DFSC is an investment advisory firm that was established in 1981 to assist its clients with their financial planning, consulting, and investment management needs. Prior to the rendering of any of the foregoing advisory services, clients are required to enter into one or more written agreements with DFSC setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). DFSC is owned by David W. Demming and David W. Demming, Jr. As of June 30, 2023, DFSC had approximately $503,743,188 of assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of DFSC, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on DFSC’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services DFSC offers clients a range of financial planning and consulting services, which may include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Asset Allocation Analysis
• Retirement Planning
• Estate Planning
• Financial Reporting
• Elder Planning
• Executive Compensation
• Investment Consulting
• Insurance Needs Analysis
• Retirement Plan Analysis
• Charitable Giving
• Risk Management
• Distribution Planning While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management. In performing these services, DFSC is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. DFSC may recommend the services of itself or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage DFSC to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by DFSC under a financial planning or Page 5 © MarketCounsel 2023 consulting engagement or to engage the services of any such recommended professionals, including DFSC itself. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising DFSC’s previous recommendations and/or services. Investment Management Services DFSC manages client investment portfolios on a discretionary or non-discretionary basis. DFSC primarily allocates client assets among various independent investment managers (“Independent Managers”), mutual funds, exchange-traded funds (“ETFs”) and individual debt and equity securities. In addition, DFSC may also recommend that clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment

vehicles (e.g., hedge funds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may also engage DFSC to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, DFSC directs or recommends the allocation of client assets among the various investment options available with the product. These assets are maintained at the underwriting insurance company or the custodian designated by the product’s provider. DFSC tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. DFSC consults with clients on an initial and ongoing basis to develop an Investment Policy Statement (“IPS”), which will address their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify DFSC if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if DFSC determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, DFSC may select or recommend certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement between the designated Independent Manager and either DFSC or the client. In addition to this brochure, clients also receive the written disclosure documents of the designated Independent Managers engaged to manage their assets. Page 6 © MarketCounsel 2023 DFSC evaluates various information about the Independent Managers it chooses to manage client portfolios, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. DFSC also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. DFSC continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. DFSC seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.