Greenspring Advisors, LLC

Part 2A of Form ADV: Firm Brochure Greenspring Advisors, LLC One West Pennsylvania Avenue, Suite 500 Towson, MD 21204 Telephone: 443-564-4600 Web Addresses: www.greenspringadvisors.com 03/23/2026 This brochure provides information about the qualifications and business practices of Greenspring Advisors. If you have any questions about the contents of this brochure, please contact us at 443-564-4600 or Aaron Tawil, Chief Compliance Officer, aaron.tawil@greenspringadvisors.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 Greenspring Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 132669.  Item 2 Material Changes This Firm Brochure provides you with a summary of Greenspring Advisors’ advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This Item is used to provide our clients with a summary of new and/or updated information; we will inform of the revision(s) based on the nature of the information as follows. Material Changes: Should a material change in our operations occur, depending on its nature, we will promptly communicate this change to clients (and it will be summarized in this Item). "Material changes" requiring prompt notification will include changes of ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates – any information that is critical to a client’s full understanding of who we are, how to find us, and how we do business. Material Change since last filed ADV amendment on March 20, 2025: 1. Item 4 - Greenspring Advisors, LLC ownership structure changed based on the following: a. The merger with Wealthstream Advisors, Inc. on October 1, 2025. b. The transfer of ownership in Greenspring Advisors, Inc from ISI Financial, Inc. to Timothy Decker, a direct owner of Greenspring Advisors, LLC. c. Greenspring Equity Holdings, LLC was formed on January 1, 2026. 2  Item 3 Table of Contents Material Changes Item 2 2 Table of Contents Item 3 3 Advisory Business Item 4 4 Fees and Compensation Item 5 16 Performance-Based Fees and Side-By-Side Management Item 6 20 Types of Clients Item 7 21 Methods of Analysis, Investment Strategies, and Risk of Loss Item 8 22 Disciplinary Information Item 9 26 Item 10 Other Financial Industry Activities and Affiliations 27 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 28 Item 12 Brokerage Practices 30 Item 13 Review of Accounts 33 Item 14 Client Referrals and Other Compensation 34 Item 15 Custody 35 Investment Discretion Item 16 36 Item 17 Voting Client Securities 37 Financial Information Item 18 38 3  Item 4 Advisory Business Greenspring Advisors, LLC is a SEC-registered investment adviser with its principal place of business located in Maryland. Greenspring Advisors began conducting business in 2004. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). Greenspring Advisors, LLC is owned by: • Greenspring Equity Holdings, LLC (39.9%) • Greenspring Wealth Management, Inc (31.6%) • Wealthstream Holdings, Inc (28.50%). John Patrick Collins, Jr., Controls 26.2% of Greenspring Advisors, LLC. There are 26 other individuals who control 73.8% of the Greenspring Advisors, LLC. Greenspring Advisors offers the following advisory services to our clients: PRIVATE MONEY MANAGEMENT SERVICES Our firm provides continuous advice to a client (individuals and trusts, estates, non-profit organizations, and charitable organizations) regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, in certain circumstances, we may develop a personal investment policy for a client and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (e.g., conservative, moderate, balanced, growth, aggressive), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and will generally include advice regarding the following securities: • • • • • • Exchange-listed securities Securities traded over the counter Foreign issuers Corporate debt securities (other than commercial paper) Commercial paper Certificates of deposit 4  • • • • • • • • Municipal securities Variable life insurance Variable annuities Mutual fund shares United States governmental securities Options contracts on securities Interests in partnerships investing in real estate. Closed-end non-diversified company operating as a business development company (BDC) Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Cash Balances Some of your assets may be held as cash and remain uninvested. Holding a portion of your assets in cash and cash alternatives, i.e., money market fund shares, may be based on your desire to have an allocation to cash as an asset class, to support a phased market entrance strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to pay fees or to provide for asset protection during periods of volatile market conditions. Your cash and cash equivalents will be subject to our investment advisory fees unless otherwise agreed upon. You may experience negative performance on the cash portion of your portfolio if the investment advisory fees charged are higher than the returns you receive from your cash. Retirement Rollovers- Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Greenspring recommends that a client roll over their retirement plan assets into an account to be managed by Greenspring, such a recommendation creates a conflict of interest if Greenspring will earn an advisory fee on the rolled-over assets. No client is under any obligation to rollover retirement plan assets to an account managed by Greenspring. Greenspring Advisory team remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Retirement Plan Rollover Recommendations As part of our investment advisory services to our clients, we may recommend that clients roll assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP 5  IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge the client an asset-based fee as set forth in the advisory agreement the client executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to the client (i.e., receipt of additional fee-based compensation). Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the rollover, they are under no obligation to have the assets in an IRA advised on by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in our clients’ best interests and not put our interests ahead of our clients’. Under this special rule’s provisions, we must: • • financial interests ahead of our clients’ when making • • • • Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in our clients’ best interests; Charge no more than a reasonable fee for our services; and Give clients basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, clients should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. 2. 3. 4. leaving the funds in the employer’s (former employer’s) plan; moving the funds to a new employer’s retirement plan; cashing out and taking a taxable distribution from the plan; or rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide clients with an explanation of the advantages and disadvantages of both account types and document the basis for our belief that the rollover transaction we recommend is in your best interests. 6  Mutual Fund Share Class Selection Process Some client accounts may hold shares of investment companies, including money market funds, closed-end funds, and/or exchange-traded funds (Funds). Those funds have their own expenses, including certain advisory, distribution, or other fees, and a client account invested in those funds will indirectly bear a portion of those expenses. Each of the fees discussed above is in addition to Greenspring’s management fee. Greenspring uses its best efforts to purchase the lowest available fund shares, but in certain instances cannot because a lower share class may not be available from the fund company. Funds generally offer multiple share classes available for investment based upon certain eligibility and/or purchase requirements. For instance, in addition to retail share classes (typically referred to as class A, class B and class C shares), funds may also offer institutional share classes or other share classes that are specifically designed for purchase by investors who meet certain specified eligibility criteria, including, for example, whether an account meets certain minimum dollar amount thresholds or is enrolled in an eligible fee-based investment advisory program. Institutional share classes usually have a lower expense ratio than other share classes. The Firm conducts periodic reviews of client holdings in mutual fund investments to ensure the appropriateness of mutual fund share class selections and whether alternative mutual fund share class selections are available that might be more appropriate given the client’s particularized investment objectives and any other appropriate considerations relevant to mutual fund share class selection. COMPREHENSIVE WEALTH MANAGEMENT SERVICES Our firm also provides Comprehensive Wealth Management Services to clients, which include all of the services listed for Private Money Management clients, plus certain financial planning services, which may involve tax planning, retirement planning, risk management analysis, estate planning, cash flow planning, business planning, and/or education planning. FINANCIAL PLANNING Greenspring provides financial planning as part of the comprehensive wealth management services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. Through the financial planning process, certain questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. As part of the financial planning service, clients receive a written report which provides the client with a detailed financial plan designed to assist the client in achieving his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas: 7  PERSONAL: We may review family records, budgeting, personal liability, estate information, and financial goals. TAX & CASH FLOW: We may analyze the client’s income tax and spending and planning for past, current, and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. INVESTMENTS: We may analyze investment alternatives and their effect on the client's portfolio. INSURANCE: We may review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. RETIREMENT: We may analyze current strategies and investment plans to help the client achieve his or her retirement goals. DEATH & DISABILITY: We may review the client’s cash needs at death, income needs of surviving dependents, estate planning, and disability income. ESTATE: We may assist the client in assessing and developing long-term strategies, including, as appropriate; living trusts, wills, reviewing estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. We gather the required information through personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives and attitudes towards risk. We review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. FINANCIAL CONSULTING SERVICES Clients can also receive investment and financial consulting advice on a more focused basis. This may include advice on only an isolated area(s) of concern, such as estate planning, 8  retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. SELECTION OF OTHER ADVISORS Greenspring may direct clients to third-party money managers. Other than the advisory fee we bill on the clients' assets, Greenspring does not earn additional compensation from the third- party money manager that it directs clients to. Before selecting a third-party money manager for clients, Greenspring will always ensure that those other advisors are properly licensed or registered as an investment advisor. RETIREMENT PLAN CONSULTING SERVICES We also provide several advisory services separately or in combination. The primary clients for these services will be the sponsors of pension, profit-sharing, 403(b), and 401(k) plans. Retirement Plan Consulting Services are generally comprised of fiduciary services and non- fiduciary services at both the plan level and participant level. With regard to fiduciary services, we provide clients (i.e., Plan Sponsors) with plan-level non-discretionary investment advice services, plan-level discretionary investment management services under Section 3(38) of ERISA, participant-level discretionary investment management services under Section 3(38) of ERISA, and participant-level non-discretionary investment advice services. With regard to non-fiduciary services, we provide plan-level services and participant-level services. Clients (i.e., Plan Sponsors) may choose to use any or all of the services described below, with the exception of choosing to use either plan-level non-discretionary investment advice services or plan-level discretionary investment management services under Section 3(38) of ERISA, as determined by the scope of the engagement. The Company manages a Pooled Employer Plan (“PEP”) called The (k)larity Plan™. This program consists of two parts directed at Participants: 1) Nondiscretionary investment advice and investment education. First, Greenspring provides non-discretionary investment advice to Participants as an ERISA 3(21) fiduciary about the allocation of their Plan accounts using the existing fund options in the Plan, which constitute the Plan’s designated investment alternatives (DIAs) (but not on investments outside the Plan). Participants have the final decision-making authority regarding the allocation of a Participant’s 401(k) account among the asset classes represented by the DIAs and regarding the selection of the DIAs for the allocations. In addition to access to (k)larity @ Work via internet platform, participants will have access to in-person investment advice. These fiduciary services are “point-in-time” investment advice. As such, the advice will be based on the Participant’s goals and circumstances known to Greenspring when the advice is given. However, Greenspring does not monitor the arrangement to determine 9  if, among other things: a. The Participant implemented the advice; b. The Participant’s goals and circumstances have changed; or c. A different recommendation would have been made based on then current information. Instead, if the Participant desires additional or updated advice, the Participant must request it through one or two methods described above. 2) Education and Communication - Greenspring provides access to educational content, including but not limited to articles, videos, webinars, newsletters, posts, and courses. Information provided may include a description of investment alternatives (along with the objectives and risk and return characteristics of the assets comprising the investment portfolio), hypothetical asset allocation models, or other general financial and investment concepts consistent with the Department of Labor’s interpretation of financial and investment education in Interpretive Bulletin 96-1. Such services, referred to as the Non-Fiduciary Services, include: • On-demand access to one-on-one financial counseling services from a Certified Financial Planner (CFP®) via a 1-800 hotline; • Access to (k)larity @ Work™, (Greenspring’s proprietary internet platform) for financial wellness services; • Education in the form of articles, videos, posts, webinars, newsletters, etc. via (k)larity @ Work™ • Access to web-based financial planning and budgeting software. This is an add- on service for which the Firm provides the participant access to the software, but the cost is borne by the participant ; • Basic counseling services related to questions about retirement planning, saving, budgeting, and debt management, tax planning (but no tax advice), risk management/insurance, estate planning, education planning, government benefits, etc.; and • Basic counseling services to help employees understand existing company benefits (e.g., HSA, LTD/STD, group life, etc.). FIDUCIARY SERVICES I. PLAN-LEVEL NON-DISCRETIONARY INVESTMENT ADVICE SERVICES a. Investment Policy Design - Greenspring will assist the Client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan and shall set forth the number of general investment options and asset class categories to be offered under the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. b. Investment Selection - Greenspring will provide non-discretionary investment advice to Client about asset classes and investment alternatives available for the 10  Plan in accordance with the Plan’s investment policies and objectives. Greenspring will utilize multiple analytic tools and databases at its disposal. Client shall have the final decision-making authority regarding the initial selection, retention, removal, and addition of investment options. c. ERISA 404(c) Investment Selection – Greenspring will assist Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. Client shall have the final decision-making authority regarding the selection of investment options. Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c). d. Investment Monitoring - Greenspring will assist the Client in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management, and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove, or replace investment options. Greenspring will meet with the Client in person, telephonically, or by electronic means at least annually to discuss the reports and the investment recommendations. The client has the authority and will be solely responsible for the actual selection or replacement of investment options. e. Selection of QDIA - Greenspring will provide non-discretionary investment advice to the Client with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. Client shall have the final decision-making authority regarding the selection of the QDIA, and the Client retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5). II. PLAN-LEVEL DISCRETIONARY INVESTMENT MANAGEMENT SERVICES UNDER SECTION 3(38) OF ERISA a. Investment Policy Design - Greenspring will develop an investment policy statement (IPS) for the Client. The IPS establishes the investment policies and objectives for the Plan and shall set forth the number of general investment options and asset class categories to be offered under the Plan. Greenspring shall have the ultimate responsibility and authority to develop the IPS and shall have the sole authority to amend it. b. Investment Selection - Greenspring will provide discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Greenspring will utilize multiple analytic tools and databases at its disposal and will have decision- making authority regarding the initial selection, retention, removal, and addition of investment options. c. ERISA 404(c) Investment Selection – Greenspring will select a broad range of investment options consistent with ERISA Section 404(c) and the regulations 11  thereunder. The client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c). d. Investment Monitoring - Greenspring will monitor investment options by preparing periodic investment reports that document investment performance, consistency of fund management, and conformance to the guidelines set forth in the IPS and determine whether to maintain or remove and replace investment options. e. Selection of QDIA - Greenspring will consult with Client as to whether the Plan should have a qualified default investment alternative (“QDIA”) for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election and as to the type of investment to serve as a QDIA (e.g., target date fund, balanced fund, or managed account). If the client decides to have a QDIA under the plan and decides upon the type of investment that will serve as a QDIA, Greenspring will select the investment to serve as the QDIA. Client retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5). III. PARTICIPANT-LEVEL NON-DISCRETIONARY INVESTMENT ADVICE SERVICES a. Investment Selection - Nondiscretionary investment advice, Greenspring provides non-discretionary investment advice to Participants as an ERISA 3(21) fiduciary about the allocation of their Plan accounts using the existing fund options in the Plan, which constitute the Plan’s designated investment alternatives (DIAs) (but not on investments outside the Plan). Participants have the final decision-making authority regarding the allocation of a Participant’s 401(k) account among the asset classes represented by the DIAs and regarding the selection of the DIAs for the allocations. In addition to access to (k)larity @ Work via internet platform, participants will have access to in-person investment advice. NON-FIDUCIARY SERVICES I. PLAN-LEVEL SERVICES a. Committee Formation, Education and Support - Greenspring will help the Client establish or refine a committee as needed. On a periodic basis, Greenspring will educate Plan fiduciaries on their duties and responsibilities and how to manage them as well as providing legislative and regulatory updates as necessary. Education will include general training regarding the fiduciary duty and prohibited transaction provisions of ERISA, as well as the importance of the documents and instruments governing the Plan. Greenspring will periodically meet with the Client to review and discuss various aspects of the Plan, which may include preparation of meeting deliverables for the Client. b. Fee Analysis, Benchmarking, and Negotiation – Greenspring will periodically assist the Client in evaluating the reasonableness of Plan fees. This may include 12  documenting and benchmarking both direct and indirect fees (e.g., revenue sharing payments) to help the Client understand what the Plan is paying and how it compares to other plans and products. Greenspring may also recommend specific steps that can be taken to reduce those fees, if applicable. When appropriate, Greenspring will assist the Client in negotiating fee arrangements and cost structures. c. Vendor Benchmarking, Search and Selection - Greenspring will periodically assist the Client by providing an analysis and comparison of the Plan’s current vendor(s) products, services, and pricing to other plans and service providers. d. Plan Conversion Services - As needed, Greenspring will assist the Client with the conversion to a new provider’s platform. e. Operational Assistance and Issue Resolution - As needed, Greenspring will assist the Client with resolving operational or administrative issues that may arise with the Plan. Greenspring may provide these services or, alternatively, may arrange for the Plan’s other providers to provide these services, as agreed upon between Greenspring and the Client. II. Participant Level Services a. Participant Education and Communication- Greenspring provides access to educational content, including but not limited to articles, videos, webinars, newsletters, posts, and courses. Information provided may include a description of investment alternatives (along with the objectives and risk and return characteristics of the assets comprising the investment portfolio), hypothetical asset allocation models, or other general financial and investment concepts consistent with the Department of Labor’s interpretation of financial and investment education in Interpretive Bulletin 96-1. Potential Additional Retirement Services Provided Outside of the Retirement Plan Agreement We and our IARs, in the course of providing Retirement Plan Services or otherwise, may establish a client relationship with one or more plan participants or beneficiaries. Such client relationships develop in various ways, including, without limitation: • as a result of a decision by the plan participant or beneficiary to purchase services from us not involving the use of plan assets; • • as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relating to assets held outside of a plan; or through a rollover of an Individual Retirement Account ("IRA Rollover"). In providing these optional services, we may offer employers and employees information about other financial and retirement products or services we and our 13  IARs offer. If we are providing Retirement Plan Services to a plan, IARs may, upon a participant’s or beneficiary's request, arrange to provide services to that participant or beneficiary through a separate agreement. These services are described as part of the Comprehensive Wealth management services. 14  ASSETS UNDER MANAGEMENT As of December 31, 2025, Greenspring managed: $6,453,466,936 on a discretionary basis $10,910,753 on a non-discretionary basis. • • Additionally, Greenspring managed $4,085,360,940 in assets under advisement. 15  Item 5 Fees and Compensation WEALTH MANAGEMENT FEES The annualized fee for Wealth Management Services will be charged as a percentage of assets under management, according to the schedule detailed in the client agreement, not to exceed 1.35% annually of the assets under management. Based on the fee described above, a minimum annual fee of $5,000 is required for Wealth Management Services. The minimum fee charged for Wealth Management Services may be higher than $5,000 for certain office locations of Greenspring. If a client's assets under management are not sufficient to generate the minimum annual fee, they have the option of paying the difference (until their assets are sufficient) to receive the desired level of service. For instance, if a client desires to receive Wealth Management Services and their assets generate an annualized fee of $4,000, they have the option of paying the difference (i.e., an additional $1,000) to reach the minimum annual fee of $5,000 until the assets under management are sufficient to generate the minimum annual fee. Fees are paid by check, wire, ACH, or directly billed from the client's account. Limited Negotiability of Advisory Fees: Although Greenspring Advisors has established the aforementioned fee schedule(s), we retain the discretion to negotiate lower fees on a client- by-client basis. Client facts, circumstances, and