Bruton Chisnell is an investment adviser providing financial planning, consulting, and investment management services. Prior to engaging Bruton Chisnell to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Bruton Chisnell setting forth the terms and conditions under which Bruton Chisnell renders its services (collectively the “Agreement”). Bruton Chisnell has been in business as an investment adviser since January 2018, when the firm purchased substantially all the assets and liabilities of Bruton Financial Advisors, LLC, which had been in business as a registered investment adviser since June 2004. James M. Bruton, Benjamin C. Bruton, and Michael A. Chisnell, Jr. are the principal owners of Bruton Chisnell. Bruton Chisnell had $644,459,532 in assets under management as of January 31, 2024, of which $420,534,500 was managed on a discretionary basis and $223,925,032 on a non-discretionary basis. This disclosure brochure describes the business of Bruton Chisnell. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Bruton Chisnell’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on Bruton Chisnell’s behalf and is subject to Bruton Chisnell’s supervision or control. Financial Planning and Consulting Services Bruton Chisnell may provide its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment related matters). These services are tailored to the individual needs of the client. In performing its services, Bruton Chisnell is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Bruton Chisnell may recommend the services of itself, its Supervised Persons in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Bruton Chisnell recommends its own services. The client is under no obligation to act upon any of the recommendations made by Bruton Chisnell under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Bruton Chisnell itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Bruton Chisnell’s recommendations. Clients are advised that it remains their responsibility to promptly notify Bruton Chisnell if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Bruton Chisnell’s previous recommendations and/or services. Page 5 © MarketCounsel 2024 Investment Management Services Clients can engage Bruton Chisnell to manage all or a portion of their assets on a discretionary or non- discretionary basis. The firm primarily allocates clients’ investment management assets among Independent Managers (as defined below) and mutual funds, and to a lesser extent among exchange-traded funds (“ETFs”), individual debt and equity securities as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. Bruton Chisnell also provides advice about any type of investment held in clients' portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically

agreed upon. Bruton Chisnell also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, Bruton Chisnell either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Bruton Chisnell tailors its advisory services to the individual needs of clients. Bruton Chisnell consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Bruton Chisnell ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Bruton Chisnell if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Bruton Chisnell’s management services. Use of Independent Managers As mentioned above, Bruton Chisnell recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between Bruton Chisnell or the client and the designated Independent Managers. Bruton Chisnell renders services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers. Bruton Chisnell also monitors and reviews the account performance and the client’s investment objectives. Bruton Chisnell receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. Page 6 © MarketCounsel 2024 When recommending or selecting an Independent Manager for a client, Bruton Chisnell reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that Bruton Chisnell considers in selecting or recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, Bruton Chisnell’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by Bruton Chisnell, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to Bruton Chisnell’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than Bruton Chisnell. In such instances, Bruton Chisnell may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Page 7 © MarketCounsel 2024