A) Description of our firm We provide investment advice and/or manage investment securities for our clients. William Dirk Calvin, CEO, is the principal owner and a member of our firm (formerly known as Mabry‐Calvin, LLC, which was founded in 1989). The company has been registered as an investment adviser since 2010. Jackson Calvin is a minority member of the firm and serves as our Chief Financial Officer and Chief Compliance Officer (CCO). In addition to managing investment securities, we also monitor the return performance of our client’s discretionary, non‐discretionary, and “held‐away” assets. Clients decide which of the “held‐ away” accounts they wish to have monitored. B) Description of our services We offer ongoing portfolio management, as well as, recommend various mutual funds, index funds, ETFs, and fixed income securities to our clients. We manage some accounts on a discretionary basis. We also work with some accounts on a non‐discretionary basis. In addition, we provide investment performance measurement on any, and all, accounts our clients choose to add to our third‐party measurement service. Where appropriate based on the Client’s individual circumstances, we may recommend that the Client open an account with American Funds to purchase F‐2 Class Shares as all or part of their investment portfolio held at American Funds whereby American Funds acts as transfer agent. Class F‐2 shares are designed for investors who choose to compensate their financial professional based on the total assets in their portfolios, rather than commissions or sales charges. This arrangement is often called an “asset‐ based” or a “fee‐based” program. Class F‐2 shares do not have an up‐front or a contingent deferred sales charge. Class F‐2 shares also do not carry a 12b‐1 fee but may have slightly higher administrative expenses than certain other Class shares. These expenses will vary among the funds. Please note that Class F‐2 shares are not available for purchase in certain employer‐sponsored retirement plans, unless they are a part of a qualifying fee‐based program. SIMPLE IRA Retirement Plan Services Additionally, we offer consulting services to plan sponsors and other named fiduciaries (the "client") regarding employer sponsored SIMPLE plans. The exact services to be provided will be clearly set forth in the services agreement between the client and Sage Investment Counsel as mutually agreed upon. Generally, the client may select one or more of the following services. 5 ERISA Non-Fiduciary Services
• Education Services to Plan Committee. This includes general education regarding the SIMPLE IRA plan’s investment options to the Plan Committee. Sage Investment Counsel will not render individualized investment advice and will not be held to an ERISA fiduciary standard for services rendered hereunder.
• Participant Education Services. Sage Investment Counsel will conduct periodic mutually agreed upon informational meetings with employees and Participants and provide general investment education, including information about the Plan, general financial and investment information and information and materials relating to the investment options available through the Plan.
• Plan Search Support. Sage Investment Counsel will consult with the Plan Sponsor regarding the selection of the SIMPLE IRA plan, if requested. Sage Investment Counsel will not render individualized investment advice and will not be held to an ERISA fiduciary standard for services rendered hereunder. Additional Non-Fiduciary ERISA Services Additional services, such as the following, may be agreed upon between the Plan and Sage Investment Counsel will be set forth in the service agreement.
• Monitoring of Qualified Fiduciary: The client is responsible as a Plan fiduciary for selection of Sage Investment Counsel, and for monitoring the performance of Sage Investment Counsel. To facilitate this responsibility, Sage Investment Counsel will provide client (a Plan fiduciary) with a structure for the annual review and monitoring of Sage Investment Counsel and its representative. ERISA Non-Discretionary Fiduciary Services These services are designed to allow the plan's sponsor and other named fiduciaries (the "client") to retain full discretionary authority or control over assets of the plan. Recommendations will be made directly to the client; plan participants will not be provided individualized, personal investment advice under these services. We will perform these non‐discretionary investment advisory services through our investment adviser representatives, and we may charge a fee for these fiduciary services, as described in this Form ADV and the advisory agreement. We will perform these investment advisory services to the plan as a fiduciary defined under ERISA Section 3(21) and we will act with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. The client may engage us to perform one or more of the following non‐discretionary investment advisory services: 6
• Investment Policy Statement: Sage Investment Counsel will assist the client in developing a formal, written Investment Policy Statement (“IPS”) or it will review and may recommend amendments to the client relating to the existing IPS, if applicable. The IPS may contain the standards and processes for selecting and monitoring Plan investments, and will set forth the number of general investment options and asset class categories to be offered to Plan participants with a goal of providing a menu of investments that will allow for the creation of well‐diversified portfolios through a mix of equity and fixed income exposures. The IPS is subject to the final approval of client, and Sage Investment Counsel does not guarantee that client will achieve the investment objectives in the IPS.
