Exchange Place is an investment adviser providing financial planning, consulting and investment management services. Prior to engaging Exchange Place to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Exchange Place setting forth the terms and conditions under which Exchange Place renders its services (collectively the “Agreement”). Exchange Place has been in business since May 2003 and is owned by John Ollquist and Thomas Padovano. As of February 27, 2024, Exchange Place has $308,908,738 of assets under management, all of which are managed on a discretionary basis. This disclosure brochure describes the business of Exchange Place. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Exchange Place’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 Exchange Place’s behalf and is subject to Exchange Place’s supervision or control. Financial Planning and Consulting Services Exchange Place provides its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment related matters). These services are tailored based upon the individual needs of the client. In performing its services, Exchange Place 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. Exchange Place may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Exchange Place recommends its own services. The client is under no obligation to act upon any of the recommendations made by Exchange Place under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Exchange Place itself. The client retains absolute discretion

over all such implementation decisions and is free to accept or reject any of Exchange Place’s recommendations. Clients are advised that it remains their responsibility to promptly notify Exchange Place if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Exchange Place’s previous recommendations and/or services. Page 5 © MarketCounsel 2024 Investment Management Services Clients can engage Exchange Place to manage all or a portion of their assets on a discretionary basis. Exchange Place primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), and individual debt securities in accordance with the investment objectives of the client. Exchange Place also provides advice about any type of investment held in clients' portfolios. Exchange Place also renders non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In so doing, Exchange Place either directs or recommends 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 client. Exchange Place tailors its advisory services to the individual needs of clients. Exchange Place 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. Exchange Place ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Exchange Place if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Exchange Place’s management services, including any limitations on investing in certain types of securities. Page 6 © MarketCounsel 2024