HPAM (or the “Firm”) is an independent, fee-only, investment advisory firm with a fiduciary duty to the clients it serves. The Firm is passionate about learning and understanding its clients’ unique wealth management needs and then providing an objective, advice-driven solution. HPAM is dedicated to putting client interests ahead of the Firm and believes that in order to provide objective and high quality advice, HPAM must seek to mitigate any conflicts of interest. HPAM has been conducting business as a registered investment adviser since December 2011. The Firm is wholly owned by Ethan S. Braid. The Firm provides financial planning, investment management and wealth management services. Prior to engaging HPAM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with the Firm setting forth the terms and conditions under which HPAM renders its services (collectively the “Agreement”). As of January 31, 2024, the Firm has $160,097,599 in assets under management, all of which are managed on a discretionary basis. This Disclosure Brochure describes the business of HPAM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of HPAM’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 HPAM’s behalf and is subject to HPAM’s supervision or control. Wealth Management Services Clients can engage HPAM to manage all or a portion of their assets on a discretionary basis. In addition, HPAM may provide its clients with a broad range of comprehensive financial planning services which may include retirement, cash flow and estate planning as well as the preparation of a net worth statement (as detailed below). Clients can engage HPAM to provide investment management and financial planning services separately, or together as part of the Firm’s overall wealth management offering. Retirement Planning The Firm’s retirement planning process is focused on identifying sources of retirement cash flows (investments, real estate, pensions, etc.) and analyzing the risk metrics associated with these sources of cash flow. HPAM strives to achieve two goals in its retirement planning process. First, to learn and understand the client’s cash flow needs and to educate the client on what amount of cash flow their portfolio can produce. Second, to manage the client’s portfolio with an emphasis on preserving capital, while at the same time seeking to provide the necessary cash flows needed throughout the client’s retirement. Page 5 © MarketCounsel 2024 Cash Flow Planning Cash flow analysis can be very helpful for clients when trying to plan future flows of income and expenses. The Firm may also incorporate planned nonrecurring events such as paying for college or a second home. Net Worth Statement The Firm may prepare a personal net worth statement for certain clients. This output demonstrates what a client owns, how assets are titled (individual name, trust name, joint, etc.) and what liabilities exist. This document

can prove helpful when conducting estate planning. Estate Planning HPAM’s estate planning process begins with the development of a personal net worth statement. Once the personal net worth statement is produced, the Firm learns the client’s estate planning objectives. The Firm then reviews account registrations, beneficiary designations and existing documents and discusses wealth transfer and gifting strategies. In general, the Firm finds that when estate planning has already been conducted, certain assets are incorrectly titled relative to the existing plan. The Firm may but is not obligated to coordinate with separate legal counsel for estate planning services. Tax Planning and Preparation HPAM may also assist clients with income tax planning and preparation. With respect to planning, the Firm periodically consults with clients on fulfilling tax compliance requirements and identifying opportunities for reducing current and future tax liabilities. With respect to tax preparation, the Firm assists clients with annual tax preparation and filing. The Firm may but is not obligated to coordinate with separate tax professionals for tax planning and preparation services. Investment Management As part of HPAM’s management services, the Firm primarily allocates clients assets among exchange- traded funds (“ETFs”), individual equities, and mutual funds. As detailed in Item 8, the Firm may also utilize cash, certificates of deposits (“CDs”), treasuries, individual debt securities and/or options in accordance with the investment objectives of the client. In addition, HPAM may recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, pooled investment vehicles and fund-of-funds when consistent with the clients’ investment objectives. 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. Page 6 © MarketCounsel 2024 The Firm tailors its advisory services to the individual needs of clients. HPAM consults with clients initially and on an ongoing basis as needed to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. For certain clients, the Firm may also develop an investment policy statement (“IPS”). HPAM seeks to ensure that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify HPAM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions on HPAM’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in HPAM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts.