The disclosure in this brochure is limited to the services that GMG provides as an investment adviser registered with the U.S. Securities and Exchange Commission to U.S. clients. Non-U.S. clients will be provided with separate disclosures and agreements. GMG provides financial planning, and investment management services. Prior to engaging GMG to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with GMG setting forth the terms and conditions under which GMG renders its services (collectively the “Agreement”). GMG has been in business for Canadian clients since May 2010. The contracts of its U.S. affiliate, Gavin Management Group, Inc., were assigned to GMG on October 1, 2021. GMG is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, GMG is owned by Connectus Canada Wealth Management ULC and indirectly owned by Focus LLC. Focus Financial Partners Inc. (“Focus Inc.”) is the sole managing member of Focus LLC and is a public company traded on the NASDAQ Global Select Market. Focus Inc. owns approximately two-thirds of the economic interests in Focus LLC. The full ownership details can be found on the Firm’s Schedule A and B of Form ADV Part 1. Focus Inc. has no single 25% or greater shareholder. Focus Inc. is the managing member of Focus LLC and has 100% of its governance rights. Accordingly, all governance is through the voting rights and Board at Focus Inc. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. GMG helps its clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to the Firm’s affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of the Firm’s parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. This Disclosure Brochure describes the U.S. business of GMG. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of GMG’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 GMG’s behalf and is subject to GMG’s supervision or control. Financial Planning GMG may provide its clients with a broad range of comprehensive financial services. In performing these services, GMG is not required to verify any information received from the client or from the client’s other Page 5 © MarketCounsel 2023 professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. GMG recommends certain clients engage the Firm for additional related services 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 GMG 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 GMG under a financial planning or business management 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 GMG’s recommendations and/or services. Investment Management Services Clients can engage GMG to manage all or a portion of their assets on a discretionary basis and in limited circumstances clients can engage GMG to manage a portion of their assets on a non-discretionary basis. GMG primarily allocates clients’ investment management assets among individual stocks, alternative strategies (e.g. long/short funds, market neutral funds), equity and bond mutual funds and ETFs, and independent investment managers (“Independent Managers”) in accordance with the investment objectives of the client. In addition, GMG also recommends that certain eligible clients invest in privately placed securities, which may include interests in pooled investment vehicles. Where appropriate, the Firm also provides advice about certain legacy positions 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. The Firm can also implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at the Firm’s primary custodian(s). GMG tailors its advisory services to the individual needs of clients. GMG 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. GMG has a process to review client investments for suitability based on the client’s investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify GMG if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon GMG’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in GMG’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Page 6 © MarketCounsel 2023 Use of Independent Managers As mentioned above, GMG 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. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. GMG 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. GMG also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. GMG 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. GMG seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Management of Collective Investment Vehicle GMG’s affiliate, Gavin Special Opportunities Fund II GP, LLC, serves as the general partner (“General Partner”) of an affiliated private investment fund, GAVIN Special Opportunities Fund LP (the “Fund”). The Firm acts as the investment manager of the Fund. Interests in the Fund are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. The Fund currently relies on an exemption from registration under the Investment Company Act of 1940, as amended. Participation as an investor in the Fund is restricted to investors that are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended. The Fund seeks to provide Limited Partners with above average long-term risk- adjusted returns that are uncorrelated to equity markets by investing substantially all of its assets in Portfolio Investments which are managed by a carefully selected group of Portfolio Managers who invest in securities issued by U.S. and non-U.S. companies that are traded on U.S. and non-U.S. national securities exchanges. To the extent certain of GMG’s individual advisory clients qualify, they will be eligible to participate as limited partners of the Fund. The firm’s investment management fee (described below in Item 5) will apply to any assets invested by clients in the Fund, but GMG will not charge other fees for management of such assets. Investors will, however, pay additional expenses in the Fund, including, but not limited to, fees and expenses of the underlying funds that the Fund invests in. Investment in the Private Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the Fund, including the Page 7 © MarketCounsel 2023 compensation received by GMG, suitability, risk factors, and potential conflicts of interest, are set forth in a Confidential Private Offering Memorandum (the “Memorandum”), Limited Partnership Agreement (the “Agreement”), and/or Subscription Agreement (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Fund. A conflict of interest exists as GMG has an incentive to recommend an investment in the Fund to promote the success of the Fund. GMG will devote its best efforts with respect to its management of both the Fund and its individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Fund, GMG may give advice or take action with respect to the Fund that differs from that for individual client accounts. To the extent that a particular investment is suitable for both the Fund and certain individual client accounts, such investments will be allocated between the Private Fund and the individual client accounts in a manner which GMG determines is fair and equitable under the circumstances to all of its clients.GMG tailors its advisory services to the individual needs of clients. GMG 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. GMG has a process to review client investments for suitability based on the client’s investment needs, goals, objectives and risk tolerance. Other Services GMG offers clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions with the assistance of our affiliate, Focus Treasury & Credit Solutions ("FTCS"), a wholly owned subsidiary of our parent company, Focus, LLC. FTCS in turn shares up to 25% of this earned revenue with GMG when licensed to receive such revenue or when no such license is required. Please see Items 5 and 10 for a fuller discussion of these services and other important information. ERISA Disclosure GMG is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including plan participants. GMG is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, GMG is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). Fiduciary Duty As a fiduciary, GMG has duties of care and of loyalty to you and are subject to obligations imposed on the Firm by the federal and state securities laws. As a result, clients have certain rights that cannot be waived or limited by contract. Nothing in our agreements with clients should be interpreted as a limitation of GMG's Page 8 © MarketCounsel 2023 obligations under the federal and state securities laws or as a waiver of any unwaivable rights clients possess.