needs will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, reports, and other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Discounts, not generally available to our advisory clients, may be offered to family members and associated persons of our firm. Fees for Management During Partial Quarters of Service For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement between Greenspring and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Greenspring’s fees are prorated through the date of termination, and any remaining balance is refunded to the client. For clients billed in advance, if assets are deposited into or withdrawn from an account after the inception of a quarter that exceed $10,000 in the aggregate during a quarter, the fee payable with respect to such assets will be prorated based on the number of days remaining in the quarter. Advisory Fee Disclaimer: Lower fees for comparable services may be available from other sources. Administrative Fees: Greenspring may provide administrative services to clients who hold 16  security positions that are not included in model portfolios, such as concentrated stock positions, treasuries, and cash equivalents needed for short-term liquidity needs. The fee for these services is 0.10%. FINANCIAL PLANNING FEES Greenspring Advisors’ Financial Planning fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Our Financial Planning fees are calculated and charged on a fixed fee basis, typically ranging from $2,000 to $150,000, depending on the specific arrangement reached with the client. Alternatively, our Financial Planning fees may be calculated and charged on an hourly basis, ranging from $150 to $750 per hour. Although the length of time it will take to provide a Financial Plan will depend on each client's personal situation, we will provide an estimate for the total hours at the start of the advisory relationship. We require one-half of the negotiated financial planning fee to be paid at the outset of the engagement, with the balance due upon completion of the plan. Fees paid in advance will never be more than six months in advance. Fees that are charged in advance will be refunded based on the prorated amount of work completed at the point of termination. Financial Planning Fee Offset: Greenspring Advisors reserves the discretion to reduce or waive the hourly fee and/or the minimum fixed fee if a financial planning client chooses to engage us for our Private Money Management or Comprehensive Wealth Management Services. The client will be billed quarterly in advance based on our total estimated Financial Planning fees. The client will be billed quarterly in arrears based on actual hours accrued. RETIREMENT PLAN CONSULTING FEES Our fees for Retirement Plan Consulting Services are based on a percentage of assets under advisement and services provided to the client and plan participants, as detailed in the client agreement, and generally do not exceed 0.50% annually of the assets under advisement. Alternatively, we may charge an annual fee for Retirement Plan Consulting Services, which generally ranges from $20,000 to $100,000, depending on the services requested and the size of the plan. Plan sponsors are invoiced in advance at the beginning of each calendar quarter, unless their retirement plan provider's billing system requires billing to occur in arrears. There are two ways 17  that a Plan might pay our fee. Employer Pays: An Employer may pay our fee, paying it from the Employer’s money without using the Plan’s assets. Plan Pays: - A Plan may pay our fee. To do so, the Plan’s Named Fiduciary or Trustee must have and use a power to pay us, or to instruct a corporate directed trustee or insurer to pay us. If the Plan pays our fee, the Named Fiduciary or Trustee decides how to allocate that expense among the Plan’s accounts, which may include Participants’ Plan Accounts. A total minimum annual fee of $10,000 is generally required, although exceptions may be granted to this minimum at the discretion of Greenspring. This minimum fee may prevent Greenspring Advisors from providing services to very small ERISA plans. Limited Negotiability of Advisory Fees: Although Greenspring Advisors has established the aforementioned fee schedule(s), we retain the discretion to negotiate lower fees on a client- by-client basis. Client facts, circumstances, and needs will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, reports, and other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Termination and Refunds: Unless the plan provider requires advisory fees to be paid in arrears, all advisory fees are billed on a quarterly basis in advance. If services are terminated mid-billing period, charges will be prorated based on the number of days that services were provided prior to receipt of notice of termination. The unearned portion of the fee based on the above proration will be refunded to the client for fees billed in advance. Advisory Fee Disclaimer: Lower fees for comparable services may be available from other sources. INSTITUTIONAL INVESTMENT CONSULTING The annualized fee for Institutional Investment Consulting Services will be charged either a flat fee, flat fee with COLA (cost of living adjustment), flat fee and an asset-based charge, or as a percentage of assets under management, according to the schedule detailed in the client agreement. A minimum annual fee of $10,000 is generally required for Institutional Investment Consulting Services, although exceptions may be granted to this minimum at the discretion of Greenspring. If a client's assets under management are not sufficient to generate the minimum annual fee, they have the option of paying the difference (until their assets are sufficient) to receive the desired level of service. 18  Limited Negotiability of Advisory Fees: Although Greenspring Advisors has established the aforementioned fee schedule(s), we retain the discretion to negotiate lower fees on a client- by-client basis. Client facts, circumstances, and needs will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Discounts, not generally available to our advisory clients, may be offered to family members and associated persons of our firm. Termination and Refunds: All advisory fees are billed quarterly, either in advance or arrears. If services are terminated mid-billing period for fees billed in advance, charges will be prorated based on the number of days that services were provided prior to receipt of notice of termination. The unearned portion of the fee based on the above proration will be refunded to the client. Advisory Fee Disclaimer: Lower fees for comparable services may be available from other sources. The 3(38) fees are charged as a flat fee with COLA or an Annual Percentage Fee generally PLAN-LEVEL DISCRETIONARY INVESTMENT MANAGEMENT SERVICES UNDER SECTION 3(38) OF ERISA Fees (1) based on the following tiered schedule: • • • 0.05% on the first $100 million of Included Assets, 0.03% on assets between $100 million and $250 million, and 0.01% on assets exceeding $250 million. The fee for any calendar quarter will be based on the market value of the Included Assets as of the last business day of the previous quarter (without adjustment for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distributions of assets). Fees are billed quarterly in arrears. The initial quarterly fee will be prorated for the number of months in which Greenspring provides services during the initial quarter, based on the market value of the Included Assets as of the last business day of the prior month. “Market value of Included Assets” refers to the value of Included Assets as reported by the custodian. 19  Item 6 Performance-Based Fees and Side-By-Side Management Greenspring Advisors does not charge performance-based fees. As a matter of policy and practice, Greenspring does not generally aggregate client trades to execute a block trade and, therefore, will typically implement client transactions separately for each account. Due to this practice, certain client trades may be executed before others and, depending on the type of security traded, may be executed at a different price and/or commission rate. Additionally, Greenspring clients may not receive volume discounts, which may be available to advisers that block client trades. 20  Item 7 Types of Clients Greenspring Advisors provides advisory services to the following types of clients: • • • • Individuals (other than high-net-worth individuals) High net worth individuals Trusts, estates, non-profit, and/or charitable organizations Corporations or other businesses not listed above o Retirement Plan Services to clients that are sponsors or other fiduciaries to plans, including 401(k), 457(b), 403(b), and 401(a) plans. Our firm also provides services to plan participants. Plans include participant-directed defined contribution plans and defined benefit plans. Plans may or may not be subject to ERISA. As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please review the disclosures provided in each applicable service. 21  Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market, regardless of the economic and financial factors considered in evaluating the stock. Quantitative Analysis. We use mathematical models in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share, and predict changes to that data. A risk of using quantitative analysis is that the models may be based on assumptions that prove incorrect. Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement, and predict changes to share price based on that data. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their 22  stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Third-Party Money Manager Analysis. We examine the experience, expertise, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we may survey the manager’s compliance and business enterprise risks. A risk of investing with a third-party manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the manager’s daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when: • • We believe the securities to be currently undervalued, and/or We want exposure to a particular asset class over time, regardless of the current 23  projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Risk of Loss. Securities investments are not guaranteed, and you may lose money on your investments. We ask that you work with us to help us understand your tolerance for risk. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Although we manage assets in a manner consistent with your investment objectives and risk tolerance, there can be no guarantee that our efforts will be successful. You should be prepared to bear the following risks of loss: • • • • • • • • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar next year will not buy as much as a dollar today, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed-income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties (i.e., non-traded REITs) and other alternative investments (private credit vehicles) have limited available liquidity. Financial Risk: Excessive borrowing to finance a business’s operations increases 24  • • • • the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Cybersecurity Risk: A breach in cybersecurity refers to both intentional and unintentional events that may cause an account to lose proprietary information, suffer data corruption, or lose operational capacity. This, in turn, could cause an account to incur regulatory penalties, reputational damage, and additional compliance costs associated with corrective measures, and/or financial loss. Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. Custodial Risk: This risk is the probability that a party to a transaction will be unable or unwilling to fulfill its contractual obligations due to technological errors, control failures, malfeasance, or potential regulatory liabilities. Alternative Investment Risk: Alternative investments involve a substantially higher degree of risk and are more speculative in nature than an investment in public (market-traded) securities. Consequently, they are not appropriate for all investors. You may lose all or substantially all of the funds you choose to invest. Alternative investments may have limited availability of liquidity and may not be suitable for investors who have immediate liquidity needs. Alternative investment mark-to-market of the position value may fluctuate from the immediately available price when attempting to liquidate the position. 25  Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. 