BWM offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to BWM rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with BWM setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). BWM filed for registration as an investment adviser in May 2023 and is owned by Denny Stoddard. As of February 14, 2024 BWM had $143,963,518, $143,728,036 of which were managed on a discretionary basis and $235,482 of which were managed on a non-discretionary basis. While this brochure generally describes the business of BWM, 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 BWM’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services BWM offers clients a broad range of financial planning and consulting services, including (but not limited to) retirement planning, educational planning, estate planning and insurance 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, BWM 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. BWM 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 recommend that clients engage BWM 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 BWM 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 BWM’s recommendations and/or services. Page | 5 © MarketCounsel 2024 Investment and Wealth Management Services BWM provides certain 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. BWM primarily allocates client assets among various stocks, bonds, exchange traded funds (“ETFs”), exchange-traded notes (“ETNs”), closed-end funds, mutual funds, structured notes, and alternative investments 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 BWM 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, BWM 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. BWM 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. BWM 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 BWM 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 BWM 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. The Firm does not serve as the sponsor of a wrap fee program (i.e., an arrangement where certain brokerage commissions and transaction costs are absorbed by the Firm). Nonetheless, the Firm is a manager through wrap programs as the Firm principally provides investment management services through accounts available through wrap fee programs offered and administered by Raymond James & Associates, Inc. (“Raymond James”), member NYSE/SIPC, or another of its affiliates. The wrap fees for participation in such programs include many transaction costs associated with execution of securities transactions. For more information relating to the wrap programs offered by Raymond James, please refer to Raymond James’ wrap fee disclosure brochure (the “Wrap Brochure”), which can be found at www.adviserinfo.sec.gov. The Raymond James programs require clients to sign separate agreements depending on the program. BWM will be named as the investment adviser (either directly or through its investment adviser representatives) in such agreements. Page | 6 © MarketCounsel 2024 The Firm expects to provide much of its investment management services through the Raymond James Ambassador Program. The Ambassador Program utilizes a wrap fee advisory account, offered and administered by Raymond James, in which the client is provided with ongoing investment advice and monitoring of securities holdings by the Firm. The Firm provides discretionary or non-discretionary management of the Ambassador Account according to the client’s objectives. The Ambassador Account offers Clients the ability to pay an Asset-based Fee in lieu of a commission for each investment. For assets outside of the Ambassador Program, clients may (depending on the other relationship) pay additional brokerage expenses as further described below. Use of Independent Managers As mentioned above, BWM 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 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. BWM 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. BWM also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. BWM 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. BWM seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Firm expects to engage the Independent Managers through one or more of Raymond James’s programs. The Independent Managers can be affiliated with Raymond James which results in a conflict of interest for Raymond James to approve and favor these Independent Managers in their programs. The Firm does not, however, receive any additional compensation if a Raymond James affiliate is selected as the Independent Managers. Clients will sign a separate agreement with Raymond James that names BWM (either directly or through an investment adviser representative of BWM) as the investment adviser. Clients should review the Wrap Brochure for more information on the RJCS Program. Page | 7 © MarketCounsel 2024