GW & Wade, LLC (“GW & Wade”) is an investment adviser registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940. GW & Wade has been in business since 1986 and primarily serves individuals and families as well as, to a lesser extent, defined contribution plans, charitable organizations, foundations and municipalities. Debra K. Brede and her team joined GW & Wade at the end of 2020. The clients who are served by Ms. Brede and her team are serviced by GW & Wade doing business as D.K. Brede Investment Management Company (“DKBIM”). Where appropriate, throughout this brochure, we will distinguish DKBIM’s practices from those of GW & Wade’s main business line. Focus Operating, LLC, Focus Financial Partners, LLC, and Focus Financial Partners, Inc. GW & Wade is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, GW & Wade is a wholly owned subsidiary of Focus Operating, LLC (“Focus Operating”), which is a wholly owned subsidiary of 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. 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 of directors at Focus Inc. (the “Board”). 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 ADV. The advisory activities of GW & Wade operate independently from the advisory activities of each of the Focus Partners. GW & WADE GW & Wade offers various financial, investment management and wealth management services to our clients. These services, summarized below, are generally provided pursuant to a written agreement with a client. We offer comprehensive financial planning services for our clients which include areas such as cash flow and budgeting, insurance needs analysis, education planning, retirement planning, and estate planning, taking into account a client’s specific financial needs and goals. We also offer investment management services. These services involve continuous advice and monitoring regarding the investment of clients’ securities assets based on their individual goals and investment objectives, typically as identified in the financial planning process. We then develop and manage a securities portfolio based on these goals and objectives. GW & Wade offers investment management services primarily on a discretionary basis, although we manage accounts for some clients on a non‐discretionary basis. Account management is guided by the stated goals and investment objectives of each client. Clients are free to impose reasonable restrictions on investments to be purchased in their accounts. Clients retain individual ownership of all securities. A client has the right to terminate an investment advisory agreement without penalty within five business days after entering into the agreement. Either we or the client may terminate an investment advisory agreement effective upon receipt of written notice by the other party. We will be winding down our broker-dealer affiliate GW & Wade Asset Management (“GWWAMC”). We are recommending that clients appoint Fidelity Brokerage Services LLC as the broker and custodian for their GW & Wade accounts. Throughout this document, we refer to Fidelity Brokerage Services as “Fidelity” and the services they provide as “custodial/ brokerage services.” For some period of time, we expect that there will be some clients who use Fidelity and some who use GWWAMC. In general, the commissions and other fees, expenses, and margin rates that we have negotiated with Fidelity on behalf of our clients are either the same or more advantageous than those of GWWAMC set forth in Item 12 below. For example, transaction fees for mutual funds are generally $3 cheaper at Fidelity. Additionally, for clients who elect electronic delivery of their brokerage statements from Fidelity or who have greater than $1 million under management with GW & Wade at Fidelity, ETF and most equity trades will be at no charge. Please call your counselor if you have not yet received Fidelity account paperwork and would like to transition your accounts sooner. In addition, some clients have brokerage and custodial arrangements elsewhere and direct us to execute transactions through that custodian/broker-dealer. Please see the discussions throughout this Item 4, in Item 5, Fees and Expenses, Item 12, Brokerage Practices and Item 14, Client Referrals and Other Compensation. Many of GW & Wade’s personnel are currently also registered representatives of GWWAMC, our affiliated broker-dealer. When those personnel provide investment advice, they are solely acting on behalf of GW & Wade and not on behalf of GWWAMC. This means that they are acting as representatives of the investment advisor and not our affiliated broker/dealer. All obligations owed to clients with respect to investment advice are owed by GW & Wade and personnel acting on its behalf and GWWAMC itself does not provide investment advice of any type. GWWAMC continues to have a limited number of brokerage accounts for customers that are not also clients of GW & Wade. GWWAMC solely executes transactions on behalf of these accounts and does not offer any investment advice. Whether an individual is acting on behalf of GW & Wade in its capacity as an investment adviser with fiduciary obligations to our clients or GWWAMC, a broker-dealer, or both is a significant fact. In particular, it affects the federal legal requirements that are applicable to the investment advice that a client receives. Specifically, since all investment advice is given by personnel acting solely on behalf of GW & Wade, the federal legal requirements under the Investment Advisers Act of 1940 (“Advisers Act”) apply to that investment advice. Under these circumstances, the federal legal requirements applicable to investment advice provided by broker-dealers do not apply to the advice clients receive even though persons providing the investment advice are registered representatives of GWWAMC as well as representatives of GW & Wade. If we advise a client about the choice of investing through an advisory arrangement or a brokerage- only arrangement, we have a conflict of interest. It is in our financial interest for a client to invest through an investment advisory arrangement with GW & Wade because a client compensates us for that service. It is not in our financial interest for a client to invest through a brokerage arrangement in which we are not involved as their investment adviser. There are circumstances under which a client’s best interest could be served by entering into a brokerage arrangement in which an investment adviser is not involved. A client may not wish to receive investment advice or may wish to receive one-time investment advice rather than continuing investment advice. For example, a client may wish to buy and hold a portfolio of securities for an extended period and not wish to have that portfolio monitored in light of the cost of an investment advisory arrangement. Given that GW & Wade only provides investment advice, GWWAMC brokerage-only accounts (i.e., where no investment advice is given) have only been offered to clients that request a non- advisory account or relationship. We are not offering new brokerage-only accounts at GWWAMC. We seek to address this conflict of interest by bringing it to the attention of clients in this Brochure so they may evaluate any recommendation we make to them about the arrangement type in light of the conflict. As a fiduciary, GW & Wade has duties of care and of loyalty to our investment advisory clients

and we are subject to obligations imposed on us by the federal and state securities laws. As a result, clients have certain rights that they cannot waive or limit by contract. Nothing in our investment advisory agreement should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights investment advisory clients possess. A. Investment Management For investment management, clients typically engage GW & Wade to provide services on a discretionary basis. This means that we make investment decisions on behalf of the client. We have a limited number of non‐discretionary relationships, where it is the client’s decision whether to implement our recommendations. As of December 31, 2022, GW & Wade managed approximately $8.9 billion in discretionary assets and $10.8 million in non‐discretionary assets. GW & Wade invests client assets in mutual funds exchange-traded funds (“ETFs”) that track actively or passively-managed indices of securities as well as individual equities and fixed income securities, and, from time to time, options. We also use third‐party separate account managers (which invest in individual equities and/or fixed income securities) that are selected through the due diligence process described in Item 8 below to manage certain assets for some of our clients. On a limited basis, when clients have expressed an interest and we believe that the investments are suitable and consistent with their investment objectives, we may recommend private investments to them. We have also approved an exchange-traded trust that tracks a basket of cryptocurrency futures for use upon client request. See Item 8, Methods of Analysis. GW & Wade recommends that clients invest in 529 Plans based on a variety of factors, including tax implications, investment options and plan services and administration. We recommend that clients invest in plans outside their state of residence when we believe that the investment options available to us on behalf of our clients outweigh the benefits of a modest state tax deduction. We have a conflict because we are incentivized to recommend this plan, which enable us to be paid an investment advisory fee on those 529 Plan assets. See Item 5.C., 529 Plans, for a discussion of our receipt and retention (without crediting) of 12b-1 fees paid to GWWAMC from mutual fund shares held in a 529 Plan as our compensation for advisory services in some accounts. See, generally, Item 5, Fees and Compensation and Item 12, Brokerage Practices, for a discussion of the fees, expenses, conflicts and mitigating factors applicable to clients’ advisory arrangements with us including, without limitation, our receipt of indirect compensation for investment management services through GWWAMC’s receipt of 12b-1 fees. Items 5.E, F and G, Item 12, and Item 14., Client Referrals and Other Compensation, describe benefits and payments received by GW & Wade from Fidelity and NFS in connection with brokerage/custodial services they provide to clients. See also Item 5.D., Other Assets Excluded from Asset-Based Management Fee. A discussion of the implications of entering into directed brokerage arrangements including using GWWAMC or Fidelity to execute transactions appears in Item 12.B. Brokerage Practices/ Directed Brokerage. Item 5.H., Other Expenses Associated with Mutual Funds and ETFs, discusses mutual funds’ expense ratios and share classes, and we describe that: mutual funds have internal costs; mutual funds offer different share classes; different share classes have different fees and expenses and therefore, different returns; share classes that pay a 12b‐1 fee generally have a higher expense ratio than other share classes of the same fund that do not pay a 12b‐1 fee by an amount at least equal to the amount of the 12b-1 fee; the share classes of a fund that have higher expense ratios have lower returns than the share classes of the same fund with lower expense ratios; and most mutual fund companies offer a class of shares that does not pay a 12b-1 fee that are available to GW & Wade’s advisory clients. B. Third‐Party Advisory Services GW & Wade sometimes recommends third-party investment advisers to manage separate accounts. In recommending third-party separate account managers, we generally consider the same factors as described in Item 8, Methods of Analysis, below, as well as the client’s account size. Clients should refer to the third-party manager’s disclosure documents for a full description of the services offered by that adviser. We monitor these third‐party managers and remain responsible for overall asset allocation of the client’s portfolio. The client determines whether to implement our advice concerning implementation of, and any change to, a third-party manager. Our arrangements relating to these managers take different forms, with a limited number provided through unaffiliated “wrap fee” programs, which typically include the cost of brokerage in an overall fee. Clients in these portfolios are encouraged to refer to the respective program’s wrap brochure. We do not sponsor or provide portfolio management services to wrap fee programs. See Item 5. I., Fees and Compensation, Third-Party Management Services and our selection process is set forth in Item 8, Methods of Analysis. A discussion of the implications of entering into directed brokerage arrangements including using GWWAMC or Fidelity to execute transactions appears in Item 12.B. Brokerage Practices/ Directed Brokerage. **** Please refer to Item 8 for a description of Methods of Analysis, Investment Strategies and Risk of Loss associated with GW & Wade’s investment strategies used in connection with each type of advisory arrangement that we offer. C. ERISA Plans GW & Wade 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 plans and ERISA plan participants. GW & Wade is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, and individual retirement accounts. As such, GW & Wade 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, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). See also Item 5., Fees and Compensation. D. Financial Planning Services GW & Wade offers financial planning services to our clients. Substantive areas of planning include income tax, estate tax, asset allocation, casualty and life insurance, education funding, retirement analysis, cash flow, employee benefits, survivor income analysis and financial organization. This service typically involves at least annual meetings between the GW & Wade representative and the client. The focus of this service is to formulate and propose a financial plan taking into account the client’s objectives, planning horizons, and regulatory restrictions, if applicable. E. Trustee and Estate Administration Services For some clients, GW & Wade personnel serve as trustees or provide estate administration services. When we serve as a trustee of a client’s account, we are deemed to have custody of the assets in that account under the SEC’s “custody rule.” Please also see Item 15, Custody. F. Focus Treasury and Credit Solutions We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions with the assistance of our affiliate, Focus Treasury & Credit Solutions, LLC (“FTCS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a discussion of these services. G. SCS SCS Capital Management LLC (“SCS”) is, like GW & Wade, an indirect, wholly-owned subsidiary of Focus LLC and Focus Inc and is therefore our affiliate. Where suitable, GW & Wade’s clients have the option of investing in certain private investment vehicles managed by SCS. Please see Items 5.J., and 10 of this Brochure for further details about SCS. ****