digital Assets. Custodians and other service providers may experience operational or security failures that adversely affect Client assets. Forks and Airdrops. Digital Asset networks may undergo “forks” (changes to protocol rules that can create new chains and new assets) or “airdrops” (unsolicited distributions of new tokens). Gravitalix or its custodians may determine, in their discretion, whether and when to support or claim such assets, or may have contractual rights to retain them. New assets created via forks or airdrops may be illiquid, volatile, or worthless, may introduce additional tax or compliance issues, and may affect the value or market perception of the original Digital Asset. Stablecoin Risks, Reserves, and Depegging. Some strategies may use USD-backed or other stablecoins. Stablecoins are subject to the risks of their underlying reserves, the solvency and integrity of issuers and custodial banks, and the legal and regulatory regimes that apply to them. There is no guarantee that a stablecoin will maintain its intended peg (for example, 1:1 with USD). A loss of confidence in an issuer’s reserves, regulatory intervention, or failure of a banking partner may cause a stablecoin to “depeg,” potentially resulting in substantial or total loss of value. Recent and Potential Future Industry Disruptions. The Digital Asset industry has experienced distress and failures among exchanges, lenders, trading firms, and other service providers, including insolvencies, suspensions of withdrawals, and allegations of fraud or misconduct. Such events can contribute to sharp declines in asset prices, reduced liquidity, increased counterparty risk, regulatory scrutiny, and reputational harm to the broader industry. Future disruptions or failures of significant market participants could adversely affect the value, liquidity, and tradability of Digital Assets held in Client accounts. Development and Acceptance of Digital Assets. As a relatively new product and technology, Digital Assets are not yet widely adopted as a means of payment for goods and services. Banks and other established financial institutions may refuse to process funds for Digital Asset transactions, process wire transfers to or from Digital Asset exchanges, Digital Asset-related companies or service providers, or maintain accounts for persons or entities transacting in Digital Assets. Market capitalization for Digital Assets as a medium of exchange and payment method may always be low. Further, a Digital Asset's use as an international currency may be hindered by the fact that it may not be considered as a legitimate means of payment or legal tender in some jurisdictions. To date, speculators and investors seeking to profit from either short- or long-term holding of Digital Assets drive much of the demand for it, and competitive products may develop which compete for market share. Further, certain virtual currencies or payment systems may be the subject of a U.S. or foreign patent application (i.e., JP Morgan Chase Bank's patent application for "Alt-Coin" with the United States Patent & Trademark Office), successfully patented, or, alternatively, mathematical Digital Asset network source codes and protocols may be patented or owned or controlled by a public or private entity. Gravitalix could be adversely impacted if Digital Assets fail to expand into retail and commercial markets. Development and Acceptance of the Digital Asset Networks. The growth and use of virtual 16  Gravitalix Financial, LLC Form ADV Part 2A Brochure currencies generally is subject to a high degree of uncertainty. Indeed, the future of the industry likely depends on several factors, including, but not limited to: (a) economic and regulatory conditions relating to both fiat currencies and virtual currencies; (b) government regulation of the use of and access to virtual currencies; (c) government regulation of virtual currency service providers, administrators or exchanges; and (d) the domestic and global market demand for— and availability of—other forms of virtual currency or payment methods. Any slowing or stopping of the development or acceptance of Digital Assets or a Digital Asset network may adversely affect an investment in Gravitalix. Development and Adoption Risk; Key Person Risk at Protocol Level. The long-term success of a Digital Asset depends on developer engagement, community support, end-user adoption, and the continued operation of its network. If the core development team or key contributors abandon a project, are compromised, or lose credibility, the Digital Asset’s value may decline materially or permanently. Transaction Fees. Many Digital Assets allow market participants to offer miners (i.e., parties that process transactions and record them on a blockchain or distributed ledger) a fee. While not mandatory, a fee is generally necessary to ensure that a transaction is promptly recorded on a blockchain or distributed ledger. The amounts of these fees are subject to market forces and it is possible that the fees could increase substantially during a period of stress. In addition, virtual currency exchanges, wallet providers and other custodians may charge high fees relative to custodians in many other financial markets. Irrevocable Digital Asset Transactions. Just as the blockchain (or similar technologies) creates a permanent, public record of Digital Asset transactions, it also creates an irrevocable one. Transactions that have been verified, and thus recorded as a block on the blockchain (or similar technologies), generally cannot be undone. Even if the transaction turns out to have been in error, or due to theft of a user's Digital Assets, the transaction is not reversible. Further, at this time, there is no U.S. or foreign governmental, regulatory, investigative, or prosecutorial authority or mechanism through which to bring an action or complaint regarding missing or stolen Digital Assets. Consequently, Gravitalix may be unable to replace missing Digital Assets or seek reimbursement for any erroneous transfer or theft of Digital Assets. To the extent that Gravitalix is unable to seek redress for such action, error or theft, such loss could adversely affect an investment in the Gravitalix. Loss or Destruction of Digital Assets. Certain Digital Assets are intended to be controllable only by the possessor of both the unique public and private keys relating to the local or online digital wallet in which such Digital Assets are held. To the extent private keys relating to the Gravitalix's Digital Asset holdings are lost, destroyed or otherwise compromised, Gravitalix may be unable to access the related Digital Assets and such private keys are not capable of being restored by a Digital Asset network. Any loss of private keys relating to digital wallets used to store Gravitalix's Digital Assets could adversely affect an investment in Gravitalix. Further, Digital Assets are typically transferred digitally, through electronic media not controlled or regulated by any entity. To the extent a Digital Asset transfers erroneously to the wrong destination, Gravitalix may be unable to recover the Digital Asset or its value. Such loss could adversely affect an investment in Gravitalix's. 17  Gravitalix Financial, LLC Form ADV Part 2A Brochure Lack of available Third-Party Qualified Custodians. As a registered investment adviser, Gravitalix hopes to utilize third-party custodians for the Clients’ Digital Assets. However, qualified third-party custodians that satisfy this requirement for certain Digital Assets may not be available, in which case Gravitalix may be required to self-custody Digital Assets. There can be no assurance that self-custody will adequately protect the security of such Digital Assets, exposing Gravitalix to up to the complete loss of a Digital Asset owing to a security breach or other failure of the self-custody procedures. In addition, regulators may not agree with the Gravitalix’s decision to self-custody a Digital Asset, resulting in the possibility of sanctions, fines or other regulatory reparations imposed on Gravitalix, us or any of our affiliates by the SEC. 2. Risks Specific to Gravitalix Yield Strategies and Related Activities Gravitalix Yield Strategies involve additional risks beyond those associated with holding Digital Assets in a non-yielding form. Clients should not treat Yield Strategies as bank accounts, savings products, or guaranteed income streams. No Guarantee of Yield or Principal. Target Yields, Client Rates, or similar metrics are non- binding estimates set by Gravitalix and may change at any time. Actual yields may be lower than Target Yields, and Clients may experience no yield or negative returns after fees and losses. Client principal (Digital Assets) is at risk; losses may be partial or total. Counterparty and Credit Risk (Centralized Lenders and Borrowers). Where Yield Strategies rely on lending to centralized counterparties (including exchanges, trading firms, or lending platforms), Client assets are exposed to the solvency, liquidity, and risk management of those counterparties. A counterparty may default, become insolvent, suspend withdrawals, or otherwise fail to honor its obligations, which may result in delayed recoveries or permanent loss. Smart Contract, Protocol, and DeFi Risk. Yield Strategies that use decentralized finance (“DeFi”) protocols and smart contracts are subject to: a) coding errors, design flaws, or unanticipated interactions with other contracts; b) governance failures or hostile governance actions; c) economic exploits (for example, flash-loan attacks, oracle manipulation, or other forms of arbitrage); and d) operational errors in deploying or interacting with DeFi protocols. Any such issue may lead to the loss, theft, or freezing of Client Digital Assets. Collateral and Liquidation Risk. Over-collateralized lending strategies may involve posting collateral that can be liquidated if loan-to-value (LTV) ratios or protocol health factors fall below specified thresholds. In periods of market stress or rapid price declines, liquidations may occur quickly, potentially at unfavorable prices, and may lock in losses for Clients. 18  Gravitalix Financial, LLC Form ADV Part 2A Brochure Liquidity and Withdrawal Risk. Gravitalix Yield Strategies, including Flexible Yield and Term Yield, depend on the liquidity of underlying positions and counterparties. Circumstances may arise where Gravitalix, a protocol, or a counterparty cannot promptly return or unwind positions without materially impacting prices or violating contractual or risk limits. As a result: a) withdrawal requests may be delayed or suspended; b) Term Yield strategies may enforce lock-ups or impose early-withdrawal penalties; and c) redemptions may be processed in-kind or in multiple tranches over time. There is no assurance that Clients will be able to exit Yield Strategies on demand or at anticipated values. Strategy Capacity and Concentration Risk in Yield Strategies. Certain Yield Strategies may have limited capacity. To the extent demand exceeds available capacity, Gravitalix may allocate opportunities among eligible Clients using its allocation policies, which may result in differing access and outcomes across accounts. Concentrated use of particular protocols, counterparties, or assets within a Yield Strategy can amplify losses if those elements fail or underperform. Conflicts of Interest in Yield Strategies and Performance-Based Compensation. For certain Clients, Gravitalix may be compensated through performance-based or yield-linked fees or may retain some or all yield generated above a stated Client Rate or Target Yield. Additionally, Gravitalix may adopt asset-based “tiers” that provide different Target Yields or Client Rates depending on the size of a Client’s or household’s assets under management. These arrangements create conflicts of interest because Gravitalix has an incentive to: a) allocate more assets to strategies expected to generate higher yields or performance; b) favor accounts that pay performance-based or yield-linked compensation or that are in higher asset tiers; and c) encourage Clients to increase assets or maintain assets in particular strategies. Gravitalix seeks to mitigate these conflicts through disclosure, supervisory oversight, and policies and procedures designed to allocate opportunities fairly and consistently; however, such conflicts cannot be fully eliminated. Tax Risk. The tax treatment of Digital Assets and yield-generating activities is uncertain and may vary by jurisdiction over time. Rewards, interest, airdrops, forked assets, and other forms of consideration may be taxable when received (even if not sold), may be treated differently from traditional interest or capital gains, and may trigger complex reporting obligations. Clients are responsible for consulting their own tax advisers and for all tax consequences arising from their investments and participation in Yield Strategies. 3. Material Risks of the Lending Program Lending-based Yield Strategies involve significant risks, including: 19  Gravitalix Financial, LLC Form ADV Part 2A Brochure Counterparty Risk. Borrowers or lending platforms (centralized or DeFi) may default, become insolvent, or fail to return Client assets. Smart contract vulnerabilities, protocol exploits, or governance failures could result in partial or total loss of Client assets. As with digital assets generally, SIPC protection does not apply to digital asset lending activities. Liquidation Risk. If the value of collateral falls below required thresholds, positions may be liquidated, potentially at unfavorable prices, resulting in losses. Custody and Operational Risk. While the Qualified Custodian maintains custody, the execution of lending transactions involves operational risks, including technology failures, key management issues, or errors in transaction execution. Regulatory Risk. Evolving and uncertain regulation of digital asset lending may restrict or prohibit lending activities, impact the ability to recover assets, or result in legal liability. Federal and state regulators, including the SEC, have taken enforcement actions against digital asset lending programs, and the regulatory status of such programs remains unsettled. Changes in law or regulation could require immediate unwinding of lending positions, potentially at unfavorable terms, or could result in regulatory sanctions against Gravitalix or its service providers. Liquidity Risk. Lent assets may not be immediately available for withdrawal. Clients may experience delays in accessing their Digital Assets, particularly during periods of market stress or if lending protocols or counterparties impose withdrawal restrictions. Market Risk. The value of Bitcoin and other Digital Assets is highly volatile. Significant price movements can occur while assets are lent, and Clients bear the full market risk of their holdings. In lending arrangements involving collateralization, rapid price declines may trigger liquidations before Gravitalix can take protective action, potentially resulting in losses exceeding the yield earned. 4. Regulatory and Legal Risks Specific to Digital Assets and Yield Programs Uncertain Regulatory Classification. The regulatory treatment of many Digital Assets, stablecoins, and DeFi or lending protocols is unsettled and evolving. Government agencies and legislative bodies in the United States and other jurisdictions may classify certain Digital Assets as securities, commodities, derivatives, or other regulated instruments, potentially subjecting Gravitalix, its Clients, or its service providers to additional licensing, registration, disclosure, or conduct requirements. Regulatory Scrutiny of Digital Asset Lending, Staking, and Yield Programs. Regulators have taken, and may continue to take, enforcement actions or impose new rules with respect to digital asset lending, staking, and yield-generating programs. Such actions may: a) restrict or prohibit certain activities currently used by Gravitalix Yield Strategies; b) require modifications, suspensions, or wind-downs of existing strategies; c) impose additional disclosure, capital, or compliance obligations; or d) affect the ability of counterparties to operate or satisfy their obligations. 20  Gravitalix Financial, LLC Form ADV Part 2A Brochure These developments may adversely affect Client accounts, including through forced liquidations, reduced yields, losses of opportunity, or the inability to access or recover Digital Assets on anticipated terms. Jurisdictional and Eligibility Limitations. Due to regulatory, sanctions, tax, or other legal considerations, Gravitalix may limit or deny access to certain Digital Assets, strategies, or Yield Programs in particular jurisdictions or for certain types of Clients or accounts. Gravitalix may modify, restrict, or discontinue specific strategies at any time, including where continued operation could create undue legal, regulatory, or operational risk. Such limitations may result in Clients in different jurisdictions having different investment menus or outcomes. Tax Risk of Digital Asset Investments. There is substantial uncertainty regarding the tax treatment of Digital Assets. As such, Gravitalix may take certain tax positions that may ultimately be treated differently in the course of an audit by the U.S. Internal Revenue Service (“IRS”), or the regulations promulgated by the IRS may change over time. As a result, Investors may be subject to adverse tax consequences associated with their investment in Gravitalix. 5. Service Provider and Infrastructure Risk Exchange, Platform, and Service Provider Risk. Gravitalix relies on exchanges, trading venues, custodians, technology vendors, data providers, banks, and other third parties to implement its strategies. Failures, outages, mismanagement, fraud, or insolvency at any such service provider may result in losses, delays in trade execution or settlement, or the inability to access or move Digital Assets. Best Execution and Pricing Risk. Digital Asset markets may be fragmented, with varying liquidity and pricing across venues. Gravitalix seeks best execution but may not always obtain the best available price or execution outcome, particularly during periods of extreme volatility or limited liquidity. In addition, pricing data from different sources may diverge, which can affect valuations, fee calculations, and realized performance. Clients should carefully review this Risk Factors section together with the rest of this Brochure and consider their own financial situation, investment objectives, risk tolerance, and time horizon before investing with Gravitalix or electing to participate in any Gravitalix Yield Strategy. Clients should consult their own legal, tax, and financial advisers regarding the risks described above. Item 9 - Disciplinary Information Gravitalix is required to disclose all material facts regarding any legal or disciplinary events that would be material to an investor’s evaluation of Gravitalix or the integrity of its management. Gravitalix has no legal or disciplinary information to disclose. Item 10 - Other Financial Industry Activities and Affiliations Neither Gravitalix nor its employees are registered as, or have pending applications to become, 21  Gravitalix Financial, LLC Form ADV Part 2A Brochure a broker-dealer or broker-dealer representative. Neither Gravitalix nor its employees are registered as, or have pending applications to become, a futures commission merchant, commodity pool operator, commodity trading adviser, or an associated person of the foregoing entities. Digital Asset Trading and Lending Partners. Gravitalix has entered into one or more commercial arrangements with trading desks and exchanges, liquidity providers and other counterparties, including Nexo US LLC, Lido Protocol, and K3 Capital (hereinafter “Partners”), under which the Partners may act as trading or lending counterparties or service providers for specific Digital Asset strategies. Partners are not a “qualified custodians” for purposes of Rule 206(4)-2 under the Advisers Act with respect to Client assets held in SMAs, and Client Digital Assets are generally custodied with one or more unaffiliated Qualified Custodians, as described in Item 15. To facilitate trading, lending, or other program features, however, certain Client Digital Assets may be transferred from a Client’s account at a Qualified Custodian to Partners, or may be held in omnibus or program-level accounts controlled by some of the Partners. These arrangements create additional counterparty, credit, operational, and legal risks, including the risk that Partners may become insolvent, fail to return Digital Assets, or otherwise be unable or unwilling to honor their obligations. Gravitalix conducts initial and ongoing due diligence on all key service providers, but cannot guarantee their performance or financial condition. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Gravitalix maintains a Code of Ethics reasonably designed to help ensure we meet our fiduciary obligations to Clients and to detect and prevent violations of securities laws. Gravitalix’s Code of Ethics establishes standards of conduct for all officers and employees consistent with the code of ethics requirements of Rule 204A-1 under the Investment Advisers Act. For purposes of Gravitalix’s Code of Ethics, Gravitalix treats Digital Assets like traditional securities and therefore subjects employees to similar prohibitions and disclosures that would be required for other assets. A copy of Gravitalix’s Code of Ethics is available to Clients and prospective Clients upon request. Gravitalix or individuals associated with Gravitalix are permitted to buy or sell assets identical to, or different from, those recommended to Clients for their personal accounts. Individuals associated with Gravitalix may also be Clients. Additionally, any related person(s) could have an interest or position in certain Digital Assets which are also recommended to Clients. In such instances, Gravitalix or its related persons, may have a financial incentive to buy or sell such Digital Assets for Clients. Gravitalix endeavors to make decisions in the best interest of its Clients, and to eliminate, mitigate, and/or disclose material conflicts of interest that arise between Gravitalix and Clients. In order to monitor conflicts of interest, Gravitalix monitors non-discretionary transactions in the personal accounts of its employees and contractors designated as “Access Persons”, 22  Gravitalix Financial, LLC Form ADV Part 2A Brochure including investing in Digital Assets. An Access Person must disclose on an initial and annual basis the holdings of all personal investment accounts, as well as all transactions in such accounts on a quarterly basis. It is the express policy of Gravitalix that no person employed by Gravitalix use material, non- public information obtained during the course of their work in deciding whether to purchase or sell any asset prior to any pending transaction(s) being executed for an advisory account. This policy is intended to prevent employees from benefiting from transactions placed on behalf of advisory accounts. Item 12 - Brokerage Practices Gravitalix executes trades on behalf of its Clients through a number of service providers or the Qualified Custodian. These service providers may include third-party digital asset trading and lending platforms, which may act as over-the-counter (“OTC”) trading counterparties, liquidity providers, or lenders. In the future, Gravitalix may execute trades through Partners (referred to as a “Trading Partner”) that provides trading or technology services and fulfills orders through its network of third-party liquidity providers. Any such arrangement would be disclosed to Clients in advance in writing and would require Client consent to the extent required by applicable law. All such arrangements would be subject to Gravitalix's duty to seek best execution for Client transactions, and Gravitalix will periodically review the quality of execution to ensure that Clients are not disadvantaged by the use of an affiliated trading entity. Gravitalix may instruct Trading Partners to make trades on behalf of SMAs at the direction of the Client for Non-Discretionary SMAs and to update allocations to Discretionary SMAs or otherwise to further the investment objectives that Clients specify. Gravitalix permits each Client to transfer Digital Assets in-kind (through a blockchain transaction) to their SMA or to withdraw Digital Assets in-kind (through a blockchain transaction). Subject to Gravitalix’s trading policies, described in this section, Digital Asset orders initiated on any business day before 12pm EST may trade on the same business day. Trade settlement is T+1. However, in certain circumstances transactions may be subject to processing delays. For example, orders initiated on non-business days may not transact until the next business day, and if trading partners and liquidity providers elect to suspend trading in or delist a Digital Asset, such trades will generally not transact until sufficient liquidity for those Digital Assets is made available to Gravitalix. Gravitalix also reserves the right to postpone trades in order to modulate its overall trading volume on a particular business day. Further, account deposits are automatically subject to a processing period that could last up to three (3) business days or longer. Deposit-related transactions will not occur until the next business day after this processing period is complete. Gravitalix maintains