General Information Graylark is an investment adviser located in Erie, Colorado that was formed in March 2023 as a Delaware limited liability company. The principal owners of Graylark are Brian Gray and Ashley Gray (the “Principals”). Brian Gray is the Chief Compliance Officer of Graylark. We are committed to helping clients build, manage, and preserve their wealth. Our Firm provides investment advisory services that help clients to achieve their stated financial goals. We will offer initial complimentary meetings upon our discretion; however, investment management services are initiated only after you and Graylark execute an Investment Advisory Agreement. Portfolio Management Services In providing portfolio management services, Graylark considers each client’s financial goals, investment objectives and risk tolerance. Client portfolios may vary in structure based on needs, size, and economic and market trends at the time, but generally include exchange traded funds (“ETFs”), mutual funds, equities (e.g., common stocks and preferred stocks, options etc.), fixed-income (e.g., corporate, municipal, U.S. Treasury, and other government and agency), and cash and cash equivalents (e.g., money market and U.S. Treasury bills). Clients may request reasonable restrictions on investments in certain financial instruments. Notice of requested restrictions is required to be given to Graylark in writing and must be agreed to by Graylark in writing. Graylark offers to manage client assets on either a discretionary or non-discretionary basis. During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition and background. Based on client needs, we develop a client’s personal profile and investment strategy. We then create and manage the client’s investments based on that policy and strategy. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals. Once we have determined the types of investments to be included in a client’s portfolio and have allocated the assets, we provide ongoing investment review and management services. Discretionary Basis - As a discretionary investment adviser, Graylark will have the authority to supervise and direct client portfolios without prior consultation with the client. We will make changes to the portfolio, as we deem appropriate, to meet client financial objectives. We trade these portfolios based on the combination of our market views and client objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. Non-Discretionary Basis - In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. For non-discretionary accounts, the client may also execute a limited power of attorney, which allows Graylark to carry out trade recommendations and approved actions in the portfolio. However, in accordance with Graylark’s non-discretionary investment advisory agreement with the client, Graylark does not implement trading recommendations or other actions in the account unless and until the client has approved the recommendation or action. The use of non-discretionary accounts may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. Sub-Advisory Services Graylark will have discretion to utilize independent third-party investment adviser to aid in the implementation of investment strategies for your portfolio.

In certain circumstances, we may allocate a portion of a portfolio to an independent third-party investment adviser (“Manager”) for separate account management based upon your individual circumstances and objectives, including, but not limited to, your account size and tax circumstances. Upon the recognition of such situations, in coordination with you, Graylark will hire a Manager for the management of those assets. These Managers shall assist our Firm in managing the day‐to‐day investment operations of the various allocations, shall determine the composition of the investments comprising the allocation, shall determine what securities and other assets of the allocation will be acquired, held, disposed of or loaned in conformity with the written investment objectives, policies and restrictions and other statements of each client comprising the allocation, or as instructed by our Firm. Managers may take discretionary authority to determine the securities to be purchased and sold for the client. As stated in the Discretionary Advisory Agreement, our Firm and its associated persons will have discretionary authority to hire and fire the Manager. Our firm will work with the sub-advisor to communicate any trading restrictions or standing instructions to refrain from a particular industry requested by the Client. In all cases, trading restrictions will depend on the sub-advisor and their ability to accommodate such restrictions. Through our relationship with Axos, the recommended Custodian of client accounts, our Firm has access to various independent Managers. We review the performance of the Managers on at least a quarterly basis. More frequent reviews may be triggered by changes in Manager’s management, performance or geopolitical and macroeconomic specific events. Financial Planning Services Graylark may provide financial planning services to those clients in need of such services in conjunction with investment advisory services. Financial planning services are included in the portfolio management services described above and fees described in Item 5 of the Brochure. With the unique goals and circumstances of each family in mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and family legacy objectives. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include: ● Review and clarification of your financial goals. ● Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning. ● Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals. ● Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable, and trust accounts that require special attention. ● Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits; and ● Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death. A written evaluation of each client's initial situation or Financial Plan can be provided upon request. Value of Assets Currently Managed As of the date of this Brochure, Graylark had $19,300,240 in discretionary assets under management.