FGWP offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to FGWP rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with FGWP setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). FGWP filed for registration as an investment adviser in April 2024 and is owned by Jeremiah R. Winters and Catherine M.C. Atwood. As of the date of this filing, FGWP does not have any assets under management; however, the Firm reasonably expects to be eligible for registration with the SEC within 120 days of approval as an investment adviser. While this brochure generally describes the business of FGWP, 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 FGWP’s behalf and are subject to the Firm’s supervision or control. Wealth Management Services FGWP 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. The service is designed to assist clients in meeting their financial goals by ascertaining each client’s investment objectives. Thereafter, the Firm will have the responsibility and authority to formulate investment strategies on the client’s behalf. The Firm will conduct client meetings to understand their current financial situation, existing resources, and tolerance for risk. Based on what is learned, an investment approach is presented to the client, consisting primarily of individual stocks, bonds, ETFs, options, and mutual funds. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Upon client request, the Firm provides a summary of observations and recommendations for the planning or consulting aspects of this service. Clients that determine to engage the Firm on a non-discretionary investment advisory basis must be willing to accept that the Firm cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore, the Firm will be unable to affect any account transactions (as it would for its discretionary clients) without first obtaining the client ’s consent. Page | 5 © MarketCounsel 2024 The Firm offers individualized investment advice to clients. Each client may impose reasonable restrictions, in writing, on the types of investments to be held in the portfolio or the Firm’s services. Restrictions on investments in certain securities or types of securities may affect the performance of the account due to the level of difficulty of the restriction when managing the account. In performing the financial planning services, FGWP 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. FGWP 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 FGWP 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 FGWP 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 FGWP’s recommendations and/or services. Use of Independent Managers As mentioned above, FGWP 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. FGWP 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. FGWP also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. FGWP 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. FGWP seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Page | 6 © MarketCounsel 2024 Assets Held Away From the Firm FGWP can leverage an Order Management System through Pontera to implement investment selection and rebalancing strategies on behalf of the client in held away accounts (i.e., accounts not directly held with our recommended custodian). These are primarily 401(k) accounts, HSAs, 403bs, 529 education savings plans, 457 plans, profit sharing plans, and other assets not custodied with the Firm’s recommended custodian. The Firm regularly reviews the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way the Firm does other accounts, though using different tools as necessary. There may be a difference in the performance of FGWP’s strategies of an account using Pontera in comparison to accounts held at the recommended custodian. Dynasty Network FGWP has entered a contractual relationship with Dynasty Financial Partners, LLC ("Dynasty"), which provides the Firm with operational and back-office support including access to a network of service providers. Through the Dynasty network of service providers, FGWP can receive preferred pricing on trading technology, reporting, custody, brokerage, compliance, and other related services. Dynasty charges a "Program Fee" for different types of programs offered. Depending on the program used or chosen by the client, this Program Fee will be included as part of the client’s annual investment management fee, as described in Item 5 below or paid by the client. In addition, Dynasty's subsidiary, Dynasty Wealth Management, LLC ("DWM") is an SEC registered investment adviser, that provides access to a range of investment services including: separately managed accounts (“SMA”), mutual fund and ETF asset allocation strategies, and unified managed accounts ("UMA") managed by external Third-Party Managers (collectively, the "Investment Programs"). FGWP can separately engage the services of Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs, the Firm will maintain the ability to select the specific, underlying Third Party Managers that will, in turn, have day-to-day discretionary trading authority over the requisite client assets. DWM sponsors an investment management platform (the "Platform" or the "TAMP") that is available to the advisers in the Dynasty Network, such as the Firm. Through the Platform, DWM and Dynasty collectively provide certain technology, administrative, operations and advisory support services that allow FGWP to manage our client portfolios and access Independent Managers that provide discretionary services in the form of traditional managed accounts and investment models. FGWP can allocate all or a portion of client assets among the different Independent Managers via the Platform. FGWP can also use the model management feature of the TAMP by creating the Firm’s own asset allocation model and underlying investments that comprise the model. Through the model management feature, the Firm may be able to outsource the implementation of trade orders and periodic rebalancing of the model when needed. FGWP will maintain the direct contractual relationship with the client and obtain, through such agreements, the authority to engage Independent Managers, DWM and/or Dynasty, as applicable, for services rendered through the Platform in service to the Client. FGWP may delegate discretionary trading authority to DWM Page | 7 © MarketCounsel 2024 and/or Independent Managers to effect investment and reinvestment of client assets with the ability to buy, sell or otherwise effect investment transactions and allocate client assets. If the client participates in certain Investment Programs, DWM or the designated manager, as applicable, is also authorized without prior consultation with either the Firm or the client to buy, sell, trade or allocate client assets in accordance with the client’s designated portfolio and to deliver instructions to the designated broker-dealer and/or custodian of the client’s assets.