TSG offers a variety of advisory services, which include financial planning, consulting, and investment and wealth management services. Prior to TSG rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with TSG setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). TSG filed for registration as an investment adviser in October 2019 and is owned by Isao L. Shoji, Alvin K. Asimah, and Christopher D. Schumacher. As of December 31, 2023, TSG had $613,316,721 of assets under management, all managed on a discretionary basis. While this brochure generally describes the business of TSG, 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 other persons who provide investment advice on TSG’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services TSG offers clients a broad range of financial planning and consulting services, which include any or all of the following functions. The Firm focuses on key areas of financial planning as defined by CFP standards:
• Cash Flow Management
• Education Planning
• Retirement Planning
• Retirement Income Planning
• Tax Planning
• Protection Planning
• Estate Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, TSG 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. TSG recommends certain 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 for the Firm to recommend that clients engage TSG or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Under a financial planning or consulting engagement, clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by TSG. 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 TSG’s recommendations and/or services. Investment and Wealth Management Services TSG manages client investment portfolios on a discretionary or non-discretionary basis. In addition, TSG provides certain clients with wealth management services which include both a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. TSG primarily allocates client assets among various exchange-traded funds (“ETFs”) in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios which can include individual debt and equity securities and mutual funds. Clients can engage TSG 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, TSG 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. TSG 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. TSG 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 TSG 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 TSG 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. Institutional Intelligent Portfolios® Platform For certain Clients, TSG may recommend that all or a portion of a Client’s investment portfolio be established through an online investment management program offered by TSG and Charles Schwab & Co., Inc. (“Schwab”). Under this service, Clients will engage TSG through an investment management agreement for these advisory services and utilize the Institutional Intelligent Portfolios® (“IIP”) offered by Schwab Performance Technologies, a software provider affiliated with Schwab. IIP is an automated investment engine through which TSG manages the Client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the Client is eligible and elects). TSG will have the discretionary authority to instruct IIP with respect to portfolio construction, asset allocation and other investment decisions, subject to the limitations described herein. IIP will implement the portfolio and will have discretionary authority to trade the exchange-traded funds (“ETFs”) in the Client’s portfolio, including the purchase and sale of investments and the automatic rebalancing back to targets. IIP utilizes ETFs, representing various asset classes for the construction of investment portfolios. TSG will work with each Client to select a portfolio to meet the needs of the Client. The Client has limited ability to put restrictions on its accounts. The portfolios cannot contain investments that are not included in the IIP universe of ETFs and cash equivalents. TSG will delegate limited investment discretion to IIP to implement trading and rebalancing within the parameters of TSG’s investment strategies. TSG’s investment philosophy is long-term, but we may make such tactical overrides to take advantage of market pricing anomalies or strong market sectors. Client portfolios must maintain a minimum balance of $5,000 to be eligible for automatic rebalancing. TSG will provide the Client with IIP’s current Form ADV Part 2A – Disclosure Brochure (or a brochure that contains all required disclosures). The Advisor shall only earn its fees as described in Item 5 below. For additional information, please see Item 12 – Brokerage Practices. Retirement Plan Consulting Services TSG provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by TSG as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of TSG’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. TSG is deemed to be a fiduciary to advisory clients that are individual retirement accounts (IRAs) pursuant to regulations under the Internal Revenue Code of 1986 (the “Code”). As such, the Firm is subject to specific duties and obligations under the Code. Retirement Plan Rollovers When leaving an employer, there are typically four options regarding the existing retirement plan: (1) leave the assets in the former employer’s plan, if permitted, (2) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (3) roll over the assets to an Individual Retirement Account (“IRA”), or (4) take a full withdrawal in cash, which would result in ordinary income tax and a penalty tax if you are under the age 59 ½. If we recommend that you roll over your 401(k) or other qualified plan assets to an IRA, this rollover recommendation presents a conflict of interest in that we would receive compensation (or may increase current compensation) when investment advice is provided following your decision to roll over your plan assets. TSG will discuss your retirement plan options including retention of your 401(k) or qualified plan assets with your current plan, if allowed. Prior to making a decision you should carefully review the information regarding your rollover options and are under no obligation to rollover retirement plan assets to an account managed by us.