MGWM is a SEC-registered investment adviser with its principal place of business located in Minnesota. MGWM has been in business since November 2008. Bennett E. Marks is the firm's principal shareholder (i.e., individuals and/or entities controlling 25% or more of MGWM). MGWM provides financial planning and investment management services primarily to high-net-worth families and individuals. We provide investment consulting services to private foundations, endowments, non-profit boards, and corporate retirement plans. (collectively, “clients” and each, a “client”) Reference to “client” or “clients” in this Disclosure Brochure are to one or more clients of MGWM and not clients of any other investment adviser. The focus of our investment management services are the six investment strategies which are described in Item 8. All strategies are actively managed and consist of securities with daily liquidity. Prior to engaging MGWM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with MGWM setting forth the terms and conditions under which MGWM renders its services (collectively, the “Agreement”). This Disclosure Brochure describes the business of MGWM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of MGWM’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 MGWM’s behalf and is subject to MGWM’s supervision or control. Financial Planning and Consulting Services MGWM offers its clients a broad range of comprehensive financial planning and consulting services, which include non-investment-related matters. These services include business planning, investments, insurance, retirement, education, estate planning, and tax and cash flow needs of the client. In addition, the firm also provides financial consulting services to private foundations regarding long-term strategic planning, the development of investment policy statements and providing consolidated performance reporting for institutional clients working with multiple custodians and managers. These services may be included as part of MGWM’s wealth management services, described below. In performing its services, MGWM 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. MGWM may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if MGWM recommends its own services. The client is under no obligation to act upon any of the recommendations made by MGWM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including MGWM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of MGWM’s recommendations. Clients are advised that it remains their responsibility to promptly notify MGWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising MGWM’s previous recommendations and/or services. Investment Management and Wealth Management Services Clients can engage MGWM to manage all or a portion of their assets on a discretionary or non- discretionary basis. When managing all or a portion of a client’s assets on a discretionary basis, MGWM will manage the assets directly or will engage the advisory services of a subadviser to manage all or a portion of a client’s assets. In addition, MGWM may provide clients with wealth management services which include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. MGWM primarily allocates clients’ investment management assets among open-end and closed-end mutual funds, ETFs, individual debt and equity securities and American Depository Receipts (“ADRs”), as well as publicly traded Real Estate Investment Trusts (“REITs”) and Master Limited Partnerships (“MLPs”), and, in limited cases, Independent Managers (as defined below). MGWM also provides advice about any type of investment held in clients' portfolios at the outset of establishing a relationship with the firm. MGWM tailors its advisory services to the individual needs of clients. MGWM consults with clients initially to develop an investment strategy based on the clients’ risk tolerance and other factors. On a case by case basis, as necessary, MGWM works with clients to develop an investment policy statement. MGWM ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. MGWM also may 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 are not held by the client’s primary custodian. In so doing, MGWM 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. Clients are advised to promptly notify MGWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon MGWM’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 MGWM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Use of Independent Managers As mentioned above, MGWM 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 MGWM or the client and the designated Independent Managers. MGWM renders services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers. MGWM also monitors and reviews the account performance and the client’s investment objectives. MGWM 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 recommending or selecting an Independent Manager for a client, MGWM 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 MGWM 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, may be exclusive of, and in addition to, MGWM’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by MGWM, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to MGWM’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 MGWM. In such instances, MGWM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Subadvisory Relationship On March 24, 2017, MGWM entered into a Subadvisory Agreement with Running Oak Capital LLC (“ROCL”) an investment adviser registered with the Securities and Exchange Commission, independent of MGWM. Through this contractual relationship, ROCL provides investment subadvisory services for the Marks Group Core Equity Portfolio strategy (“MGCEP”). The MGCEP will be managed in the same manner as ROCL’s Efficient Growth Equity Strategy (“REGS”). ROCL will continue to provide advisory services to its existing clients as well as procure new clients. MGWM will provide its clients whose assets are advised according to its MGCEP with a copy of ROCL’s disclosure brochure (i.e., Form ADV Parts 2A and 2B) and Privacy Notice at least 48 hours prior to ROCL managing such account. Annually, MGWM will provide a copy of ROCL’s Privacy Notice and will offer or provide a copy of material updates to ROCL’s disclosure brochure to clients whose investment portfolios are managed pursuant to MGCEP. MGWM is responsible for oversight of ROCL’s advisory activities conducted on behalf of MGWM’s clients pursuant to the Subadvisory Agreement. MGWM will be available to answer questions clients may have regarding any portion of their accounts managed by ROCL and will generally act as the communication conduit between clients and ROCL. Though the terms of the Subadvisory Agreement set forth specific details regarding the engagement and termination of ROCL as a sub-adviser, MGWM has ultimate authority to hire and fire ROCL. Sponsor of Wrap Program MGWM is the sponsor of the Marks Group Wealth Management Wrap Program (the “Program”), a wrap fee program. For clients who participate in the Program, MGWM provides its investment management services and arranges for brokerage transactions under a single annualized fee. Participants in the Program may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. A complete description of the Program’s terms and conditions (including fees) are contained in the Program’s wrap fee brochure. Amount of Managed Assets As of February 8, 2024, MGWM managed $1,480,177,123 of clients' assets on a discretionary basis plus $208,816,402 of clients' assets on a non-discretionary basis.