We offer wrap fee programs as described in this Wrap Fee Program Brochure. Our wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. A wrap fee program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services may include portfolio management, and the fee is not based directly upon transactions in your account. Your fee is bundled with our costs for executing transactions in your account(s). This results in a higher advisory fee to you. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. By participating in a wrap fee program, you may end up paying more or less than you would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to you by the executing broker. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap [or bundled] fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. In addition to the advisory services, the wrap fee program includes certain brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. We are independently owned and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and not as an investment advisor to you. It will have no discretion over your account and will act solely on instructions it receives from us [or you]. Schwab has no responsibility for our services and undertakes no duty to you to monitor our firm’s management of your account or other services we provide to you. Schwab will hold your assets in a brokerage account and buy and sell securities and execute other transactions when we [or you] instruct them to. We do not open the account for you. Schwab does not charge transaction fees for U.S. listed equities and exchange traded funds. Since we pay the transaction fees charged by the custodian to clients participating in our wrap fee program, this presents a conflict of interest because we are incentivized to recommend equities and exchange traded funds over other types of securities in order to reduce our costs. To mitigate this conflict our firm upholds our fiduciary duty in selecting the appropriate asset for a given portfolio and the cost to trade that asset is not taken into account when determining that appropriateness. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Granite Harbor Advisors, Inc. Our Wrap Advisory Services Wrap Portfolio Management: We emphasize continuous and regular account supervision. As part of this service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least annually and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals, and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Our firm utilizes the sub-advisory services of SEI Investments Company (“SEI”) for portfolio diversification and access to additional asset classes. As part of this process, we will provide initial due diligence on the programs available, gather information from clients about their financial situation, investment objectives, and restrictions, and deliver the required account paperwork and disclosure documents if the client selects a program. Prior to referring

clients to SEI, we will ensure that they are licensed, or notice filed with the respective authorities. Our firm also offers variable annuity management for certain annuities which are sold on a fee-only basis. These arrangements are custodied direct with the sponsor and the terms and conditions will be set forth in a separate agreement entered into by the client with the sponsor. The fees for these offerings vary but will never exceed the fees disclosed for our Wrap Portfolio Management service. The maximum fee for our Wrap Portfolio Management service is 1.75% of the assets under management in each household which may also be a flat dollar amount not to exceed 1.75% of assets under management. Our firm’s annualized fees are generally billed on a pro-rata basis monthly or quarterly in arrears based on an average daily balance of the account(s) value during the billing period. Our advisory fee will be assessed on cash and cash equivalents unless otherwise agreed to in writing. The exact arrangements shall be indicated in the executed client agreement. It should be noted that our firm is not assessed transaction charges for either the sub-advised accounts or fee- based variable annuities, as these costs are built into the program/ product fees borne by the client. The total estimated fee, as well as the ultimate fee that we charge you, is negotiable and will based on the scope and complexity of our engagement with you. Fees will be automatically deducted from your account. As part of the fee deduction process, you are made aware of the following: 1. Clients must provide our firm with written authorization permitting direct payment of advisory fees from their account(s) maintained by a custodian who is independent of our firm; 2. Our firm provides clients with electronic access to quarterly performance reports showing the fee amount, the value of the assets upon which the fee was based, the specific manner in which the fee was calculated as well as a disclosure that it is the client’s responsibility to verify the accuracy of fee calculation, and that the custodian does not determine its accuracy; and 3. The account custodian sends a statement to the client, at least quarterly, showing all account disbursements, including advisory fees. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Granite Harbor Advisors, Inc. Fees for sub-advisory services rendered to our clients by SEI are billed on a pro-rata basis quarterly in arrears based on the average daily balance of the account(s) value during the billing period. Our firm calculates the quarterly fee due to us and instructs SEI the amount to deduct from your managed account. Our fee will be in addition to fees that are imposed by SEI for programs and managers they make available, which they deduct separately. SEI establishes and maintains their own separate billing processes, which we have no control of. The advisory fee paid to our firm shall not exceed the fee published for this service. The terms and conditions under which the client shall engage SEI will be set forth in a separate agreement between the client and SEI. Other Types of Fees & Expenses: You may pay custodial fees, charges imposed directly by a mutual fund, index fund, annuity or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such as a commission or markup) for trades executed away from Schwab at another broker-dealer, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. It is important to note that our firm does not include the trading cost associated with unsolicited trades made by clients in our wrap-fee program. The client will be billed directly for these fees. Our investment advisory representatives receive a portion of the advisory fee that you pay us, either directly as a percentage of your overall fee or as their salary from our firm. In cases where our investment advisory representatives are paid a percentage of your overall advisory fee, this may create an incentive to recommend that you participate in a wrap fee program rather than a non-wrap fee program (where you would pay for trade execution costs) or brokerage account where commissions are charged. This is because, in some cases, we may stand to earn more compensation from advisory fees paid to us through a wrap fee program arrangement if your account is not actively traded. Termination and Refunds: Either party may terminate the advisory agreement signed with our firm for Wrap Portfolio Management service in writing at any time. Upon notice of termination pro-rata advisory fees for services rendered to the point of termination will be charged. If advisory fees cannot be deducted, our firm will send an invoice for due advisory fees to the client.