TWAM has been in business since October 1988 and is principally owned by William S. Wright. TWAM provides comprehensive investment advisory services, including but not limited to investment management, investment planning, estate planning, tax planning, insurance planning and business planning. These services are designed to assist clients in understanding and identifying certain implications of decisions they may make in planning for the future. TWAM had $295,444,979 in discretionary assets under management as of December 31, 2023. Prior to engaging TWAM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with TWAM setting forth the terms and conditions under which TWAM renders its services (collectively the “Agreement”). Neither TWAM nor the client can 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 TWAM is not considered an assignment. This disclosure brochure describes the business of TWAM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of TWAM’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 TWAM’s behalf and is subject to TWAM’s supervision or control. Investment Management Services Clients can engage TWAM to manage all or a portion of their assets on a discretionary basis. TWAM primarily allocates clients’ investment management assets among mutual funds and individual debt and equity securities in accordance with the investment objectives of the client. TWAM can also provide advice about any type of investment held in clients' portfolios at the beginning of the advisory relationship. TWAM tailors its advisory services to the individual needs of clients. TWAM consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that impact the clients’ investment needs. TWAM endeavors to ensure that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. TWAM also can render 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 are not held by the client's primary custodian. In so doing, TWAM 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. Clients are advised to promptly notify TWAM if there are changes in their financial situation or investment objectives

or if they wish to impose any reasonable restrictions upon TWAM’s management services. Page 5 © MarketCounsel 2024 Financial Planning and Consulting Services As part of client’s portfolio management services, TWAM provides its clients with financial planning and consulting services (which may include tax-related and other non-investment related matters). These services include investment planning, retirement planning, estate planning, tax planning, insurance planning and business planning. These services are designed to assist clients in understanding and identifying certain implications of decisions they may make in planning for the future. In performing its services, TWAM 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. TWAM may recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if TWAM recommends its own services. The client is under no obligation to act upon any of the recommendations made by TWAM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including TWAM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of TWAM’s recommendations. Clients are advised that it remains their responsibility to promptly notify TWAM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising TWAM’s previous recommendations and/or services. Additions and Withdrawals to Accounts Clients may make additions to and withdrawals from their account at any time, subject to TWAM’s right to terminate an account. Clients shall provide TWAM with at least five (5) business days’ advance notice of any additions to or withdrawals from its account in order to ensure that TWAM is kept informed of the current status of the account. Clients may withdraw account assets on notice to TWAM, subject to the usual and customary securities settlement procedures. However, TWAM designs its portfolios as long- term investments and the withdrawal of assets can impair the achievement of a client’s investment objectives. Additions can be in cash or securities provided that TWAM reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. TWAM may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Page 6 © MarketCounsel 2024