A. General Information Graylark is an investment adviser located in Denver, Colorado that was formed in March 2023 as a Delaware limited liability company. The principal owner of Graylark is Brian Gray. Graylark offers investment advisory services to separately managed accounts (“SMAs”) for individuals, families, and entities with one or more accounts. Graylark may invest some or all of a Graylark client’s portfolio in third-party funds. Investment advisory services are provided through consultation with the client and include: determination of financial objectives, understanding of risk, identification of any financial problems, portfolio analysis, and cash flow management. Graylark is a “fee-only” investment advisory firm. Graylark does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other products for a commission. Affiliates of Graylark, however, may engage in the foregoing activities. B. Investment Advisory Services In providing investment advisory 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). In addition, appropriate client portfolios may also include, without limitation, private funds and other financial instruments. 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. 1. Discretionary Basis As a discretionary investment adviser, Graylark will have the authority to supervise and direct client portfolios without prior consultation with the client. 2. 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. C. 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 may also be offered as a stand-alone service for a separate fee. Graylark’s financial planning services normally address areas such as tax planning, insurance review, education funding, retirement planning, and estate planning. D. Type and Value of Assets Currently Managed Graylark is a newly formed registered investment advisory firm. Accordingly, as of the date of this Brochure, Graylark does not have any assets under management.