The Gleason Group was formed in 2015 and is owned by Gavin T. Gleason since May 15, 2015. As of the close of business on December 31, 2023, The Gleason Group has a total of $ 785,409,717 assets under management, $758,856,776 on a Discretionary basis and $ 26,552,941 on a Non-Discretionary Basis. While this brochure generally describes the business of The Gleason Group, 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 any other person who provides investment advice on The Gleason Group’s behalf and is subject to the Firm’s supervision or control. Wealth Management Services The Gleason Group provides individual and business clients with wealth management services as part of a comprehensive wealth management engagement, which includes a broad range of financial planning and consulting services and discretionary and/or non-discretionary management of investment portfolios. Prior to The Gleason Group rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with The Gleason Group setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Financial Life Planning and Consulting Services The Gleason Group offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions: ● Financial Planning ● Retirement Planning ● Education Planning ● Estate Planning ● Beneficiary Coordination ● Risk Management ● Insurance Analysis ● Debt Analysis ● Lending Solutions ● Charitable Strategies ● Advisory Team Coordination ● Social Security and Medicare Guidance In performing these services, The Gleason Group is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. The Gleason Group may recommend clients engage the Firm for additional related services, 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 clients engage The Gleason Group or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by The Gleason Group under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising The Gleason Group’s recommendations and/or services. Page | 5 March 8, 2024 Investment Management Services The Gleason Group offers clients a broad range of discretionary and/or non-discretionary investment management services, including: ● Portfolio Design ● Behavioral Coaching ● Savings & Investment Strategies ● Income & Distribution Solutions ● Tax Strategies ● Reporting

& Tracking ● Retirement Plan Services The Gleason Group primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), index funds, and individual debt and equity securities, in accordance with their stated investment objectives. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage The Gleason Group 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, The Gleason Group 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. The Gleason Group tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. The Gleason Group 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 The Gleason Group if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if The Gleason Group 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. Retirement Plan Services The Gleason Group is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to certain ERISA plans and plan participants. The Gleason Group is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to certain ERISA plans, ERISA plan participants, IRAs and IRA owners (collectively, “Retirement Account Clients”). As such, The Gleason Group is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). The Gleason Group also provides certain non-discretionary investment-related services to retirement plans qualified under sections 401(a) and (k) of the Internal Revenue Code of 1986, as amended. These services Page | 6 March 8, 2024 do not include discretionary investment management and The Gleason Group does not act as either a fiduciary, an administrator, or a trustee in connection with providing these services.