• Investment Recommendations & Performance Monitoring: As mutually agreed upon, Sage Investment Counsel will review the investment options

available through the Plan and consult with the client as to what options exist with the goal of assisting the client in selecting the “core” investments to be offered to Plan participants, including the Plan’s QDIAs if applicable, that has been approved by the client. As mutually agreed upon, Sage Investment Counsel will provide reports on a regular basis that are designed to assist the client in monitoring the core investment options and to assist the client’s decision‐making in removing and replacing investments that no longer meet the client’s objectives. Sage Investment Counsel has no discretion with regard to selecting or removing investments for the Plan.
• Selection of Qualified Default Investment Alternative. If applicable, Sage Investment Counsel will assist client in its selection of an investment fund product meeting the definition of a QDIA in ERISA Regulation 2550.404c‐5(e)(3). The QDIA shall be reflected in the IPS, if applicable. Client retains the sole responsibility to provide all required notices to Participants as required under ERISA section 404(c)(5). Sage Investment Counsel makes no representations that the Plan will otherwise be compliant with section 404(c). Rollover Services Disclosure In conjunction with the advisory services offered, we may provide education or recommendations related to the rollover of an employer sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. When our firm or our Associated Person(s) recommend an investor roll over plan assets into an Individual Retirement Account (“IRA”), we and our Associated Person(s) may earn an asset‐based fee as a result. However, no compensation is received if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, your fees and expenses will increase because fees will apply to assets rolled over to an IRA and ongoing services will be extended to these assets. 7 Further, you may incur other levels of fees and expenses, including, but not limited to, investment‐ related expenses imposed by other service providers and mutual fund managers not affiliated with us, as well as other fees and expenses charged by the custodian, third‐party administrator, and/or record‐ keeper. We make no representations or warranties relating to any costs or expenses associated with the services provided by any third parties, and you understand that these fees are in addition to the fee paid to us for the rollover advice. In cases where we provide you with rollover advice as defined by the Department of Labor, which may also include setting up and/or completing the rollover transaction, we do not serve as a custodian, and we do not provide legal or tax advice to you. In addition, we do not have any responsibilities or potential liabilities in connection with assets not related to the rollover and investments that are not managed by us. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests. In accordance with various rules and regulations, we must act in your best interest and we must not put our interests ahead of your interests. Additionally, we must: meet a professional standard of care when making investment recommendations (give prudent advice); never put our financial interests ahead of yours when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that we give advice that is in your best interest; charge no more than is reasonable for our services; and, give you basic information about any conflicts of interest. We rely on all information you provide to us, whether financial or otherwise, without independent verification. We request that you promptly notify us in writing of any material change in the financial and other information provided to us, and to promptly provide any such additional information as may be reasonably requested by us. Due to the volatile and unpredictable nature of financial markets, we do not guarantee any future performance, any specific level of performance, the success of any recommendations or strategies that we may take or recommend for you, or the success of our overall recommendations. Investment recommendations are subject to various market, currency, economic, political, and business risks, and that investment decisions will not always be profitable. C) Tailoring our services to individual needs and restrictions on investing While clients share many similarities, we manage portfolios with the purpose of reaching investment goals that are suitable for the individual client. We will not manage accounts if client goals are not compatible with one of our investment styles. We will, however, monitor any client accounts even if the goal is not compatible with our philosophy or investment style. Accounts that we manage will be separate, not pooled, and held at a custodian independent of us. 8 Clients may impose restrictions on investing in certain securities or types of securities in some of the portfolios in which we maintain discretion. We inform clients when, and if, these restrictions are not possible. D) Wrap fee programs We do not manage wrap fee programs. E) Assets under management As of January 31, 2024, we managed approximately $129,657,303 in discretionary assets and no non‐ discretionary assets.