JPWM is principally owned by Mark Perlson and John F. Carey, and has been in business as an SEC registered investment adviser since June 2004. JPWM provides financial planning, consulting and investment management services. Prior to engaging JPWM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with JPWM setting forth the terms and conditions under which JPWM renders its services (collectively the “Agreement”). As of January 30, 2024, JPWM had $216,381,760 in assets under management, all of which was managed on a discretionary basis. This Disclosure Brochure describes the business of JPWM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of JPWM’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 JPWM’s behalf and is subject to JPWM’s supervision or control. Financial Planning and Consulting Services JPWM provides its clients with a broad range of comprehensive financial planning and consulting services. These services include, but are not limited to investments, retirement, education and cash flow needs of the client. In performing its services, JPWM 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. JPWM recommends the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if JPWM recommends its own services. The client is under no obligation to act upon any of the recommendations made by JPWM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including JPWM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of JPWM’s recommendations. Clients are advised that it remains their responsibility to promptly notify JPWM if there is ever any

change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising JPWM’s previous recommendations and/or services. Investment Management Services Clients can engage JPWM to manage all or a portion of their assets on a discretionary basis. JPWM primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities and/or options, as well as the securities components of variable annuities and variable life insurance contracts, in accordance with the investment objectives of Page 5 © MarketCounsel 2024 the client. JPWM may provide advice about any type of investment or legacy position otherwise held in clients' portfolios. JPWM also renders non-discretionary investment management services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans or other products that are not be held by the client’s primary custodian. In so doing, JPWM 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. JPWM tailors its advisory services to the individual needs of clients. JPWM 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. JPWM ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify JPWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon JPWM’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in JPWM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Page 6 © MarketCounsel 2024