GWM is an investment adviser providing financial planning, consulting, and investment management services. Prior to engaging GWM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with GWM setting forth the terms and conditions under which GWM renders its services (collectively the “Agreement”). Neither GWM nor the client may assign the Agreement without the consent of the other party. A transaction that does not result in a change of actual control or management of GWM is not considered an assignment. GWM has been in business since November 15, 2005. Jason R. Radabaugh, Christopher B. Downing, and Matthew B. Lowe are the principal owners of GWM. As of January 24, 2024, GWM had $1,110,493,792 of assets under management: $1,084,027,928 of which was managed on a discretionary basis and $26,465,864 of which was managed on a non-discretionary basis. This disclosure brochure describes the business of GWM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of GWM’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 GWM’s behalf and is subject to GWM’s supervision or control. Financial Planning and Consulting Services GWM provides its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment related matters). These include investment management services to individuals, trusts, businesses, qualified retirement plans, and charitable organizations on a fee for service basis. In performing its services, GWM 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. GWM will recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if GWM recommends its own services. The client is under no obligation to act upon any of the recommendations made by GWM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including GWM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of GWM’s recommendations. Clients are advised that it remains their responsibility to promptly notify GWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising GWM’s previous recommendations and/or services. Page 5 © MarketCounsel 2024 Investment Management Services Clients can engage GWM to manage all or a portion of their assets on a discretionary or non- discretionary basis. GWM primarily allocates clients’ investment management assets on a discretionary and/or a non- discretionary basis among Independent Managers (as defined below), mutual funds, exchange traded funds (“ETFs”), individual debt and equity securities, and/or options. GWM also provides advice about any type of investment held in clients' portfolios. GWM also renders non-discretionary investment management

services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans, and/or other products that are not be held by the client’s primary custodian. GWM helps certain clients manage payouts as well as direct or recommend 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. GWM tailors its advisory services to the individual needs of clients. GWM ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify GWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon GWM’s management services. Use of Independent Managers As mentioned above, GWM recommends 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 GWM or the client and the designated Independent Managers. GWM renders services to the client relative to the discretionary selection of Independent Managers. GWM also monitors and reviews the account performance and the client’s investment objectives. When selecting an Independent Manager for a client, GWM 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 GWM 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, are exclusive of, and in addition to, GWM’s investment advisory fee set forth above. Page 6 © MarketCounsel 2024 In addition to GWM’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 GWM. In such instances, GWM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Additions and Withdrawals to Accounts Clients may make additions to and withdrawals from their account at any time, subject to GWM’s right to terminate an account. Clients may withdraw account assets on notice to GWM, subject to the usual and customary securities settlement procedures. However, GWM designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives.