Based in Woburn, MA, 93 Financial is a registered investment adviser and licensed insurance agency serving individuals, families, business owners, trusts and estates for financial planning, investment management, insurance and retirement planning. 93 Financial was founded as an insurance agency in 2004 and registered as an investment adviser in 2008. Lawrence E. Welch and Paul J. Welch are the principals of 93 Financial, and are joined by brothers James Welch and John Welch. 93 Financial’s unique one-on-one approach is a more traditional, customized kind of service that aims to build strong personal relationships with clients that develop into life-long partnerships. All decisions and services are designed with an in-depth understanding of the client’s goals and objectives. Prior to engaging 93 Financial to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with 93 Financial setting forth the terms and conditions under which 93 Financial renders its services (collectively the “Agreement”). As of January 16, 2024, 93 Financial had $638,844,083 of assets under management, all of which was managed on a discretionary basis. This disclosure brochure describes the business of 93 Financial. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of 93 Financial’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 93 Financial’s behalf and is subject to 93 Financial’s supervision or control. Financial Planning and Consulting Services 93 Financial 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 to the needs of the client, but generally include retirement planning. In performing its services, 93 Financial 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. 93 Financial may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if 93 Financial recommends its own services. The client is under no obligation to act upon any of the recommendations made by 93 Financial under a financial planning or consulting engagement or to engage the services of any such

recommended professional, including 93 Financial itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of 93 Financial’s recommendations. Clients are advised that it remains their responsibility to promptly notify 93 Financial if Page 5 © MarketCounsel 2024 there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising 93 Financial’s previous recommendations and/or services. Investment Management Services Clients can engage 93 Financial to manage all or a portion of their assets on a discretionary basis. 93 Financial primarily allocates clients’ investment management assets among mutual funds and exchange-traded funds (“ETFs”) in accordance with the investment objectives of the client. 93 Financial also provides advice about any type of investment held in clients' portfolios. 93 Financial 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 529 plans or other products that may not be held by the client’s primary custodian. In so doing, 93 Financial 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 product. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. 93 Financial tailors its advisory services to the individual needs of clients. 93 Financial consults with clients initially and on an ongoing basis to determine the client’s objective, risk tolerance, time horizon and other factors that impact the client’s investment needs. 93 Financial then recommends investments it believes are suitable for the clients’ investment needs, goals, objectives, and risk tolerance. Clients are advised to promptly notify 93 Financial if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon 93 Financial’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in 93 Financial’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts.