Windward provides clients with a broad range of wealth management services. Prior to engaging Windward to provide any investment advisory services, clients are required to enter into one or more written agreements with Windward setting forth the terms and conditions under which Windward renders its services (collectively the “Agreement”). Windward has been in business and registered as an investment adviser since 1999. Windward’s principal owners are Andrew S. Osborne (who holds ownership through the Andrew Steven Osborne and Lindsey Deann Osborne Revocable Trust) and Emily Petty (who holds ownership through the Tyler S. Petty and Emily Tierney Petty Living Trust). As of January 31, 2024, Windward had $247,584,326 of assets under management, all of which were managed on a discretionary basis. This Disclosure Brochure describes the advisory business of Windward. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Windward’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 Windward’s behalf and is subject to Windward’s supervision or control. Wealth Management Services Clients can engage Windward for its wealth management services, which include a broad range of comprehensive financial planning services as well as discretionary management of investment portfolios. Windward’s financial planning services are tailored to the individual needs of the client, and include tax planning, budgeting and cash management, retirement planning, estate planning, debt management, charitable giving, and insurance planning. With respect to its discretionary investment management services, as further discussed in Item 8, Windward primarily invests clients’ assets in exchange-traded funds (“ETFs”) and mutual funds, but also invests such

assets in other securities where deemed appropriate for the client. Windward consults with clients initially and on an ongoing basis to develop a financial roadmap which determines risk tolerance, time horizon and other factors that impact the clients’ investment needs. Windward's investment approach is designed to address each client's investment needs, goals, objectives and risk tolerance. Windward chooses portfolios composed of specific investments that are designed to address each client's financial needs, objectives and Page | 5 © MarketCounsel 2024 circumstances. Windward will periodically review such portfolios and rebalance as market conditions or client circumstances warrant. Clients should promptly notify Windward if (1) there are changes in their financial situation or investment objectives or (2) if they wish to impose any reasonable restrictions upon Windward’s management services. The Firm allows clients to impose reasonable restrictions or mandates on the management of their accounts. However, if, in the Firm’s sole discretion, it believes that the restrictions or mandates imposed by the client will materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts, Windward may decline to accept those conditions. The client can then choose to proceed without the requested restrictions or seek a different investment adviser. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Windward for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Tax Preparation Services Windward provides tax preparation services to wealth management and non-advisory clients.