WTFG offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to WTFG rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with WTFG setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). WTFG filed for registration as an investment adviser in November 2017 and has been owned by Douglas Wells, Ralph Trecaso and Christopher Walters. As of December 31, 2023, WTFG had $482,943,218 in regulatory assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of WTFG, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on WTFG’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services WTFG offers clients a broad range of financial planning and consulting services, which includes retirement planning, education planning, trust and estate planning and life insurance needs. While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, WTFG is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. WTFG recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage WTFG or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by WTFG under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising WTFG’s recommendations and/or services. Page | 5 © MarketCounsel 2024 Wealth Management Services WTFG provides clients with wealth management services which includes financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. WTFG primarily allocates client assets in accordance with their stated investment objectives among various individual equity and debt securities, along with mutual funds, and exchange-traded funds (“ETFs”). For certain larger client portfolios, the Firm may also allocate assets to independent investment managers (“Independent Managers”). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios (but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon). Clients can engage WTFG to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, WTFG directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. The Firm’s Supervised Persons can also recommend the purchase of these held away investments in their

capacity as registered representatives as further discuss in this Disclosure Brochure. WTFG tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. WTFG consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify WTFG if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if WTFG determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, WTFG selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. The Independent Manager(s) fees may be included In the Firm's fees, but in certain Page | 6 © MarketCounsel 2024 circumstances the Independent Manager(s)' fees are in addition to the Firm's fees. The Firm has an incentive to select an Independent Manager where the fees are separate from the Firm's. The Firm will ensure that any recommendation to utilize an Independent Manager is in the best interest of the client regardless of the fees. WTFG evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. WTFG also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. WTFG continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. WTFG seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests Retirement Plan Consulting Services WTFG provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by WTFG as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of WTFG’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Page | 7 © MarketCounsel 2024