Founded in June 2001 by principal John R. Sanderson (and providing advisory services since July 2001), Sanderson offers financial planning, investment consulting, and investment management services, focusing on developing asset allocations, performing due diligence, selecting managers, monitoring those managers, reviewing overall performance and performing periodic rebalancing. As of December 31, 2023, Sanderson had $1,116,320,692 in assets under management, of which $183,283,244 was managed on a discretionary basis and $933,037,448 was managed on a non- discretionary basis. Prior to engaging Sanderson to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Sanderson setting forth the terms and conditions under which Sanderson renders its services (collectively the “Agreement”). This Disclosure Brochure describes the business of Sanderson. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Sanderson’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on Sanderson’s behalf and is subject to Sanderson’s supervision or control. Financial Planning Services Sanderson provides clients with a broad range of comprehensive financial planning and consulting services. These services generally include retirement planning, education planning, and goal planning, as well as other areas requested by the client. Sanderson’s financial planning services are generally offered as part of its overall wealth management services. In performing its services, Sanderson is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Sanderson recommends the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Sanderson recommends its own services. The client is under no obligation to act upon any of the recommendations made by Sanderson under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Sanderson itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Sanderson’s recommendations. Clients are advised that it remains their responsibility to promptly notify Sanderson if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Sanderson’s previous recommendations and/or services. Page 5 © MarketCounsel 2024 Investment Management Services Sanderson provides clients with wealth management services which generally include a broad range of comprehensive financial planning services as well as discretionary and/or non-discretionary management of investment portfolios. Sanderson primarily allocates clients’ investment management assets among mutual funds, but may also utilize exchange-traded funds (“ETFs”) and/or Independent Managers (as defined below). In addition, Sanderson also recommends that certain eligible clients invest in alternative investments such as individual and pooled privately placed securities (i.e. hedge funds, private equity funds, and venture capital funds) and other private placements (i.e. equity, credit or real estate investments) (together referred to as “Alternative Investments”). Sanderson may also provide advice about any type of investment held in clients' portfolios as necessary, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Sanderson also renders non-discretionary investment management services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not be held by the client’s primary custodian. In so doing, Sanderson either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets

are maintained at the specific insurance company or custodian designated by the product. Sanderson tailors its advisory services to the individual needs of clients. Sanderson consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Sanderson ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Sanderson if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Sanderson’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in Sanderson’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Use of Independent Managers As mentioned above, Sanderson recommends that certain clients authorize the active management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between Sanderson or the client and the designated Independent Managers. Sanderson renders services to the client relative to the non-discretionary recommendation of Independent Managers. Sanderson also monitors and reviews the account performance and the client’s investment objectives. Page 6 © MarketCounsel 2024 Sanderson receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending an Independent Manager for a client, Sanderson reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that Sanderson considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, Sanderson’s investment advisory fee. As discussed above, the client will incur additional fees than those charged by Sanderson, the designated Independent Managers, and corresponding broker- dealer and custodian. In addition to Sanderson’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than Sanderson. In such instances, Sanderson may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Retirement Plan Consulting Services Sanderson 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 and benefits, investment selection, plan fee and cost analysis, plan committee consultation, fiduciary and compliance, and participant education. As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Sanderson 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 Sanderson’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement.