CPR offers a variety of advisory services, which include investment consulting and investment management services. This includes outsourced chief investment officer services for other investment advisers. Prior to CPR rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with CPR setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). The Firm provides its services exclusively through other investment advisers (“Primary Adviser”). The Firm may have limited interactions and discussions with clients of those Primary Adviser that have engaged the Firm to provide its services. CPR has been registered as an investment adviser since June 25, 2021 and is owned by Thomas Balis. As of February 28, 2024, CPR has $1,351,624,620 in assets under management, all of which are managed on a discretionary basis. While this brochure generally describes the business of CPR, 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 other persons who provide investment advice on CPR’s behalf and are subject to the Firm’s supervision or control. Furthermore, the Firm’s “clients” are the Primary Adviser that engage the Firm. The clients of those Primary Adviser are not CPR’s clients. For ease of understanding in this brochure, however, the term “clients” will sometimes refer to those Primary Adviser clients. If the clients of such Primary Adviser have any questions about the Firm’s services or relationship with that client, the Firm is available through the Primary Adviser to discuss further. Investment Management Services CPR is engaged by other investment advisers (the Primary Advisers) to manage the investment portfolios of those Primary Advisers. CPR primarily allocates assets on a discretionary basis, among various mutual funds, exchange-traded funds (“ETFs”) and liquid alternative investments, in accordance with the investment objectives determined by the Firm’s Primary Adviser clients. Where appropriate, the Firm also provides advice about any type of legacy position, other investments held in portfolios, or other investments that clients request advice upon. Clients should

not, however, assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage CPR 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, CPR directs or recommends the allocation of client assets among the various investment options available with the product. Page | 5 © MarketCounsel 2024 These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. CPR tailors its advisory services to meet the needs of its clients. As a reminder, those clients are the Primary Adviser that engage the Firm. The Firm will work with those Primary Adviser to manage portfolios in a manner consistent with the end client’s needs and objectives as determined by the Primary Adviser. The Primary Adviser is responsible for consulting with end 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. End clients are advised to promptly notify their Primary Adviser 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 CPR 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. Investment Consulting Services CPR can also be engaged by the Primary Adviser to render investment consulting services. While the investment consulting services can vary, the Firm anticipates that the most common investment consulting service engagement will involve providing similar services as described above under the investment management services section. In the investment consulting engagement, however, the Firm will provide its research, analysis and recommendations to the Primary Adviser. The Primary Adviser will then be responsible for what to do with the recommendations.