TFS was founded July 2000 and has been in business as an SEC registered investment adviser since December 2003. Alan Rubin and James Payne are the principal owners of TFS. From the firm’s inception, it has been TFS’s mission to identify its clients’ financial and estate goals, formulate a comprehensive strategy, and provide them with the appropriate investment and insurance vehicles to fulfill those needs. TFS provides financial planning, consulting, and investment management services. Prior to engaging TFS to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with TFS setting forth the terms and conditions under which TFS renders its services (collectively the “Agreement”). As of December 31, 2022, TFS had approximately $254,922,234 in assets under management, all of which was managed on a discretionary basis. This disclosure brochure describes the business of TFS. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of TFS’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 TFS’s behalf and is subject to TFS’s supervision or control. Financial Planning and Consulting Services TFS provides its clients with a broad range of comprehensive financial planning and consulting services (which include tax-related and other non-investment related matters). These services include education planning, retirement planning, cash flow projections, and estate planning in conjunction with client’s legal counsel. In performing its services, TFS 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. TFS recommends the services of itself, its Supervised Persons in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if TFS recommends its own services. The client is under no obligation to act upon any of the recommendations made by TFS under a financial planning or consulting engagement or to engage the services of any such recommended professional, including TFS itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of TFS’s recommendations. Clients are advised that it remains their responsibility to promptly notify TFS if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising TFS’s previous recommendations and/or services. Page

5 © MarketCounsel 2023 Investment Management Services Clients can engage TFS to manage all or a portion of their assets on a discretionary or non-discretionary basis. TFS primarily allocates clients’ investment management assets among mutual funds, exchange traded funds (“ETFs”), individual debt and equity securities, certificates of deposit, and/or options as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. In addition, where appropriate, TFS recommends that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which include debt, equity, and/or pooled investment vehicles when consistent with the clients’ investment objectives. TFS also provides advice about any type of investment otherwise held in its clients' portfolios, but clients should not assume that these assets are being continually monitored or otherwise advised on by the Firm unless specifically agreed upon. TFS also renders non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or other products that may not be held by the client’s primary custodian. In so doing, TFS 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. TFS tailors its advisory services to the individual needs of clients. TFS ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify TFS if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon TFS’s management services. Additions and Withdrawals to Accounts Clients may make additions to and withdrawals from their account at any time, subject to TFS’s right to terminate an account. Clients may withdraw account assets on notice to TFS, subject to the usual and customary securities settlement procedures. However, TFS designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Where appropriate, TFS consults with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Page 6 © MarketCounsel 2023