CTS was founded in 1972 and initially specialized in individual tax preparation for executives and professionals, primarily in the advertising and marketing industries. Over time, services for individuals were expanded, and now include personal financial planning, retirement planning, investment planning, insurance planning and asset management. In November 1985, CTS registered with the SEC as a registered investment adviser. CTS is owned by Todd W. Much, Charles A. Marien, Jonathon C. Much, and Christopher T. Much. Prior to engaging CTS to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with CTS setting forth the terms and conditions under which CTS renders its services (collectively the “Agreement”). CTS has $274,197,000 of assets under management as of September 30, 2023, all of which are managed on a discretionary basis. This Disclosure Brochure describes the business of CTS. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of CTS’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on CTS’s behalf and is subject to CTS’s supervision or control. Financial Planning and Consulting Services CTS provides comprehensive financial planning, focused retirement planning, as well as tax planning and preparation. A CTS comprehensive financial plan analyzes a client’s financial life, followed by a situation analysis and a recommendation of strategies that can help clients develop a plan towards achieving their goals. CTS’s comprehensive financial plan begins with a detailed review of a client’s net worth and asset diversification. CTS examines the client’s current “financial situation” which help determine the current status in various areas, such as savings and educational funding. CTS may provide an estimate for current and future years’ income taxes. If applicable, CTS will also conduct a detailed cash flow analysis to determine how clients are spending their money and review their mortgage. If applicable, CTS will devise a strategically sound plan for funding college education. CTS spends considerable time developing a retirement plan using multiple “what-if” scenarios. CTS may review clients’ estate plans as well as their insurance needs, including life, disability, health, auto, homeowner’s, and long-term care insurance. For some clients, CTS will provide a focused retirement plan that concentrates on achieving the client’s retirement goals. A CTS focused retirement plan targets a specific age for clients to comfortably retire from their career. This includes a review of the client’s net worth and asset diversification. If applicable, planning for college education will also be considered. This plan develops multiple “what-if” scenarios for Page 5 © MarketCounsel 2023 achieving retirement using alternative spending and savings goals in conjunction with varying retirement age, rate of return, and inflation rate assumptions. Unlike many investment advisers and financial planners, CTS also provides accounting services and income tax preparation and planning. Tax returns are prepared and/or supervised by an Enrolled Agent who has earned the privilege of practicing and representing taxpayers before the Internal Revenue Service. Some of the tax and accounting services provided by CTS include personal and federal state income tax preparation, tax planning and projections for current and future years, business income tax preparation for Partnerships, Trusts, LLC’s, and corporations, and representation for tax audits and resolution of IRS tax notices, and bookkeeping services for small businesses. Investment Management Services Clients can engage CTS to manage all or a portion of their assets on a discretionary basis. CTS primarily allocates clients’ investment management assets among mutual funds, exchange traded funds (“ETFs”), individual debt and equity securities, Independent Managers (as defined below), as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. CTS also provides advice about any type of investment held in clients' portfolios. CTS also may render investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, or other products that may not be held by the client’s primary custodian. In so doing, CTS directs the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. CTS tailors its advisory services to the individual needs of clients. CTS

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. CTS ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify CTS if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon CTS’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in CTS’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. In performing its services, CTS is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. CTS may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if CTS recommends its own Page 6 © MarketCounsel 2023 services. The client is under no obligation to act upon any of the recommendations made by CTS under a financial planning or consulting engagement or to engage the services of any such recommended professional, including CTS itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of CTS’s recommendations. Clients are advised that it remains their responsibility to promptly notify CTS if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising CTS’s previous recommendations and/or services. Use of Independent Managers As mentioned on the previous page, CTS may recommend that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between CTS or the client and the designated Independent Managers. CTS renders services to the client relative to the discretionary selection or recommendation of Independent Managers. CTS also monitors and reviews the account performance and the client’s investment objectives. CTS receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending or selecting an Independent Manager for a client, CTS reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that CTS considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, CTS’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by CTS, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to CTS’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than CTS. In such instances, CTS may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. If CTS refers a client to an Independent Manager where CTS’s compensation is included in the advisory fee charged by such Independent Manager and the client engages the Independent Manager, CTS is compensated for its services by receipt of a fee to be paid directly by the Independent Manager to CTS in Page 7 © MarketCounsel 2023 accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, as amended, and any corresponding state securities laws, rules, regulations, or requirements. Any such fee is paid solely from the Independent Manager’s investment management fee, and does not result in any additional charge to the client.