VWP offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to VWP rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with VWP setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). VWP was for registration as an SEC registered investment adviser on July 20, 2021 and is owned by Enrique Figueroa and Christopher Caruso. As of February 1, 2024, the Firm has approximately $ 120,309,852 in assets under management, all of which is managed on a discretionary basis. While this brochure generally describes the business of VWP, 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 VWP’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services VWP offers clients a broad range of financial planning and consulting services, such as retirement planning and cash flow 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, VWP 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. VWP recommends certain clients engage the Firm for additional related services 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 VWP or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by VWP 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

VWP’s recommendations and/or services. Investment and Wealth Management Services VWP provides clients with wealth management services which include a broad range of financial planning and consulting services as well as management of investment portfolios. The Firm provides discretionary management of client assets, but clients may limit the Firm’s discretion on specified accounts. Page | 5 © MarketCounsel 2024 VWP primarily allocates client assets among various mutual funds and exchange-traded funds (“ETFs”) in accordance with their stated investment objectives. On a less frequent basis, the Firm allocates assets among individual debt and equity securities and privately placed securities (including debt, equity and/or interests in pooled investment vehicles). 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. Clients can engage VWP 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, VWP 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. VWP 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. VWP 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 VWP 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 VWP 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.