Since March 2000, SFWC has been in business as an independent registered investment adviser, dedicated to providing its clients with a wide range of investment related solutions necessary to assist them in their pursuit of financial success. SFWC’s expansive service offerings include comprehensive wealth management, financial planning, and portfolio management. The firm’s principal voting shareholder is Michael T. Dwyer, III. As of December 31, 2023, SFWC had $1,180,745,837in assets under management, of which $1,031,700,044 was managed on a discretionary basis and $149,045,793 was managed on a non-discretionary basis. Prior to engaging SFWC to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with SFWC setting forth the terms and conditions under which SFWC renders its services (collectively the “Agreement”). This Disclosure Brochure describes the business of SFWC. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of SFWC’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 SFWC’s behalf and is subject to SFWC’s supervision or control. Financial Planning Services SFWC’s financial planning services encompass a variety of functions addressing a multitude of investment and non-investment related matters. These services incorporate any or all of the following, without limitation:
• Preparation of statements of financial position
• Financial independence modeling
• Cash flow modeling
• Survivor income needs analyses
• Education planning analyses
• Estate planning strategies
• Asset protection strategies
• Risk management strategies
• Wealth transfer strategies
• Investor education services
• Preparation of investment policy statements
• Preparation of trust/retirement withdrawal strategies
• Bill paying services SFWC’s financial planning services are typically reserved for the firm’s investment management clients, as explained below. However, in certain circumstances, SFWC also provides these services to non- investment management clients on a standalone basis. Page 5 © MarketCounsel 2024 In performing its services, SFWC 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. SFWC recommends the services of itself, its Supervised Persons in their individual capacities as insurance producers/agents, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if SFWC recommends its own services. The client is under no obligation to act upon any of the recommendations made by SFWC under a financial planning or consulting engagement or to engage the services of any such recommended professional, including SFWC itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of SFWC’s recommendations. Clients are advised that it remains their responsibility to promptly notify SFWC if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising SFWC’s previous recommendations and/or services. Page 6 © MarketCounsel 2024 Investment Management and Wealth Management Services SFWC manages clients’ investment portfolios on a discretionary and/or non-discretionary basis. Typically portfolio management is rendered in conjunction with the firm’s financial planning services under a single, coordinated offering (collectively, SFWC’s “wealth management services”). SFWC primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”) and collective investment vehicles in accordance with the investment objectives of the client. The firm also provides advice with regard to legacy positions or investments otherwise held in its clients’ portfolios. Certain of the collective investment vehicles recommended by SFWC take the form of private placement securities. As such, SFWC limits such

recommendations to clients who are deemed to be “accredited investors,” as defined by Rule 501 under the Securities Act of 1933. SFWC also provides advice about any type of investment held in clients' portfolios. SFWC also render 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 may not be held by the client’s primary custodian. In so doing, SFWC 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. Where appropriate, the firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the firm unless specifically agreed upon. SFWC tailors its advisory services to the individual needs of clients. SFWC consults with clients initially and on an ongoing basis to develop an investment policy statement which determines risk tolerance, time horizon and other factors that may impact the clients’ investment needs. SFWC ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify SFWC if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon SFWC’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 SFWC’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Page 7 © MarketCounsel 2024 Use of Independent Managers As mentioned above, SFWC recommends that certain clients authorize the active discretionary 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 SFWC or the client and the designated Independent Managers. SFWC renders services to the client relative to the discretionary selection of Independent Managers. SFWC also monitors and reviews the account performance and the client’s investment objectives. SFWC 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 selecting an Independent Manager for a client, SFWC 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 SFWC 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, are exclusive of, and in addition to, SFWC’s investment advisory fee set forth above. As discussed above, the client incurs additional fees than those charged by SFWC, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to SFWC’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 SFWC. In such instances, SFWC may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers.