Gateway offers hands-on, integrated financial planning and investment services designed to simplify clients’ financial affairs and align them with their family values and aspirations. Gateway has been in business since January 2010 and is owned by Brian J. Power, Jay H. Flamme, and Glenn A. Blachman. As of December 31, 2023, Gateway manages $743,748,220 in assets on a discretionary basis. Prior to engaging Gateway to provide any of the foregoing investment advisory services, clients are required to enter into one or more written agreements with Gateway setting forth the terms and conditions under which Gateway renders its services (collectively the “Agreement”). This Disclosure Brochure describes the business of Gateway. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Gateway’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 Gateway’s behalf and is subject to Gateway’s supervision or control. Financial Planning Services Gateway provides its clients with a broad range of comprehensive financial planning services. These services generally include retirement planning, education planning, survivorship and insurance planning, estate and tax planning. These services may be included as part of Gateway’s wealth management services, described below. Gateway also offers advice on cash flow and debt management, tax planning, liability management strategies, and estate and wealth transfer planning. In performing its services, Gateway is not required to verify any information received from clients or from clients’ other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Gateway will recommend the services of itself, its Supervised Persons in their individual capacities as insurance agents, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Gateway recommends its own services. The client is under no obligation to act upon any of the recommendations made by Gateway under a financial planning engagement or to engage the services of any such recommended professional, including Gateway itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Gateway’s recommendations. Clients are advised that it remains their responsibility to promptly notify Gateway if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Gateway’s previous recommendations and/or services. Investment and Wealth Management Services Gateway provides discretionary and non-discretionary investment management services. Gateway also provides clients with wealth management services, which includes a broad range of comprehensive financial planning services (as needed), as well as discretionary or non- discretionary management of investment portfolios. Gateway primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”), and managed futures in accordance with the investment objectives of each client. Gateway also provides advice about any type of legacy position or investment otherwise held in clients' portfolios. Gateway also renders non-discretionary investment management services to clients regarding variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans

or other products that may not be held by the client’s primary custodian. In so doing, Gateway either directs or recommends the allocation of client assets among the various investment options that are available within the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Gateway tailors its advisory services to the individual needs of clients. Gateway 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. Gateway ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Gateway if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Gateway’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in Gateway’s sole, discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Use of Independent Managers As mentioned above, Gateway 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 Gateway or the client and the designated Independent Managers. Gateway renders services to the client relative to the discretionary selection of Independent Managers. Gateway also monitors and reviews the account performance and the client’s investment objectives. Gateway 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 selecting an Independent Manager for a client, Gateway 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 Gateway 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, Gateway’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by Gateway, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to Gateway’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 Gateway. In such instances, Gateway may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers.