D & P provides financial planning, consulting, and investment management services. Prior to engaging D & P to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with D & P setting forth the terms and conditions under which D & P renders its services (collectively the “Agreement”). D & P has been in business as an investment adviser since October 25, 2002. Mark Provost is the principal owner of D & P. D & P has $152,052,828 of assets under management as of December 31, 2023, all of which are managed on a non-discretionary basis. This Disclosure Brochure describes the business of D & P. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of D & P’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on D & P’s behalf and is subject to D & P’s supervision or control. Financial Planning and Consulting Services D & P may provide its clients with a broad range of comprehensive financial planning and consulting services. These services include retirement and education planning as they relate to the client’s investments. In performing its services, D & P is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. D & P may recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if D & P recommends its own services. The client is under no obligation to act upon any of the recommendations made by D & P under a financial planning or consulting engagement or to engage the services of any such recommended professional, including D & P itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of D & P’s recommendations. Clients are advised that it remains their responsibility

to promptly notify D & P if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising D & P’s previous recommendations and/or services. Investment Management Services Clients can engage D & P to manage all or a portion of their assets on a non-discretionary basis. D & P primarily allocates clients’ investment management assets on a non-discretionary basis among mutual funds, exchange-traded funds (“ETFs”), and individual debt and equity securities in accordance with the investment objectives of the client. D & P also provides advice about any type of investment held in clients' portfolios. Page 5 © MarketCounsel 2024 D & P also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans or other products that may not be held by the client’s primary custodian. In so doing, D & P either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. D & P tailors its advisory services to the individual needs of clients. D & P 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. D & P ensures that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. Clients are advised to promptly notify D & P if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon D & P’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 D & P’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts.