Freedom Day Solutions offers investment management services. Prior to Freedom Day Solutions rendering such services, clients are required to enter into one or more written agreements with Freedom Day Solutions setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Freedom Day Solutions has been registered as an investment adviser since January 2006 and is wholly owned by Ryan J. Krueger and Michael B. Catalano. As of January 31, 2024, Freedom Day Solutions had $422,931,342 assets under management, $364,213,240 of which was managed on a discretionary basis and $58,718,102 of which was managed on a non-discretionary basis. While this brochure generally describes the business of Freedom Day Solutions, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Freedom Day Solutions’ behalf and are subject to the Firm’s supervision or control. Investment Management Services Freedom Day Solutions manages client investment portfolios on a discretionary or non-discretionary basis. Freedom Day Solutions primarily allocates client assets among various exchange-traded funds (“ETFs”) and individual debt and equity securities in accordance with their stated investment objectives. In addition, Freedom Day Solutions will manage a certain portion of a client’s assets through investments in digital assets where the Firm has determined the client has sufficient knowledge of the digital asset space and is able to handle the inherent risk of digital assets. Digital assets include, but are not limited to, Bitcoin, Ethereum, Stablecoin and other cryptocurrency investments (all referred to as “Digital Assets” throughout this brochure). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Freedom Day Solutions to manage and/or 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, Freedom Day Solutions 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. Freedom Day Solutions tailors its investment management services, as described herein, to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a Page | 5 © MarketCounsel 2024 manner consistent with those needs and objectives. Freedom Day Solutions consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Freedom Day Solutions if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios.

Clients can impose reasonable restrictions or mandates on the management of their accounts if Freedom Day Solutions 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. Sub-Advisory Services to Other Investment Advisers A sub-advisory relationship occurs when Freedom Day Solutions enters into an agreement with an unaffiliated registered investment adviser (“the Delegating Adviser”) to manage client investment portfolios on a discretionary basis to certain of the Delegating Advisers’ clients (each a “Sub-Advisory Client”). For such relationships, Freedom Day Solutions will place, per the written agreements between Freedom Day Solutions, the Delegating Adviser and/or Sub-Advisory Clients, orders for the execution of investment transactions for the Sub-Advisory Clients’ assets delegated to its management. Freedom Day Solutions provides such management consistent with each Sub-Advisory Client’s individual stated goals, objectives, and risk tolerances, as provided to Freedom Day Solutions by the Delegating Adviser. Sub- Advisory Clients incur fees related to both Freedom Day Solutions’ sub-advisory services and the on-going services provided by the Delegating Adviser. Those fees can be presented separately or in combination by the Delegating Adviser in its agreement with the Sub-Advisory Client. Such fees may be higher than a Sub-Advisory Client would otherwise pay in the event they engaged Freedom Day Solutions directly. Sub-Advisory Services to the Freedom Day Dividend ETF In addition to the above-described arrangements, Freedom Day Solutions acts as the sub-adviser of the Freedom Day Dividend ETF (Symbol: MBOX) (“the FDS ETF”), a series of the Alpha Architect ETF Trust, a registered investment company. Empowered Funds, LLC (“Empowered Funds”) serves as the investment adviser to the FDS ETF. The terms of the sub-advisory services will be set forth in a sub- advisory agreement (“Sub-Advisory Agreement”) between Empowered Funds and the Firm. Additional information about the sub-advisory services the Firm provides to the FDS ETF is available in the FDS ETF’s prospectus and Statement of Additional Information ("SAI"), provided upon request. As sub-adviser, Freedom Day Solutions has full discretion with regards to investments made on behalf of the FDS ETF and does not tailor its advisory services to the individual needs of investors in the FDS ETF. Where appropriate for investment management clients, Freedom Day Solutions may exercise its discretionary authority and, without further approval from such clients, invest a percentage of their assets in the FDS ETF. Because the Firm will receive compensation as the sub-adviser to the FDS ETF, the Firm Page | 6 © MarketCounsel 2024 will have a conflict of interest to recommend the FDS ETF. The Firm has procedures in place whereby it will ensure that all recommendations are made in its clients’ best interest. Estate Planning Freedom Day Solutions offers estate planning services to our investment management clients to assist with general information as it applies to reviews of existing plans, gathering information needed to provide outside firms in the creation of documents, and updating existing plans for clients. The fees associated with estate planning services are separate and in addition to the ongoing asset based advisory fees and are disclosed in Item 5.