Gateway Wealth offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Gateway Wealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Gateway Wealth setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Gateway Wealth has been registered as an investment adviser since September 2022 and is principally owned by David Wood (Chief Visionary Officer), Eric Hall (Chief Executive Officer) and Jill Batley (President and Chief Compliance Officer). As of December 31, 2023, Gateway Wealth had $891,580,271 in regulatory assets under management, $556,507,460 of which were managed on a discretionary basis and $335,072,811 on a non-discretionary basis. While this brochure generally describes the business of Gateway Wealth, 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 Gateway Wealth’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services Gateway Wealth will typically provide a variety of financial planning and consulting services to clients, pursuant to a written financial planning agreement. Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a client’s financial situation. A financial plan developed for, or financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client. For example, recommendations may be made that the client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Gateway Wealth may also refer clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Firm will provide a written summary of the client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Firm may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict of interest. For example, the Firm has an incentive to recommend that Page | 5 © MarketCounsel 2024 clients engage the Firm for investment management services or to increase the level of investment assets with the Firm, as it would increase the amount of advisory fees paid to the Firm. Clients are not obligated to implement any recommendations made by Gateway Wealth or maintain an ongoing relationship with the Firm. If the client elects to act on any of the recommendations made by the Firm, the client is under no obligation to implement the transaction through the Firm. 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 Gateway Wealth’s recommendations and/or services. While these services are 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, Gateway Wealth 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. Gateway Wealth 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. Wealth Management Services Gateway Wealth provides clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. In accordance with the client’s stated investment objectives, Gateway Wealth primarily allocates client assets among various low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”). The Firm may also utilize individual stocks and bonds and independent investment managers (“Independent Managers”) where appropriate. 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 Gateway Wealth 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, Gateway Wealth 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. Gateway Wealth 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 Page | 6 © MarketCounsel 2024 objectives. Gateway Wealth 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 Gateway Wealth 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 Gateway Wealth 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. Retirement Plan Consulting Services Gateway Wealth 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:
• Vendor Analysis
• Employee Enrollment
• Education Tracking
• IPS Support
• Investment Management
• Investment Consulting
• Performance Reports
• ERISA 404(c) Assistance
• Benchmarking Services
• Ongoing Investment Assistance As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Gateway Wealth 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 Gateway Wealth’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. The Firm can provide investment advisory services on behalf of the Plan and Plan Sponsor, which may be in either a 3(21) or 3(38) context depending on whether or not the Furn is also providing discretionary investment management over the Plan assets. For 3(38) services, the Firm shall have the discretion to select the investments for the Plan and/or make investment decisions on behalf of Plan Participants. Use of Independent Managers As mentioned above, Gateway Wealth 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 are 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, Page | 7 © MarketCounsel 2024 clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Gateway Wealth 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. Gateway Wealth also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Gateway Wealth 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. Gateway Wealth seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Gateway Wealth includes securities transaction fees together with its wealth management fees. Including these fees into a single asset-based fee is considered a “Wrap Program.” The Firm sponsors the Gateway Wealth Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Participants in the Wrap Program may pay a higher or lower aggregate fee than if investment management and brokerage services are purchased separately. Additional information about the Wrap Program is available in Gateway Wealth’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV (the “Wrap Brochure”).