SFO offers a variety of advisory services, which include financial planning, consulting, subscription and investment management services. Prior to SFO rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with SFO setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). SFO filed for registration as an investment adviser in January 2023 and is owned by Nicholas D. Stenger and Darin Bond Roth. As of March 20, 2024, SFO had $270,984,698 assets under management all of which were managed on a discretionary basis. While this brochure generally describes the business of SFO, 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 SFO’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services SFO offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Cash Flow Forecasting
• Trust and Estate Planning
• Insurance Planning
• Retirement Planning
• Tax Planning
• Education 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, SFO 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. SFO recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or an affiliated investment agency, 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 SFO 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 SFO 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 Page | 5 © MarketCounsel 2024 investment objectives for the purpose of reviewing, evaluating or revising SFO’s recommendations and/or services. Stenger+ Stenger+ is a subscription service that allows subscribers to access the Firm’s premium shows, podcasts, articles and webinars. Stenger+ does not include any individualized investment advice. The subscription cost is $5 per month and is included in the investment management and wealth management services described below for any client with $1,000 or more in a managed account. Investment and Wealth Management Services SFO 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. They type of services (including investment management only, wealth management, and family office services) will depend on the client’s needs as well as the assets under management. SFO primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, 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 SFO 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, SFO 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. SFO 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. SFO 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 SFO 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 SFO 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. Page | 6 © MarketCounsel 2024 The Firm currently has the following offerings: Stenger Wealth Management Wealth management clients have unlimited access to an SFO investment adviser representative who will create a comprehensive, custom financial plan and deliver detailed financial coaching to the client and their family. The investment adviser representative will proactively host an annual review meeting each year and a series of additional check-in calls as needed. Fees start at 1.25% per year. Stenger Family Office For clients with $2 million investable assets or more, SFO combines our wealth management offering with tax planning and preparation and estate planning services. SFO clients have dedicated, unlimited access to a senior level investment adviser representative. Clients also have access to accountants and estate planning attorneys. SFO Family Office clients receive an annual engagement bonus of $650 towards the cost of tax preparation services and $500 towards the cost of estate planning services offered through Legacy & Life Law Firm. In addition to the annual review and mid-year check in process, Family Office clients will receive an estate plan review with a team of estate planning attorneys. Stenger Investment Management Clients that do not require a full-service relationship with an investment adviser representative can access our proprietary, custom investment portfolios. Portfolios can be customized to meet certain objectives or invested in a model portfolio managed by the SFO Investment Committee. Stenger Investment Management employs the use of tax loss harvesting and because accounts are highly customized, typically do not issue costly capital gains distributions, a common issue with mutual funds and ETFs. Proxy voting is maintained by the SFO Investment Committee. Investment Management clients also have access to tax planning, estate planning and insurance services for an additional fee. Stenger GoldDesk Investors with less than $100,000 who would like to start a full-service financial planning and investment relationship with an investment adviser representative can access all the resources of SFO with a low minimum account size of $1,000. Stenger GoldDesk clients have access to an investment adviser representative and will receive a fully customized and comprehensive financial plan, reviewed once per year. GoldDesk clients also have access to tax planning, estate planning and insurance services for an additional fee. Use of Independent Managers As mentioned above, SFO selects 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 Page | 7 © MarketCounsel 2024 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. SFO 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. SFO also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. SFO 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. SFO seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.