Description of Services and Fees Estate Counselors, LLC d/b/a The Milwaukee Company is a registered investment advisor based in Thiensville, Wisconsin. We are organized as a limited liability company under the laws of the State of Wisconsin. We have been providing investment advisory services since 2004, formerly under the name of Willms, S.C. and since January 20, 2010 as Estate Counselors, LLC. In August 2018, we began doing business as The Milwaukee Company. The Milwaukee Company is owned by the Emily M. Willms Family Trust, the Jacob A. Willms Family Trust, the Michael R. Willms Family Trust, and the Andrew J. and Linda S. Willms Trust. Jacob A. Willms is the trustee to the Emily M. Willms Family Trust, the Jacob A. Willms Family Trust, and the Michael R. Willms Family Trust. Andrew J. Willms and Linda S. Willms are trustees to the Andrew J. and Linda S. Willms Trust.
A description of our services and fees follows. As used in this Brochure, the words "we", "our", and "us" refer to The Milwaukee Company and the words "you", "your", and "client" refer to clients and prospective clients of our Firm. "Associated Persons" refers to our Firm's officers, employees, and all individuals providing investment advice on behalf of our Firm.
The Milwaukee Company is committed to always placing our client's interests first, to giving advice that is not based on our opinions but rather on peer-reviewed academic research, and to providing a high level of personalized client service.
Investment Approach The Milwaukee Company is an independent financial advisory firm that offers portfolio management services to individuals, trusts, investment entities, and charitable organizations.
The Milwaukee Company utilizes proprietary, rules-based investment strategies based on extensive academic research and theory that tactically adapt client portfolios to reflect changes in economic and market conditions in an effort to enhance risk-adjusted rates of return and reduce portfolio volatility. We believe that over the long-term, investment results are optimized by developing strategically diversified portfolios consisting of low-cost index-based exchange-traded funds ("ETFs") that are monitored over time, periodically rebalanced, and adjusted using proprietary quantitative models that adapt client portfolios to reflect changes in the securities markets and the economy. A description of each of our investment strategies is available upon request, or can be found at our website: www.themilwaukeecompany.com. The Milwaukee Company also monitors a wide array of well-accepted capital market risk signals and economic indicators for signs of exceptional conditions. In that event we may make discretionary adjustments to our clients' portfolios in addition to those directed by our rules-based strategies.
As part of our portfolio management services, we may use one or more sub-advisors to manage a portion of your account on a discretionary basis. Through the advisory agreement you sign with us, we are authorized to delegate some or all of our investment-related rights, powers and duties to sub- advisors. We will only engage a sub-advisor if (i) we believe that the sub-advisor and the investment strategies to be utilized thereby is in your best interests and are consistent with your Investment Policy Statement; and (ii) the sub-advisor is a registered investment advisor under the Investment Advisor's Act of 1940. We will provide you with a copy of the sub-advisor's then-current Form ADV, Part 2B prior to submitting your account to the sub-advisor for management. The sub-advisor(s) may use one or more of their model portfolios to manage your account. We will regularly monitor the performance of your accounts managed by the sub-advisor(s) and, may hire and terminate any sub-advisor without your prior approval. We may pay a portion of our advisory fee to the sub-adviser(s) we use; however, you will not pay our firm a higher advisory fee as a result of any sub-advisory relationships.
5 While our investment approach is intended to tailor our client's portfolios to their personal risk tolerance, there is no guarantee that the investments we recommend, or the stock

market generally, will perform in the future as they have in the past. As a result, even though a portfolio is intended to result in a certain level of risk, the actual volatility experienced in the account's value may be greater or less than anticipated.
Exchange Traded Fund Adviser Services We serve as the Adviser to ETF SERIES SOLUTIONS (the "Trust") on behalf of the series The Brinsmere Fund – Growth ETF ("Fund") and The Brinsmere Fund – Conservative ETF ("Fund"). For more information, including investment objectives, risks, charges, and expenses, please read the Funds' prospectus and summary prospectuses (collectively, "prospectuses"), statement of additional information, and other reports to shareholders for complete disclosures relating to the Funds before investing. Refer to the Investment Discretion section below for additional disclosures on our discretionary authority. Securities held in separate accounts may also be the same securities as those purchased by the Fund.
Financial Planning and Consulting Services We offer financial planning and consulting services to help our clients determine and achieve their long-term financial goals. These services include (but are not limited to):
•Review of client's assets and liabilities.
•Assessment of client's risk tolerance and investment objectives.
•Consideration of client's investments and asset allocation.
•Risk management and insurance planning.
•Income tax, retirement, and estate planning.
•Plan implementation. We then provide an executive summary, highlighting the plan of action we recommend, which clients may implement or reject as they deem appropriate in their discretion.
Financial planning recommendations are based on information provided to us regarding a client's current financial situation. Therefore, clients are strongly encouraged to notify us if his/her financial situation, goals, objectives or needs change.
Assumptions may be made with respect to interest rates, inflation rates, and more when formulating our recommendations. In addition, we may make use of historical data pertaining to past trends and performance of the market and economy and the like. It is important to recognize that past performance may not be indicative of future performance, and that we cannot guarantee or promise that a client's objectives and goals will be met.
As part of our financial planning services, we may suggest clients retain third-party service providers such as an attorney, accountant, bookkeeper or insurance agent. We are not compensated in any way for third-party referrals, and all such suggestions are subject to the client's approval and consent. Clients are under no obligation to use any service provider recommended by us.
The Milwaukee Company can provide strategic and tactical advisory consulting and concierge services to our high-net-worth clients. We may also refer attorneys, accountants, bookkeepers, insurance agents and other third-party service providers to our clients. We are not compensated in any way for third-party referrals, and all such suggestions are subject to the client's approval and consent. Clients are under no obligation to use any service provider recommended by us.
6 Types of Investments As mentioned above, we primarily recommend index tracking exchange traded funds to implement our investment recommendations. However, we are not limited to any single type of security. We may give advice on a variety of investments including (but not limited to) mutual funds, equity securities, corporate, municipal, and government bonds, certificates of deposit, investment company securities, U.S. government securities, and option contracts on securities.
Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular Securities. These restrictions must be provided in advance by you to our Firm in writing.
Assets Under Management As of 3/31/2024, we manage $1,081,811,573 in client assets on a discretionary basis.