a general approach of placing Digital Asset orders within traditional 23  Gravitalix Financial, LLC Form ADV Part 2A Brochure business hours (Monday to Friday, 9:00am to 5:00pm Eastern Time), and may not place orders on non- business days or after business hours. However, Gravitalix at all times reserves the right to determine in its discretion and without notice, whether to extend business hours, delay trading hours, or otherwise manage trading in Digital Assets for any reason including in response to market events. Such market events include but are not limited to market instability, instances of elevated localized volatility, insufficient or unstable market depth (i.e., illiquid markets), price dislocation, incomplete execution, fast markets, rapidly widening bid-ask spreads, and halted Digital Assets. For the avoidance of doubt, Gravitalix does not extend, delay or manage trading based on any view about whether markets are likely to rise or fall. Gravitalix does not attempt to time-the- market. In fulfilling its duties to its Clients, Gravitalix endeavors at all times to put the interests of its Clients first. Gravitalix maintains policies and procedures designed to ensure that client trades are executed in accordance with best execution obligations regardless of affiliate relationships. Gravitalix regularly evaluates its affiliates’ trading spreads to ensure that they are generally in line with the market rates of its major competitors; however, this economic relationship may create a conflict of interest since this relationship may influence Gravitalix’s choice of a Trading Partner over a competitor. Gravitalix manages this conflict through disclosures, policies and procedures to enable Clients to make informed decisions and through policies and procedures that require it to act in the Client’s best interests. Item 13 - Review of Accounts As part of all Gravitalix service offerings, Gravitalix’s SMAs are overseen by Gravitalix’s investment advisory personnel, supported by related software and algorithms to support and facilitate portfolio management. The Discretionary SMAs are regularly monitored to confirm they are within a range of the allocation of the desired weighting and investment strategy. SMA Clients receive monthly reporting identifying total assets under management, cash balances, unrealized gain/loss, pricing data, asset allocations, portfolio balances over time as well as recent transactions. Some Clients may have access to some of this data via the Client Portal. Discretionary SMA Clients are directed, on at least a quarterly basis, to review and update their investment preferences and may impose reasonable restrictions on the management of their accounts, subject to Gravitalix’s approval. Item 14 - Client Referrals and Other Compensation Gravitalix may offer compensation to Partners who recommend Gravitalix and refer new Clients to Gravitalix (each a “Referrer”). Clients are advised of such compensation prior to opening an account. Due to compensation from Gravitalix, Referrers may have an incentive to recommend Gravitalix, which is a conflict of interest. Clients are not charged any fee nor do Clients incur any additional costs for being referred to Gravitalix by a Referrer. 24  Gravitalix Financial, LLC Form ADV Part 2A Brochure All of the Firm’s Clients are introduced to Gravitalix through a third-party platform. The Firm does not provide compensation to a Referrer for these introductions, and no Referrer provides the Firm with any compensation, marketing support, or other economic benefits. Clients should be aware that the Firm’s relationship with a Referrer may create a potential conflict of interest because the Firm’s client base is dependent on the platform. The Firm seeks to mitigate this conflict by providing all advisory services in accordance with its fiduciary duty and in the best interests of each client. In addition, certain Gravitalix personnel are eligible for variable compensation based on Gravitalix’s growth. This compensation is based on firm-wide targets, individual targets, or both, which may create an incentive for such personnel to recommend Gravitalix's services. The marketing and solicitation activities of these individuals are supervised by Gravitalix in accordance with applicable rules, including Rule 206(4)-3 under the Advisers Act. All personnel engaged in solicitation activities on behalf of Gravitalix comply with applicable solicitation rules and provide required disclosures to prospective clients. Item 15 – Custody SMAs A. For SMAs, Client Digital Assets are held in custody with one or more unaffiliated qualified custodians (each, a “Qualified Custodian”). Gravitalix does not serve as a qualified custodian. The Qualified Custodian may utilize technology and digital asset wallet infrastructure provided by Fireblocks, Inc. (“Fireblocks”), a New York corporation and technology service provider for Digital Assets, under separate services agreements. In connection with certain trading or Yield Strategies, Gravitalix may instruct a Qualified Custodian to transfer Client Digital Assets to or from accounts held with Partners or counterparties. Fireblocks’ wallet technology seeks to reduce the risk of a single point of private key compromise by layering a cryptographic protocol called MPC-CMP, secure hardware enclaves, and a governance engine. Private key material for wallets used by the Qualified Custodian is split across multiple parties, which may include the Qualified Custodian, Fireblocks, Gravitalix, or other service providers, depending on the wallet configuration. Gravitalix will be deemed to have “custody” of certain Client Digital Assets for purposes of the Advisers Act custody rule because Gravitalix has the authority to take/compensate itself with such Digital Assets, for example, by deducting Platform Fees from a Client’s account or, in limited cases, by instructing the Qualified Custodian to transfer Digital Assets from a Client’s account in accordance with the Client’s standing written authorization. Some Digital Assets held by Clients are not “funds” or “securities” under the custody rule and therefore may not be subject to all of the protections applicable to funds and securities. As a fiduciary, Gravitalix takes steps reasonably designed to safeguard Client Digital Assets against loss or misappropriation, including the use of multi-party computation technology, 25  Gravitalix Financial, LLC Form ADV Part 2A Brochure including secure storage protocols, diligence and oversight of Qualified Custodians and other service providers, and insurance coverage where available. Clients should be aware, however, that Digital Assets present unique custody risks, technological vulnerabilities, cybersecurity threats, insolvency or operational risk at custodians or service providers, and the potential for permanent and total loss. Certain protections applicable to traditional securities (such as SIPC coverage) do not apply to Digital Assets. Clients will receive account statements directly from the applicable Qualified Custodian at least quarterly, showing all holdings and transactions in their SMA. Gravitalix also provides Clients with online access to account information and periodic statements through the Gravitalix client portal (the “Client Portal”). These Gravitalix reports may differ from the Qualified Custodian’s statements due to timing or valuation methods and should be considered supplemental. We urge Clients to carefully review the statements they receive from the Qualified Custodian and to compare them to any account information or reports provided by Gravitalix. Item 16 - Investment Discretion Gravitalix has discretionary management authority only over Discretionary SMAs for Clients that have signed Advisory Agreements permitting certain discretionary services. For Discretionary SMAs, Gravitalix has authority under the Advisory Agreement to direct Trading Partners and the Qualified Custodian to buy and sell Digital Assets and to invest Digital Assets into various Gravitalix Yield Strategies or other custom strategies on a Client’s behalf when Gravitalix determines it is appropriate in accordance with the Client's investment objectives and risk tolerance, including in connection with rebalancing. Each Client makes their own decision whether to invest in a Gravitalix Yield Strategy. Gravitalix trades or invests in response to Client actions (such as deposits or withdrawals, allocation changes, or elections to exclude certain assets from the Client’s account), to rebalance the Client’s portfolio or to otherwise further the Client’s investment goals. Clients can request a Non-Discretionary SMA. For Non-Discretionary SMAs, Gravitalix will only execute transactions or take other actions when specifically instructed by the Client in writing or through other agreed-upon communication methods as specified in the Advisory Agreement. Gravitalix may provide investment recommendations, but the Client retains sole authority to accept or reject such recommendations. Item 17 - Voting Client Securities While SMAs do not hold securities with voting rights attached, some Digital Assets may feature the ability to participate in governance activities including the ability to vote on topics that directly or indirectly affect return on investment through on-chain governance, Gravitalix’s infrastructure does not support this capability and makes no promise of doing so in the future. As such, Clients are currently unable to participate in such governance activities for Digital Assets held in SMAs. 26  Gravitalix Financial, LLC Form ADV Part 2A Brochure Item 18 - Financial Information Gravitalix does not require or solicit prepayment of more than one thousand two hundred USD ($1,200) in advisory fees per Client, six (6) months or more in advance. Therefore, Gravitalix is not required to include a financial statement. Gravitalix has discretionary authority to manage Client assets. To the best of Gravitalix’s knowledge, Gravitalix is not aware of any financial condition that is reasonably likely to impair Gravitalix’s ability to meet its contractual commitments to Clients. Gravitalix has not been the subject of a bankruptcy petition at any time during the past ten (10) years. 27