Gradient Advisors, LLC

• A percentage of assets under your management
• Fixed fees (other than subscription fees)
• Other

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

Asset-based fee: up to 1.5% of assets a year (the maximum the brochure states)

Flat fee: $300 to $2,000 (financial planning and consulting)

As stated in the firm's Form ADV Part 2A brochure dated March 31, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

$289,253,282 as of October 2026, filing dated March 31, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Financial planning services
• Portfolio management for individuals and/or small businesses
• Pension consulting services
• Selection of other advisers (including private fund managers)

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2010 (16 years)

Employees

Total: 173. Performing investment advisory functions: 166.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

Charles Schwab & Co., Inc.SEI Investments Distribution Co.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

Other offices (Schedule D, Section 1.F)

25 other offices, as of the April 2026 filing

Bloomington, MNBullhead City, AZChesapeake, VADavison, MIGeneva, ILKansas City, MTKnoxville, TNLady Lake, FLLaguna Hills, CAMacon, GAMequite, NVMokena, ILNew Port Beach, CAOmaha, NEPeru, ILPocahontas, ARPoint Lecanto, FLPueblo, CORichmond, VARoanoke, VASan Antonio, TXSandpoint, IDSchaumburg, ILSt Portage, WIWarsaw, MO

States registered or notice-filed

51 states or jurisdictions

AKALARAZCACOCTDCDEFLGAHIIAIDILINKSKYLAMAMDMEMIMNMOMSMTNCNDNENHNJNMNVNYOHOKORPARISCSDTNTXUTVAVTWAWIWVWY

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

6 Reports 6 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(1) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?
• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.D(5) Has another federal regulator, a state regulator, or a foreign financial regulator ever denied, suspended, or revoked the registration or license of the firm or an advisory affiliate, prevented either by order from associating with an investment-related business, or restricted either one's activity?

Civil court matters Item 11.H

• 11.H(1)(a) In the past ten years, has a domestic or foreign court issued an injunction against the firm or an advisory affiliate in connection with investment-related activity?
• 11.H(2) Is the firm or an advisory affiliate now the subject of a civil proceeding that could result in a yes answer to any part of 11.H(1)?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $120,555,969 in the October 2021 data and $289,253,282 in the October 2026 data, up 140%.

Total employees: 112 in October 2021 and 173 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. April 2026
   • Item 11 disclosure answers changed: 6 yes answers, previously 5 (now yes: 11.D(5)).
   • Employees performing advisory functions went from 169 to 166.
   • Regulatory assets under management went from $218,611,410 to $289,253,282 (+32%).
   • Added an office in Bullhead City, AZ.
   • Added an office in Geneva, IL.
   • Added an office in Kansas City, MT.
   • Added an office in Lady Lake, FL.
   • Added an office in Laguna Hills, CA.
   • Added an office in New Port Beach, CA.
   • Added an office in Omaha, NE.
   • Added an office in Peru, IL.
   • Added an office in Pocahontas, AR.
   • Added an office in Point Lecanto, FL.
   • Added an office in Richmond, VA.
   • Added an office in Roanoke, VA.
   • Added an office in Sandpoint, ID.
   • Added an office in St Portage, WI.
   • No longer lists an office in Arlington, TX.
   • No longer lists an office in Bothell, WA.
   • No longer lists an office in Fairview Heights, IL.
   • No longer lists an office in Gilbert, AZ.
   • No longer lists an office in Greensboro, NC.
   • No longer lists an office in Knoxville, TN.
   • No longer lists an office in Lagrange, IL.
   • No longer lists an office in Laguna Niguel, CA.
   • No longer lists an office in Lancaster, PA.
   • No longer lists an office in Newton Square, PA.
   • No longer lists an office in Oklahoma City, OK.
   • No longer lists an office in Pelham, AL.
   • No longer lists an office in Webster, TX.
   • No longer lists an office in Wilminton, NC.
   • Updated its list of owners and control persons (Schedule A).
2. January 2026
   • Updated its list of owners and control persons (Schedule A).
3. November 2025
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.