GDS offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to GDS rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with GDS setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). GDS has been providing investment advisory services since October 1, 2021 and is principally owned by Glen Smith and Robert Casey. As of January 25, 2024, GDS had $891,704,184 assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of GDS, 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 GDS’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services GDS offers financial planning and consulting services along with its portfolio management services. These services can range from broad-based financial planning to consultative or single subject planning. In providing financial planning the Firm will gather information about the client’s financial circumstances and objectives, determine their current financial position and to define and quantify the client’s long-term goals and objectives. Once the Firm specifies those long-term objectives (both financial and non-financial), it will develop shorter-term, targeted objectives. Once the Firm reviews and analyzes the information provided by the client, it will deliver a written plan, designed to help the client achieve its stated financial goals and objectives. Financial plans are based on each client’s financial situation at the time the plan is presented, and on the financial information provided to the Firm. Clients are encouraged to promptly notify the Firm if their financial situation, goals, objectives, or needs change. In performing these services, GDS 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. GDS 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 GDS 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 GDS under a financial planning or consulting engagement. Clients are advised Page | 5 © MarketCounsel 2024 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 GDS’s recommendations and/or services. Wealth Management Services GDS offers discretionary portfolio management services. The Firm tailors its advisory services to the individual needs of clients. The Firm consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon, and other factors that may impact the clients' investment needs. The Firm has discretionary authority and responsibility to formulate investment strategies on the client’s behalf. Discretionary authorization allows the Firm to determine the specific securities, and the amount of securities, to be purchased or sold in the account without obtaining the client’s approval prior to each transaction. In limited circumstances, the Firm may accept non-discretionary authority. In those circumstance, the Firm will obtain the client’s approval prior to executing any transactions in the account. The client can accept

or reject the advice provided on a non-discretionary basis. GDS primarily allocates client assets among various equity securities, warrants, corporate debt securities (other than commercial paper), municipal securities, mutual fund shares, United States government securities, pooled investment vehicles, and exchange traded funds (“ETFs”). 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. GDS Model Portfolios As part of the Firm’s portfolio management services, it can invest client assets according to one or more model portfolios developed by the Firm. These models are based on research provided to the Firm by Raymond James Financial Services (“Raymond James”). The research and reports used on the Raymond James Core Growth Guided Model portfolio provide an allocation framework for the Firm to design models for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Raymond James notifies the Firm when changes are made to the Core Growth Guided Model Portfolio and the rationale for the change. Raymond James also posts updates about the model on a monthly basis which the Firm considers in its process. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Page | 6 © MarketCounsel 2024 When client accounts are managed using models, investment selections are based on the underlying model and the Firm does not develop customized (or individualized) portfolio holdings for each client. Therefore, clients cannot set restrictions on the specific holdings or allocations within that model, nor the types of securities that can be purchased in that model. Clients can put reasonable restrictions on the management of assets by the Firm, but the client may not get access to a particular model. The determination to use a particular model or models is always based on each client's individual investment goals, objectives and mandates. For more information on the Firm’s Model Portfolios, see Item 8: Methods of Analysis, Investment Strategies and Risk of Loss. Retirement Plan Rollover Recommendations The Firm is providing the following acknowledgment to you pursuant to Department of Labor guidance and rules. When the Firm provides investment advice to a client regarding a retirement plan account or individual retirement account, the Firm is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way the Firm makes money creates some conflicts with the client’s interests, so the Firm operates under a special rule that requires it to act in the client’s best interest and not put its interest ahead of the client’s. Under this special rule's provisions, the Firm must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put the Firm’s interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that the Firm gives advice that is in the best interest;
• Charge no more than is reasonable for our services; and
• Give the client basic information about conflicts of interest. The Firm benefits financially from a rollover of a client’s assets from a retirement account to an account that the Firm manages or provides investment advice, because the assets increase the Firm’s assets under management and, in turn, its advisory fees. As a fiduciary, the Firm only recommends a rollover when it believes it is in the client’s best interest.