Corporate Structure Whitegate Investment Counselors, Inc. (“WICI”) is a SEC-registered investment adviser with its principal place of business located in New Hampshire. The firm began conducting business in 1992 under the name of Whitegate Investment Counselors, Inc.(“Whitegate”). On 12/31/2015, Taylor, Cottrill LLC (another New Hampshire firm) merged with Whitegate and the combined entity was renamed Taylor, Cottrill, Erickson and Associates, Inc. On 12/28/2021, Taylor, Cottrill, Erickson & Associates, Inc. changed its name back to Whitegate Investment Counselors, Inc. and sold the assets and business unit associated with its branch office in New London, New Hampshire. Listed below are the firm's shareholders as of 12/31/2022 (i.e., these individuals and/or entities control 25% or more of this company):
• Carl George Erickson: Majority Shareholder, Principal, Director, as Trustee of the Carl G. Erickson Revocable Trust dtd 6/09/1998
• Paulette Wheeler Wolfe: Chief Operating Officer (“COO”), Chief Compliance Officer (“CCO”), and Shareholder Education and Background of Officers and Shareholders is listed in WICI’s ADV Part 2B (attached to our ADV Part 2A). Investment Services WICI provides advice to clients regarding the investment of client funds based on the individual needs of the client. Through personal discussions (including, but not limited to, one or more of the following communication methods: letters, e-mails, telephone conferences, in-person meetings and forms that we request clients to complete to help us gather data about their family and financial situations) in which goals and objectives based on a client's particular circumstances are established, we develop an asset allocation and investment recommendations for each client. We then create and manage a portfolio based on that asset allocation. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, return expectations, expected deposit/withdrawal patterns and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. Account supervision is guided by the client's stated risk tolerance, return expectations, expected deposit and withdrawal patterns and tax considerations. WICI manages advisory accounts on a discretionary or non-discretionary basis although most accounts are managed on a discretionary basis. We will consider accepting any restrictions on investment in certain securities, or types of securities or industry sectors on a best-efforts basis for a client if we feel the restrictions are reasonable and can be executed without compromising our ability to meet the client’s investment objectives. These restrictions can be discussed with portfolio managers at any time. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• American Depositary Receipts of foreign issuers
• Warrants
• Commercial Paper
• Corporate debt securities
• Certificates of deposit
• Municipal Bonds
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in real estate Depending on market conditions, holding periods may vary considerably. After-tax returns are taken into consideration for taxable accounts. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended

when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Participant Directed 401(k) Profit-Sharing Plan Services Although WICI does not currently provide this service for any Participant Directed 401(k) Plan clients at this time, WICI has in the past and may in the future perform certain investment advisory and reporting services for participant directed 401(k) profit-sharing plans on a non-discretionary basis. Such services include selection of mutual funds to be offered to participants, information regarding the benefits of participation in the plan, historical information on returns of various asset classes, asset allocation information, generic information on different types of mutual funds and specific information on risk levels, track records and management of the mutual funds selected for the plan. WICI does not generally place trades (as most plans are self-directed) or provide record keeping and administrative services but does provide quarterly or semi-annual performance reports and periodic updates of the information described previously. Selection of Other Advisors Although WICI does not currently provide this service for any of its clients at this time, WICI has in the past and may in the future perform certain investment advisory and reporting services to advise certain clients in the selection of other advisors, including Third Party Money Managers and/or Hedge Funds. Based on the client's individual circumstances and needs we then perform management searches of various unaffiliated registered investment advisers to identify which registered investment adviser's portfolio management style may be appropriate for that client. Factors considered in making this determination include account size, risk tolerance, and the investment philosophy of the selected registered investment adviser. Clients should refer to the selected registered investment adviser's Firm Brochure or other disclosure document for a full description of the services offered. We will monitor the performance of the selected registered investment adviser(s). If we determine that a particular selected registered investment adviser(s) is not providing sufficient management services to the client or is not managing the client's portfolio in a manner consistent with the client’s individual objectives, time horizons, risk tolerance, return expectations, expected deposit/withdrawal patterns and liquidity needs, we may suggest that the client contract with a different registered investment adviser and/or program sponsor. Under this scenario, our firm may assist the client in selecting a new registered investment adviser and/or program. However, any move to a new registered investment adviser and/or program is solely at the discretion of the client. Consulting Services Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Wrap Fee Programs We do not participate in any wrap fee programs. Assets Under Management Based on 12/31/2022 values, Whitegate Investment Counselors, Inc. actively manages or advises on a total of $618,358,119 million of clients’ assets: $608,357,028 million on a discretionary basis and $10,001,091 million on a non-discretionary basis.