QWP offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to QWP rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with QWP setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). QWP filed for registration as an investment adviser in June 2023. QWP is principally owned by Brandon Ross, Jonathan Blumenthal and Timothy Harder. The principals each own their membership interest through their individually owned corporations: Brandon Ross through SARHLR Inc.; Jonathan Blumenthal through MKBZEP Corp; and Timothy Harder through GOHGEH Inc. As of March 21, 2024, QWP had $3,116,745,366 in assets under management; $3,088,207,197 of which was managed on a discretionary basis and $28,438,169 of which was managed on a non-discretionary basis. While this brochure generally describes the business of QWP, 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 other persons who provide investment advice on QWP’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services QWP offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, QWP 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. QWP recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to Page | 5 © MarketCounsel 2024 implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage QWP or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by QWP under a financial planning or consulting engagement. 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 QWP’s recommendations and/or services. Investment and Wealth Management Services QWP provides clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. QWP primarily allocates client assets among various exchange-traded funds (“ETFs”), individual debt and equity securities, mutual funds, options, independent investment managers (“Independent Managers”), structured notice and other alternative investments in accordance with their stated investment objectives. 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. Clients can engage QWP to manage and/or 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, QWP directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. QWP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. QWP consults with clients on an initial and ongoing basis to assess their specific risk profile, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify QWP if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if QWP 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 Third-Party for Certain Assets Held Away QWP can leverage the Pontera Order Management System ("Pontera") to implement investment selection and rebalancing strategies on behalf of clients in held away accounts (i.e., accounts not directly held with Page | 6 © MarketCounsel 2024 the custodian(s) recommended by the Firm). These are primarily 401(k) accounts, HSAs, 403bs, 529 education savings plans, 457 plans, profit sharing plans, and other assets. QWP regularly reviews the available investment options in these accounts, monitors them, and rebalances and implements the Firm’s strategies in the same way as other accounts, though using different tools as necessary. Retirement Plan Consulting Services QWP provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by QWP as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance

with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of QWP’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Use of Independent Managers As mentioned above, QWP selects 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 with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. QWP evaluates a variety of information about Independent Managers, which includes 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. QWP also takes into consideration each Independent Page | 7 © MarketCounsel 2024 Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, and management turnover, among other factors. QWP 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. QWP seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. For more information about the Independent Managers, see the Dynasty TAMP disclosures, below. Use of Dynasty TAMP QWP has entered into a contractual relationship with Dynasty Financial Partners, LLC (“Dynasty”), which provides the Firm with operational and back-office support including access to a network of service providers. Through the Dynasty network of service providers, QWP may receive preferred pricing on trading technology, reporting, custody, brokerage, compliance and other related services. In addition, Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”), an SEC registered investment adviser, provides access to a range of investment services including: separately managed accounts (“SMA”), mutual fund and ETF asset allocation strategies, and unified managed accounts (“UMA” and together with the SMAs is the same as the Independent Managers) managed by external third party managers (collectively, the “Investment Programs”). QWP may separately engage the services of Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs, QWP will maintain the ability to select the specific, underlying Independent Managers that will, in turn, have day-to-day discretionary trading authority over the requisite client assets. Dynasty charges a “Platform Fee,” for which, unless otherwise disclosed, the client will be charged, separate from and in addition to such client’s annual investment management fee, as described in Item 5 below. This arrangement presents a conflict of interest because QWP is incentivized to allocate client investment assets to the Investment Programs in order to receive more advantageous pricing from Dynasty. The annual investment management fee charged to the client is not affected if Platform Fees are decreased. QWP seeks at all times to ensure that any conflicts are addressed on a fully-disclosed basis and investment decisions are handled in a manner that is aligned with the client’s best interests. The Firm does not receive any portion of the fees paid directly to Dynasty or the service providers made available through its platform. Dynasty and DWM offer an investment management platform (the “Platform” or the “TAMP") that is available to the advisers in the Dynasty Network, such as QWP. Through the Platform, DWM and Dynasty collectively provide certain technology, administrative, operations and advisory support services that allow advisers to manage their own portfolios and access Independent Managers. QWP can allocate all or a portion of client assets among the different Independent Managers via the Platform. QWP can also use the model and/or overlay management feature of the TAMP by creating its own asset allocation model and Page | 8 © MarketCounsel 2024 underlying investments that comprise the model. Through the model management feature, the Firm can outsource the implementation of trade orders and periodic rebalancing of the model when needed. QWP will maintain the direct contractual relationship with each client and obtain, through such agreements, the authority to engage the Independent Managers, DWM and/or Dynasty, as applicable, for services rendered through the Platform in service of such client. QWP may delegate discretionary trading authority to DWM and/or Independent Managers to affect investment and reinvestment of client assets with the ability to buy, sell or otherwise effect investment transactions and allocate client assets. If a client is participating in certain Investment Programs, DWM or the designated Independent Manager, as applicable, is also authorized without prior consultation of QWP or the client to buy, sell, trade or allocate such client’s assets in accordance with the client’s designated portfolio and to deliver instructions to the designated broker-dealer and/or custodian of such client’s assets. In providing investment advice and portfolio management services to clients, the Firm acts as an investment adviser and fiduciary to and on behalf of each client and not as an agent of Dynasty or DWM. Use of Dynasty Outsourced Chief Investment Officer (“OCIO”) Program Additionally, QWP can use DWM’s customized portfolio solutions, which are offered to investment advisers through its Outsourced Chief Investment Officer Program (the “OCIO Program”). Through the OCIO Program, DWM provides discretionary investment management services through its Investment Committee, in concert with research furnished by Envestnet PMC and iCapital Securities, LLC. OCIO strategies may entail active or passive management strategies with the goal of creating portfolios focused on asset protection and growth of capital. Passive portfolios typically employ inexpensive, passive ETFs, while active portfolios typically employ active third-party investment strategies, as appropriate. Portfolios are constructed, implemented and monitored through a due diligence program that functions at the sub- manager and product level.