The Firm offers a variety of advisory services including consulting and investment and portfolio management services. Prior to the rendering of any of the foregoing advisory services, clients are required to enter into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). The Firm has been an independent registered investment adviser since May 1985 and is wholly owned by Gary Greenberg. As of December 31, 2023, the Firm had $132,979,318 in client assets under discretionary management and no client assets under non-discretionary management.
While this brochure generally describes the business of the Firm, certain sections also discuss the activities of its Supervised Persons, which refers to the Firm’s employees and/or any other person who provides investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control. Consulting Services The Firm offers clients a range of consulting services, which may include any or all of the following functions: Cash Flow Forecasting Retirement Planning Asset Allocation Business Planning Estate Planning Insurance Needs Analysis Risk Management Charitable Giving Investment Expert Testimony While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (as described below). In performing these services, the Firm 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. The Firm may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage the Firm to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by the Firm under a consulting engagement or to engage the services of any such recommended professionals, including the Firm itself. Clients are advised that it remains their responsibility to promptly notify the Firm Page 5 © MarketCounsel 2017 of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Firm’s previous recommendations

and/or services. Investment Management Services The Firm manages client investment portfolios on a discretionary basis. In addition, the Firm provides clients with investment management services which may include a broad range of comprehensive consulting services as well as discretionary management of investment portfolios. In regards to portfolio management services, the Firm primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities and options in accordance with the investment objectives of the individual clients. In addition, the Firm may also recommend that clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may also engage the Firm to 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, the Firm 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. The Firm tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. The Firm consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify the Firm if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if the Firm 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.