GMFG offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to GMFG rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with GMFG setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). GMFG filed for registration as an investment adviser in December 2022 and is owned by James Ronn, Donald Phillips, and Robert Phillips. As of December 31, 2023, GMFG had $424,484,981 assets under management. $347,916,422 of these assets were managed on a discretionary basis and $76,568,559 were managed on a non-discretionary basis. While this brochure generally describes the business of GMFG, 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 GMFG’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services GMFG offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Education Planning
• Benefit Planning
• Executive Benefit Strategies 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, GMFG 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. GMFG 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 Page | 5 © MarketCounsel 2024 recommend that clients engage GMFG 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 GMFG 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 GMFG’s recommendations and/or services. Wealth Management Services GMFG provides clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. GMFG primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, alternative investments and independent investment managers (“Independent Managers”) 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, 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 GMFG 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, GMFG 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. GMFG 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. GMFG 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 GMFG 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 GMFG 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. Consulting Services Through Mutual Securities, Inc. The Firm can provide advice to clients regarding their variable annuities and/or insurance policies through a relationship with Mutual Securities. Mutual Securities engages the Firm to advise the client on the investment of the subaccounts amongst the various options available. The services are provided to Mutual Page | 6 © MarketCounsel 2024 Securities for customers (“Brokerage Customers”) who provide written consent requesting to receive the Firm’s consulting services. The Firm only provides these services to clients that have signed an Advisory Agreement with the Firm and have consented to such with Mutual Securities. Retirement Plan Consulting Services GMFG 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 GMFG 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 GMFG’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Use of Independent Managers As mentioned above, GMFG can select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. GMFG evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. GMFG also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Page | 7 © MarketCounsel 2024 GMFG continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. GMFG seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.