26  Item 10 Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Greenspring nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither Greenspring nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor, or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Greenspring has no registration relationships to our advisory business that create conflicts of interest. D. Selection of Other Advisors or Managers and How This Advisor is Compensated for Those Selections Greenspring may direct clients to third-party money managers. Greenspring is not compensated by the advisors to whom it directs those clients, although our advisory fees will be billed against these assets. Before selecting other advisors for clients, Greenspring will always ensure that those other advisors are properly licensed or registered as investment advisors. Since our founding, Greenspring has aspired to give back by making meaningful financial and relational investments in our local communities. To further our stewardship efforts and commitment to charitable giving, Greenspring has a grant program where employees of the firm serve on a committee to determine grant awards. 27  Code of Ethics, Participation or Interest in Client Transactions Item 11 and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct for our employees, including compliance with applicable federal securities laws. Greenspring Advisors and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports, as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement, and recordkeeping provisions. Greenspring Advisors’ Code of Ethics further includes the firm's policy prohibiting the use of material non- public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. request a A copy of our Code of Ethics is available to our advisory clients and prospective clients. You copy by emailing Aaron Tawil, Chief Compliance Officer, may aaron.tawil@greenspringadvisors.com. Greenspring Advisors and individuals associated with our firm are prohibited from engaging in principal transactions. Greenspring Advisors and individuals associated with our firm are prohibited from engaging in agency cross transactions. Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security or securities, which may also be recommended to a client. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, thereby preventing such employee(s) from benefiting from transactions placed on behalf of advisory 28  accounts. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. This prevents such employees from benefiting from transactions placed on behalf of advisory accounts. 4. Our firm requires prior approval for any IPO or private placement investments by related persons of the firm. 5. We maintain a list of all reportable securities holdings for our firm and anyone associated with this advisory practice who has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or his/her designee. 6. We have established procedures for the maintenance of all required books and records. 7. Clients can decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. 8. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 9. We require delivery and acknowledgement of the Code of Ethics by each supervised person of our firm. 10. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 11. Any individual who violates any of the above restrictions may be subject to termination. 29  Item 12 Brokerage Practices Private Clients Business: I. For discretionary clients, Greenspring Advisors requires these clients to provide us with written authority to determine the broker-dealer to use and the commission costs that will be charged to these clients for these transactions. As a matter of policy and practice, Greenspring does not generally aggregate client trades to execute block trades and, therefore, will typically implement client transactions separately for each account. Due to this practice, certain client trades may be executed before others and, depending on the type of security traded, may be executed at a different price and/or commission rate. Additionally, Greenspring clients may not receive volume discounts, which may be available to advisers who block client trades. Greenspring generally recommends that investment management accounts be maintained at Fidelity or Schwab. Prior to engaging Greenspring to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with Greenspring setting forth the terms and conditions under which Greenspring shall manage the client’s assets, and a separate custodial/clearing agreement with each designated broker- dealer/ custodian. Factors that the Greenspring considers in recommending Fidelity or Schwab (or any other broker- dealer/custodian to clients) include historical relationship with Greenspring, financial strength, reputation, execution capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid by Greenspring’s clients shall comply with Greenspring’s duty to obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might charge to affect the same transaction where Greenspring determines, in good faith, that the commission/transaction fee is reasonable. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including, but not limited to, the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although Greenspring will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are exclusive of, and in addition to, Greenspring’s investment management fee. Greenspring’s best execution responsibility is qualified if securities that it purchases for client accounts are mutual funds that trade at net asset value as determined at the daily market close. 30  Research and Additional Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Greenspring may receive from Fidelity or Schwab (or another broker-dealer/custodian, investment platform, and/or mutual fund sponsor) without cost (and/or at a discount) support services and/or products, certain of which assist the Greenspring to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by Greenspring may be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Greenspring in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products that may be received may assist Greenspring in managing and administering client accounts. Others do not directly provide such assistance but rather assist Greenspring to manage and further develop its business enterprise. Greenspring’s clients do not pay more for investment transactions effected and/or assets maintained at, Fidelity or Schwab as a result of this arrangement. There is no corresponding commitment made by Greenspring to Fidelity, Schwab, or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as a result of the above arrangement. Institutional Client Business: ii. Greenspring works with many different vendors in the retirement plan industry to serve the needs of our clients. There is no direct link between our firm's relationship with these vendors and the advisory services we provide to our clients, although we may receive economic benefits through these relationships that may not otherwise be available. These benefits include the following products and services (provided without cost or at a discount): research-related products and tools; consulting services; access to an electronic communications network for client account information; and discounts on compliance, marketing, research, technology, and practice management products or services provided to Greenspring by third-party vendors. These vendors may also pay for business consulting and professional services received by Greenspring’s related persons. The receipt of economic benefits by our related persons or us creates a conflict of interest and could influence our choice for custody, record keeping, administration, and brokerage services. These vendors may also pay or reimburse expenses (including travel, lodging, meals, and entertainment expenses) for Greenspring’s personnel to attend conferences or meetings 31  relating to their services. Some of the products and services made available by these vendors may benefit Greenspring, but may not benefit our client accounts. These products or services may assist us in managing and administering client accounts. Other services offered by these vendors are intended to help us manage and further develop our business. The benefits received by Greenspring or our personnel do not depend on the amount of business directed to these vendors. Clients should be aware, however, that the receipt of economic benefits by Greenspring Advisors or our related persons in and of itself creates a potential conflict of interest and may indirectly influence our choice or recommendation of these vendors for retirement plan provider services. Greenspring’s Chief Compliance Officer, Aaron Tawil, remains available to address any questions that a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. 32  Item 13 Review of Accounts PRIVATE MONEY MANAGEMENT AND COMPREHENSIVE WEALTH MANAGEMENT SERVICES REVIEWS: While the underlying securities within Private Money Management and Comprehensive Wealth Management Services accounts are continually monitored, these accounts are generally reviewed at least quarterly, but no less than annually. Accounts are reviewed by advisors in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances or the market, political, or economic environment. REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive from their broker-dealer, we will provide online access to quarterly reports summarizing account performance, balances, and holdings. RETIREMENT PLAN CONSULTING SERVICES REVIEWS: Greenspring Advisors will review the client's Investment Policy Statement (IPS) whenever the client advises us of a change in circumstances regarding the needs of the plan. Greenspring Advisors will also review the investment options of the plan according to the agreed-upon time intervals established in the IPS. Such reviews are conducted by advisors and will generally occur quarterly, but no less than annually. REPORTS: Greenspring Advisors will provide reports to Retirement Plan Consulting Services clients based on the terms set forth in the client's Investment Policy Statement (IPS). FINANCIAL PLANNING SERVICES REVIEWS: While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically, no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. REPORTS: Financial Planning clients will receive a completed financial plan. Additional reports will not typically be provided unless otherwise contracted for. 33  Item 14 Client Referrals and Other Compensation Greenspring does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to Greenspring clients. 34  Item 15 Custody We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Our firm does not have actual or constructive custody of client accounts. We will not serve as a custodian for Plan assets in connection with the Retirement Plan Services. The Sponsor is responsible for selecting the custodian for Plan assets. We may be listed as the contact for the Plan account held at an investment sponsor or custodian. The Sponsor for the Plan will complete the account paperwork with the outside custodian, who will provide the name and address of the custodian. The custodian for Plan assets is responsible for providing the Plan with periodic confirmations and statements. We recommend that the Sponsor review the statements and reports received directly from the custodian or investment sponsor. 35  Item 16 Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • • • • Determine the security to buy or sell; and/or Determine the amount of the security to buy or sell; and/or Determine the broker-dealer where trades will be executed; and/or Determine the amount of commission paid for trade execution Clients give us discretionary authority when they sign a discretionary agreement with our firm, and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. When providing Retirement Plan Services described herein, we may exercise discretionary authority or control over the investments specified in the Agreement. We perform these services to the Plan as an investment manager under ERISA Section 3(38). This discretionary authority is specifically granted to us by Sponsor, as specified in the Agreement (see also Item 4 above). 36  Item 17 Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Greenspring has authorized third- party managers to vote proxies on behalf of clients who hold individual equity and fixed income securities in their accounts. In these situations where authorization has been granted, we have notified the clients of this delegation of proxy voting authority to the third-party managers. We may provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. 37  Item 18 Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. As an advisory firm that maintains discretionary authority for client accounts, we are also required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. Currently, there are no such financial conditions that exist. Greenspring Advisors has not been the subject of a bankruptcy petition at any time during the past ten years. 38