SGAM offers investment management/advisory and ERISA plan services to its clients. Prior to SGAM rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with SGAM setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). SGAM has been registered as an investment adviser since October 2017. The Firm is owned by the following entities: the MTK Irrevocable Trust; the W.R. Stephens, Jr. Revocable Trust; and the Elizabeth S. Campbell Revocable Trust. The trustees of these entities are, respectively, Alan B. Tedford, W.R. Stephens, Jr., and Elizabeth S. Campbell. As of March 13, 2024, the Firm had $1,137,726,808 in assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of SGAM, 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 SGAM’s behalf and is subject to the Firm’s supervision or control. Investment Management Services SGAM manages client investment portfolios on a discretionary basis. SGAM has two primary offerings. The Firm has an ETF Model Strategy in which client assets are invested primarily in exchange-traded funds (“ETFs”) through a series of proprietary models managed by SGAM. In addition, the Firm has a fixed- income only offering (the Fixed Income Strategy) in which client assets are invested in individual debt offerings and exchange traded funds. 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 SGAM 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, SGAM 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. SGAM provides investment advice to clients based on their authorized asset allocation preferences and stated investment boundaries which are determined by the clients after extensive initial meetings with the clients. The Firm does not otherwise consider each client’s individual investment objectives, time horizon or other factors when making investment decisions on behalf of its clients. Clients are advised to promptly Page | 5 © MarketCounsel 2024 notify SGAM 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 SGAM 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. ERISA Plan Services SGAM provides advisory services to retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), including participant-directed defined contribution plans, such as 401(k) plans, defined contribution plans that are not participant-directed and defined benefit plans (“ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an investment advisory or investment management agreement with SGAM describing the services that SGAM will perform for the ERISA plan and its participants. SGAM provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. ERISA Fiduciary Services to Participant-Directed Plans For participant-directed defined contribution plans, SGAM provides investment advisory services on a non- discretionary basis and in that capacity, the ERISA Plan Client retains and exercises, final decision-making authority and responsibility for the implementation (or rejection) of SGAM’s recommendations or advice. SGAM’s ERISA fiduciary investment advisory services include assisting the ERISA Plan Client in developing and implementing an investment policy statement, assisting the ERISA Plan Client in selecting a broad range of plan investment options consistent with ERISA Section 404(c), assisting the ERISA Plan Client in making decisions about the selection, retention, removal and/or replacement of plan investment options, and if the ERISA Plan Client has determined that the plan should have a qualified default investment alternative (a “QDIA”) for participants who fail to make an investment election, assisting in the selection of the investment that will serve as a QDIA. If the ERISA Plan Client engages an unaffiliated third-party registered investment adviser to select the plan investment line-up, then in that case, SGAM provides non-discretionary investment advice to the ERISA Plan Client about the line-up and any recommended changes thereto, and assists the ERISA Plan Client in monitoring the performance of the unaffiliated third-party registered investment adviser. SGAM also provides asset allocation services to assist plan participants in determining the allocation of money in their Plan account among the Plan’s designated investment alternatives. The asset allocation service

is not an investment itself, but instead a service to help participants to decide how to invest their Plan account. In addition, SGAM provides participant-level investment advisory services about asset classes and plan investment options on a non- discretionary basis to participants in the ERISA Plan who elect to use this service and if so elected, the participant will retain and exercise final decision-making authority and responsibility for the implementation (or rejection) of SGAM’s recommendations or advice. Page | 6 © MarketCounsel 2024 Non-Fiduciary Services to Participant-Directed Plans SGAM’s non-fiduciary services to participant-directed defined contribution plans include assisting the ERISA Plan Client in monitoring, selecting and supervising plan service vendors; increasing retirement plan participation among employees and improving investment and financial understanding by employees; and educating plan participants about general investment principles and the investment options available under the plan. Consulting Services to Employer Plan Sponsors of Participant-Directed Plans SGAM also provides consulting services to the employer plan sponsor of participant-directed defined contribution plans. Those services consist of educating the plan sponsor on retirement plan features and plan design options and assisting with understanding and evaluating plan design issues and considerations. ERISA Fiduciary Services to Defined Contribution Plans that are not Participant-Directed and Defined Benefit Plans (“Pooled ERISA Plans”) For defined contribution plans that are not participant-directed and defined benefit plans, SGAM’s fiduciary services consist of investing and reinvesting the plan assets, in its sole discretion, in the SGAM managed portfolio(s) selected by the ERISA Plan Client. The ERISA Plan Client is solely responsible for selecting the SGAM managed portfolio or portfolios in which plan assets will be invested and appoints SGAM as an investment manager under Section 3(38) of ERISA with respect to its management of the plan assets invested in the selected SGAM managed portfolios. For a more detailed description of SGAM’s fiduciary and non-fiduciary services, the ERISA Plan Client should refer to the investment management or advisory agreement. Rollover Recommendations A conflict of interest would arise if SGAM were to make recommendations about retirement plan distributions and rollovers to IRAs, IRA to IRA transfers, IRA to plan rollovers, plan to plan rollovers and change of account types for a retirement plan or IRA (each, a “rollover recommendation”) if it results in SGAM receiving compensation that it would not have received absent the recommendation, for example, fees for advising or managing a rollover IRA. In that instance, SGAM would manage this conflict through a process designed to develop an informed recommendation in the best interest of the client. If SGAM were to make a rollover recommendation, it would be fiduciary advice under the Investment Advisers Act of 1940 (the “Advisers Act”). Also, if SGAM were to provide investment advice to a plan participant about his/her retirement plan account or to an IRA owner about his/her IRA, including a rollover recommendation, SGAM would be a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. In addition to being a conflict of interest, it would also be a prohibited transaction under ERISA and/or the Code when SGAM receives compensation as a result of the rollover that it would Page | 7 © MarketCounsel 2024 not have received absent the recommendation. In that circumstance, SGAM would need to comply with the conditions of exceptions to the prohibited transaction rules (e.g., an applicable prohibited transaction exemption such as PTE 2020-02 or non-enforcement policy). As a result, SGAM does not make rollover recommendations. Instead, SGAM provides information about the alternatives available to plan participants and IRA owners, and answers their questions in a neutral, educational manner. In that way, the individual can make an informed decision about whether to take a distribution and, if so, whether to roll it over to an IRA with SGAM or another IRA provider. No client is under an obligation to roll over ERISA Plan or IRA assets to an account advised or managed by SGAM. Services Provided to Nonqualified Deferred Compensation Plans (“Top Hat Plans”) SGAM also provides investment advisory and/or investment management services to unfunded nonqualified deferred compensation plans that are established primarily for the purpose of providing deferred compensation for a select group of management or highly compensated employees (referred to here as “Top Hat Plans”). Top Hat Plans are not subject to the fiduciary rules and prohibited transaction rules of ERISA and the Code. Investment Management Services Provided to Individual ERISA Plan Accounts Individual clients can engage SGAM to provide investment management services with respect to the individual's ERISA Plan account in a participant-directed ERISA Plan, if and to the extent permitted under the ERISA Plan documents. In that case, the individual client is required to enter into an investment management agreement with SGAM describing the services. Such services are referred to here as "Participant Account Investment Management Services".