CTS FINANCIAL PLANNING, INC.

CTS Financial Planning, Inc. Disclosure Brochure Disclosure Brochure December 23, 2025 CTS Financial Planning, Inc. a Registered Investment Adviser 737 North Michigan Ave., Suite 2120 Chicago, Illinois 60611 (312) 337-1040 www.ctsfinancialgroup.com This brochure provides information about the qualifications and business practices of CTS Financial Planning, Inc. (hereinafter “CTS”). If you have any questions about the contents of this brochure, please contact Charles Marien at (312) 337-1040. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about CTS Financial Planning, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. CTS Financial Planning, Inc. is an SEC registered investment adviser. Registration does not imply any level of skill or training. © MarketCounsel 2025  CTS Financial Planning, Inc. Disclosure Brochure Item 2. Material Changes This Item discusses only the material changes that have occurred to CTS’ Disclosure Brochure since its last annual update dated December 20, 2024. The Firm has no material changes to disclose. . © MarketCounsel 2025 Page ii  CTS Financial Planning, Inc. Disclosure Brochure Item 3. Table of Contents Item 1. Cover Page ....................................................................................................................................... i Item 2. Material Changes ............................................................................................................................. ii Item 3. Table of Contents ............................................................................................................................. iii Item 4. Advisory Business ............................................................................................................................ 4 Item 5. Fees and Compensation .................................................................................................................. 7 Item 6. Performance-Based Fees and Side-by-Side Management ............................................................. 9 Item 7. Types of Clients ............................................................................................................................... 9 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 10 Item 9. Disciplinary Information .................................................................................................................. 14 Item 10. Other Financial Industry Activities and Affiliations ....................................................................... 14 Item 11. Code of Ethics .............................................................................................................................. 14 Item 12. Brokerage Practices ..................................................................................................................... 15 Item 13. Review of Accounts...................................................................................................................... 18 Item 14. Client Referrals and Other Compensation ................................................................................... 19 Item 15. Custody ........................................................................................................................................ 19 Item 16. Investment Discretion................................................................................................................... 20 Item 17. Voting Client Securities ................................................................................................................ 20 Item 18. Financial Information .................................................................................................................... 21 © MarketCounsel 2025 Page iii  CTS Financial Planning, Inc. Disclosure Brochure Item 4. Advisory Business CTS was founded in 1972 and initially specialized in individual tax preparation for executives and professionals, primarily in the advertising and marketing industries. Over time, services for individuals were expanded, and now include personal financial planning, retirement planning, investment planning, insurance planning and asset management. In November 1985, CTS registered with the SEC as a registered investment adviser. CTS is owned by Todd W. Much, Charles A. Marien, Jonathon C. Much, and Christopher T. Much. Prior to engaging CTS to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with CTS setting forth the terms and conditions under which CTS renders its services (collectively the “Agreement”). CTS has $313,859,000 of assets under management as of September 30, 2025, all of which are managed on a discretionary basis. This Disclosure Brochure describes the business of CTS. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of CTS’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 CTS’s behalf and is subject to CTS’s supervision or control. Financial Planning and Consulting Services CTS provides comprehensive financial planning, focused retirement planning, as well as tax planning and preparation. A CTS comprehensive financial plan analyzes a client’s financial life, followed by a situation analysis and a recommendation of strategies that can help clients develop a plan towards achieving their goals. CTS’s comprehensive financial plan begins with a detailed review of a client’s net worth and asset diversification. CTS examines the client’s current “financial situation” which help determine the current status in various areas, such as savings and educational funding. CTS may provide an estimate for current and future years’ income taxes. If applicable, CTS will also conduct a detailed cash flow analysis to determine how clients are spending their money and review their mortgage. If applicable, CTS will devise a strategically sound plan for funding college education. CTS spends considerable time developing a retirement plan using multiple “what-if” scenarios. CTS may review clients’ estate plans as well as their insurance needs, including life, disability, health, auto, homeowner’s, and long-term care insurance. For some clients, CTS will provide a focused retirement plan that concentrates on achieving the client’s retirement goals. A CTS focused retirement plan targets a specific age for clients to comfortably retire from their career. This includes a review of the client’s net worth and asset diversification. If applicable, planning for college education will also be considered. This plan develops multiple “what-if” scenarios for © MarketCounsel 2025 Page 4  CTS Financial Planning, Inc. Disclosure Brochure achieving retirement using alternative spending and savings goals in conjunction with varying retirement age, rate of return, and inflation rate assumptions. Unlike many investment advisers and financial planners, CTS also provides accounting services and income tax preparation and planning. Tax returns are prepared and/or supervised by an Enrolled Agent who has earned the privilege of practicing and representing taxpayers before the Internal Revenue Service. Some of the tax and accounting services provided by CTS include personal and federal state income tax preparation, tax planning and projections for current and future years, business income tax preparation for Partnerships, Trusts, LLC’s, and corporations, and representation for tax audits and resolution of IRS tax notices, and bookkeeping services for small businesses. Investment Management Services Clients can engage CTS to manage all or a portion of their assets on a discretionary basis. CTS primarily allocates clients’ investment management assets among mutual funds, exchange traded funds (“ETFs”), individual debt and equity securities, Independent Managers (as defined below), as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. CTS also provides advice about any type of investment held in clients' portfolios. CTS also may render investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, or other products that may not be held by the client’s primary custodian. In so doing, CTS directs 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. CTS tailors its advisory services to the individual needs of clients. CTS consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. CTS ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify CTS if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon CTS’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in CTS’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. In performing its services, CTS 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. CTS may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if CTS recommends its own © MarketCounsel 2025 Page 5  CTS Financial Planning, Inc. Disclosure Brochure services. The client is under no obligation to act upon any of the recommendations made by CTS under a financial planning or consulting engagement or to engage the services of any such recommended professional, including CTS itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of CTS’s recommendations. Clients are advised that it remains their responsibility to promptly notify CTS if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising CTS’s previous recommendations and/or services. Use of Independent Managers As mentioned on the previous page, CTS may recommend 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 CTS or the client and the designated Independent Managers. CTS renders services to the client relative to the discretionary selection or recommendation of Independent Managers. CTS also monitors and reviews the account performance and the client’s investment objectives. CTS 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, CTS 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 CTS 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, CTS’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by CTS, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to CTS’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 CTS. In such instances, CTS may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. If CTS refers a client to an Independent Manager where CTS’s compensation is included in the advisory fee charged by such Independent Manager and the client engages the Independent Manager, CTS is compensated for its services by receipt of a fee to be paid directly by the Independent Manager to CTS in © MarketCounsel 2025 Page 6  CTS Financial Planning, Inc. Disclosure Brochure accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, as amended, and any corresponding state securities laws, rules, regulations, or requirements. Any such fee is paid solely from the Independent Manager’s investment management fee, and does not result in any additional charge to the client. Item 5. Fees and Compensation CTS offers its services on a fee basis, which may include hourly and/or fixed fees, as well as fees based upon assets under management. Financial Planning and Consulting Fees CTS may charge a fixed fee and/or hourly fee for financial planning and consulting services. These fees are negotiable, but generally range from $500 to $7,500 on a fixed fee basis and/or from $125 to $500 on an hourly rate basis, depending upon the level and scope of the services and the professional rendering the financial planning and/or the consulting services. Prior to engaging CTS to provide financial planning and/or consulting services, the client is required to enter into a written agreement with CTS setting forth the terms and conditions of the engagement. Generally, CTS requires one-half of the financial planning and/or consulting fee (estimated hourly or fixed) payable upon entering the written agreement. The balance is generally due upon delivery of the financial plan or completion of the agreed upon services. Investment Management Fee CTS provides investment management services for an annual fee based upon a percentage of the market value of the assets being managed by CTS. CTS’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client. CTS does not, however, receive any portion of these commissions, fees, and costs. CTS’s annual fee is prorated and charged quarterly, in arrears. The valuation is typically based on the average market value of the assets. The valuation frequency used and process for billing purposes depends on where the assets are custodied. The assets held at the Firm’s primary Financial Institution are typically valued on an average daily basis. The valuation of assets held away from the primary Financial Institution will depend on the valuations provided by that other Financial Institution that has custody of the assets. This can result in the assets being valued in a number of different ways including the average daily balance, the average of the month end during the quarter, the last day of the period and/or other methods. CTS will only use a valuation method that it believes is in the client’s best interest. The Firm will use the valuations provided by the Financial Institutions of the assets (or in the event such valuation is not available, a third-party service provider). © MarketCounsel 2025 Page 7  CTS Financial Planning, Inc. Disclosure Brochure The annual fee varies depending upon the market value of the assets under management and the type of investment management services to be rendered, as follows: PORTFOLIO VALUE BASE FEE Up to $250,000 2.00% $250,001 - $500,000 1.75% $500,001 - $750,000 1.50% $750,001 - $1,000,000 1.25% Above $1,000,000 1.00% CTS, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). Fees Charged by Financial Institutions As further discussed in response to Item 12 (below), CTS generally recommends that clients utilize the brokerage and clearing services of Charles Schwab & Co, Inc. (“Schwab”) for investment management accounts. CTS participates in the institutional customer program offered by Schwab. Schwab offers to independent investment advisors services which include custody of securities, trade execution, clearance and settlement of transactions. CTS receives some benefits from Schwab through its participation in the program. CTS also recommends that clients utilize Nationwide Securities, LLC (“Nationwide Securities”) as custodian for certain retirement accounts and variable annuity accounts. CTS may only implement its investment management recommendations after the client has arranged for and furnished CTS with all information and authorization regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, Schwab, Nationwide Securities, any other broker-dealer recommended by CTS, broker-dealer directed by the client, trust companies, banks etc. (collectively referred to herein as the “Financial Institutions”). Clients may incur certain charges imposed by the Financial Institutions and other third parties such as fees charged by Independent Managers (as defined below), custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients may incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to CTS’s fee. © MarketCounsel 2025 Page 8  CTS Financial Planning, Inc. Disclosure Brochure CTS’s Agreement and the separate agreement with any Financial Institutions may authorize CTS or Independent Managers to debit the client’s account for the amount of CTS’s fee and to directly remit that management fee to CTS or the Independent Managers. Any Financial Institutions recommended by CTS have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to CTS. Fees for Management During Partial Quarters of Service For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement between CTS and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. CTS’s fees are charged through the date of termination and any remaining balance is charged to the client, as appropriate. Clients may make additions to and withdrawals from their account at any time, subject to CTS’s right to terminate an account. Additions may be in cash or securities provided that CTS reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to CTS, subject to the usual and customary securities settlement procedures. However, CTS designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. CTS may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Item 6. Performance-Based Fees and Side-by-Side Management CTS does not provide any services for performance-based fees. Performance-based fees are those based on a share of capital gains on or capital appreciation of the assets of a client. Item 7. Types of Clients CTS primarily provides its services to individuals; however, CTS may also provide its services to pension and profit sharing plans, trusts, estates, corporations and business entities. Minimum Account Size As a condition for starting and maintaining a relationship, CTS generally imposes a minimum portfolio size of $50,000 for mutual fund portfolios and $150,000 for individual equity portfolios. CTS, in its sole discretion, may accept clients with smaller portfolios based upon certain criteria including anticipated © MarketCounsel 2025 Page 9  CTS Financial Planning, Inc. Disclosure Brochure future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, and pro bono activities. CTS only accepts clients with less than the minimum portfolio size if, in the sole opinion of CTS, the smaller portfolio size will not cause a substantial increase of investment risk beyond the client’s identified risk tolerance. CTS may aggregate the portfolios of family members to meet the minimum portfolio size. Additionally, certain Independent Managers may impose more restrictive account requirements and varying billing practices than CTS. In such instances, CTS may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis CTS’s primary method of analysis is technical and its secondary method is cyclical analysis. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that CTS will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that CTS is recommending. The risks with cyclical analysis are similar to those of technical analysis. Investment Strategies CTS does not utilize a passive buy-and-hold strategy for its clients’ investments. Rather, CTS proactively manages investments daily with the goal of limiting its clients’ losses when stock and bond markets decline. Because of this, CTS believes its strategy is especially suitable for conservative investors and “baby boomers” nearing retirement who are seeking strategies that are lower in risk and volatility. CTS’s key principals invest their money in the same programs offered to its clients. The primary investment program offered by CTS is the CTS Consolidated Asset Management Program (“CTS CAMP”). The objectives of CTS CAMP are twofold: • To generate reasonable returns in a manner consistent with its clients’ targeted asset allocation strategy; and • To manage downside risks. © MarketCounsel 2025 Page 10  CTS Financial Planning, Inc. Disclosure Brochure CTS’s strategies emphasize risk reduction, and CTS invests conservatively or defensively when confronted with uncertainty and volatility in the stock and bond markets. CTS’s investment strategies combine the benefits of “asset allocation” with its proprietary proactive selection system for both stocks and bonds. Specifically, CTS determines which CTS CAMP asset allocation model is most suitable for a client based on the client’s investment objectives, time horizon, and risk tolerance. CTS also offers the CTS Retirement Asset Management Program (“CTS RAMP”), which helps clients to actively manage their retirement plans such as a 401(k) or 403(b) plan. In this case, clients’ assets are maintained at the custodian for the employer’s plan, and CTS helps the client choose among the funds offered by the employer’s plan. CTS strives to ensure its clients are invested in programs consistent with their risk tolerance level. Clients may be asked to complete an Investor Profile Analysis, which will help CTS determine what a client’s maximum exposure to the stock and bond markets should be. For instance, clients invested in the Balanced Growth Strategy would have a maximum stock exposure of 70%, but if conditions in the stock market were unfavorable, this exposure would decrease. Within each asset allocation model, the maximum exposure to stocks and bonds is based on CTS’s proactive selection system. This system utilizes sophisticated, technical indicators and rotation systems to determine if a client should be fully invested in stocks and/or bonds, or moved partially or fully into a stable money market account. The rotation systems help determine in which sectors or segments of the stock and bond markets to be invested. For instance, in the case of bonds, the systems may rotate between U.S. investment grade, high yield and global/foreign bonds. In the case of stocks, the systems may rotate between U.S. large cap, U.S. small cap and foreign stocks. CTS’s more aggressive stock models may rotate partially into industry-specific stock sectors such as energy, technology, real estate, and precious metals. As previously indicated, if market conditions are unfavorable, CTS’s stock and bond rotation systems can move partially or fully into the safety of a money market account. The goal of CTS’s strategies is to try to limit losses. Asset Allocation Models CTS CAMP has a wide range of asset allocation models that have different objectives and risk tolerance levels. For lower risk investors, there are bond-only models that emphasize primarily income and in some cases, growth of capital. The models differ based on the types of bonds utilized. CTS has a diversified bond model that can invest in short and intermediate investment grade bonds, as well as high-yield and global foreign bonds. CTS also has a model that invests only in tax-free municipal bonds. For higher-risk investors, CTS CAMP has several stock oriented allocation models that focus on growth and income, or aggressive growth for more risky models. The models differ based on the maximum exposure allowed to stocks (between 50% and 100%). Some of CTS’s stock models can utilize industry specific stock sectors such as health, energy, technology, real estate, and precious metals, etc. Some of © MarketCounsel 2025 Page 11  CTS Financial Planning, Inc. Disclosure Brochure CTS’s stock models can utilize strategies that go short on various indexes and sectors of the stock market. Investment Vehicles CTS CAMP utilizes primarily no-load mutual funds and Exchange Traded Funds (“ETFs”) to execute most of its stock and bond positions. Some mutual funds are chosen based on their Morningstar ratings, their long-term track record, portfolio composition, the fund size, and the tenure of their manager. Where possible, CTS emphasizes the institutional class of funds where the fees are the lowest, and tries to avoid funds with redemption fees to assure clients’ funds are easily accessible. Some mutual funds and ETFs are also chosen because they represent specific style or index sectors like large-cap growth, mid-cap value, NASDAQ 100, S&P 500, etc. and allow for more frequent trading. CTS CAMP also recommends no-load variable annuities for some clients, when appropriate. These no-load variable annuities have no up-front fees, no redemption fees, and a very low flat insurance fee. CTS also utilizes variable annuities when a new client comes to CTS and has a prior position in a non-qualified variable annuity that needs to be maintained for tax purposes. Risks of Loss General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. Market Risks The profitability of a significant portion of CTS’s recommendations may depend to a great extent upon correctly assessing the future course of price movements of stocks and bonds. There can be no assurance that CTS will be able to predict those price movements accurately. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of open-end mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of an open-end mutual fund is calculated at the end of each business day. The trading prices of a closed-end mutual fund’s shares may differ significantly © MarketCounsel 2025 Page 12  CTS Financial Planning, Inc. Disclosure Brochure from the NAV during periods of market volatility, which may, among other factors, lead to a closed-end mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers CTS may recommend the use of Independent Managers for certain clients. CTS will continue to do ongoing due diligence of such managers, but such recommendations relies, to a great extent, on the Independent Managers ability to successfully implement their investment strategy. In addition, CTS does not have the ability to supervise the Independent Managers on a day-to-day basis other than as previously described in response to Item 4, above. Management Through Similarly Managed Accounts For certain clients, CTS may manage portfolios by allocating portfolio assets among various mutual funds on a discretionary basis using one or more of its proprietary investment strategies (collectively referred to as “investment strategy”). In so doing, CTS buys, sells, exchanges and/or transfers shares of mutual funds based upon the investment strategy. CTS’s management using the investment strategy complies with the requirements of Rule 3a-4 of the Investment Company Act of 1940, as amended. Rule 3a-4 provides similarly managed accounts, such as the investment strategy, with a safe harbor from the definition of an investment company. The investment strategy may involve an above-average portfolio turnover that could negatively impact upon the net after-tax gain experienced by an individual client. Securities in the investment strategy are usually exchanged and/or transferred without regard to a client’s individual tax ramifications. Certain investment opportunities that become available to CTS’s clients may be limited. For example, various mutual funds or insurance companies may limit the ability of CTS to buy, sell, exchange or transfer securities consistent with its investment strategy. As further discussed in response to Item 12, CTS allocates investment opportunities among its clients on a fair and equitable basis. © MarketCounsel 2025 Page 13  CTS Financial Planning, Inc. Disclosure Brochure Item 9. Disciplinary Information CTS is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of management. CTS does not have any required disclosures to this Item. Item 10. Other Financial Industry Activities and Affiliations CTS is required to disclose any relationship or arrangement that is material to its advisory business or to its clients with certain related persons. CTS has described such relationships and arrangements on the next page. Receipt of Insurance Commission CTS is under common control with Certified Insurance Consultants, Inc. (“CIC”), a duly licensed insurance agency. Certain of CTS’s Supervised Persons, in their individual capacities, are also licensed insurance agents with CIC, and in such capacity, may recommend, on a fully-disclosed commission basis, the purchase of certain insurance products. While CTS does not sell such insurance products to its investment advisory clients, CTS does permit its Supervised Persons, in their individual capacities as licensed insurance agents, to sell insurance products to its investment advisory clients. A conflict of interest exists to the extent that CTS recommends the purchase of insurance products where CTS’s Supervised Persons receive insurance commissions or other additional compensation. Item 11. Code of Ethics CTS and persons associated with CTS (“Associated Persons”) are permitted to buy or sell securities that it also recommends to clients consistent with CTS’s policies and procedures. CTS has adopted a code of ethics that sets forth the standards of conduct expected of its associated persons and requires compliance with applicable securities laws (“Code of Ethics”). In accordance with Section 204A of the Investment Advisers Act of 1940 (the “Advisers Act”), its Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public information by CTS or any of its associated persons. The Code of Ethics also requires that certain of CTS’s personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain pre- approval of certain investments such as initial public offerings and limited offerings. Unless specifically permitted in CTS’s Code of Ethics, none of CTS’s Access Persons may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household as the Access Person) any transactions in a security which is being actively purchased or sold, © MarketCounsel 2025 Page 14  CTS Financial Planning, Inc. Disclosure Brochure or is being considered for purchase or sale, on behalf of any of CTS’s clients. Access Persons may engage in transactions where completed as part of a batch trade with clients. When CTS is purchasing or considering for purchase any security on behalf of a client, no Access Person may affect a transaction in that security prior to the completion of the purchase or until a decision has been made not to purchase such security. Similarly, when CTS is selling or considering the sale of any security on behalf of a client, no Access Person may affect a transaction in that security prior to the completion of the sale or until a decision has been made not to sell such security. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact CTS to request a copy of its Code of Ethics. Item 12. Brokerage Practices As discussed above, in Item 5, CTS generally recommends that clients utilize the brokerage and clearing services of Schwab , as well as Nationwide Securities for certain retirement accounts and variable annuity accounts. The final decision to custody assets with Schwab is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. CTS is independently owned and operated and not affiliated with Schwab. Schwab provides CTS with access to its institutional trading and custody services, which are typically not available to retail investors. Factors which CTS considers in recommending Schwab, Nationwide Securities or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Schwab enables the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial Institutions. The commissions paid by CTS’s clients to Schwab comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to affect the same transaction where CTS determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. CTS © MarketCounsel 2025 Page 15  CTS Financial Planning, Inc. Disclosure Brochure seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. CTS periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions CTS receives without cost from Schwab administrative support, computer software, related systems support, as well as other third party support as further described below (together "Support") which allow CTS to better monitor client accounts maintained at Schwab and otherwise conduct its business. CTS receives the Support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The Support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The Support benefits CTS, but not its clients directly. Clients should be aware that CTS’s receipt of economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer over another that does not furnish similar software, systems support or services. In fulfilling its duties to its clients, CTS endeavors at all times to put the interests of its clients first and has determined that the recommendation of Schwab is in the best interest of clients and satisfies the Firm's duty to seek best execution. Specifically, CTS receives the following benefits from Schwab: i) receipt of duplicate client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication network for client order entry and account information. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at Schwab. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by CUSTODIAN. Other potential benefits may include occasional business entertainment of personnel of CTS by Schwab personnel, including meals, invitations to sporting © MarketCounsel 2025 Page 16  CTS Financial Planning, Inc. Disclosure Brochure events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist CTS in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of the Firm's fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts, including accounts not maintained at Schwab. Schwab also makes available to CTS other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Schwab may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to the Firm. While, as a fiduciary, CTS endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefits received and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. Brokerage for Client Referrals CTS does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Directed Brokerage The client may direct CTS in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by CTS (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, CTS may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). © MarketCounsel 2025 Page 17  CTS Financial Planning, Inc. Disclosure Brochure Trade Aggregation Transactions for each client will be affected independently, unless CTS decides to purchase or sell the same securities for several clients at approximately the same time. CTS may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among CTS’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which CTS’s Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. CTS does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13. Review of Accounts For those clients to whom CTS provides investment management services, CTS monitors those portfolios as part of an ongoing process while regular account reviews are generally conducted on a quarterly basis or as requested by the client. For those clients to whom CTS provides financial planning and/or consulting services, reviews are conducted on an “as needed” basis. Such reviews are conducted by one of CTS’s investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with CTS and to keep CTS informed of any changes thereto. CTS contacts ongoing investment advisory clients at least annually to review its previous services and/or © MarketCounsel 2025 Page 18  CTS Financial Planning, Inc. Disclosure Brochure recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account statements directly from the broker-dealer or custodian for the client accounts. Those clients to whom CTS provides investment advisory services may receive a report from CTS that may include such relevant account and/or market-related information such as an inventory of account holdings and account performance from time to time. Clients should compare the account statements they receive from their custodian with those they receive from CTS. Those clients to whom CTS provides financial planning and/or consulting services will receive reports from CTS summarizing its analysis and conclusions as requested by the client or otherwise agreed to in writing by CTS. Item 14. Client Referrals and Other Compensation In the event a client is introduced to CTS by either an unaffiliated or an affiliated solicitor, the Firm may pay that solicitor a referral fee in accordance with applicable state securities laws. Unless otherwise disclosed, any such referral fee is paid solely from CTS’s investment management fee and does not result in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the client will receive a solicitor’s disclosure statement containing the terms and conditions of the solicitation arrangement. Any affiliated solicitor of CTS is required to disclose the nature of his or her relationship to prospective clients at the time of the solicitation and will provide all prospective clients with a copy of the Firm’s written brochure(s) at the time of the solicitation. CTS may recommend certain of its clients to various professionals, Trostin, Kantor & Esposito, LLC, for various legal services (collectively, “Professionals”). The Professionals render such services independently of CTS. CTS does not receive any portion of the fees charged (referral or otherwise) for the services rendered by Professionals. However, CTS may receive reciprocal recommendations from these Professionals. Item 15. Custody CTS’s Agreement and/or the separate agreement with any Financial Institution may authorize CTS through such Financial Institution to debit the client’s account for the amount of CTS’s fee and to directly remit that management fee to CTS in accordance with applicable custody rules. The Financial Institutions recommended by CTS have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees © MarketCounsel 2025 Page 19  CTS Financial Planning, Inc. Disclosure Brochure paid directly to CTS. In addition, as discussed in Item 13, CTS may send periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from CTS. CTS also has custody due to clients giving the Firm limited power in a standing letter of authorization to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in an SEC no-action letter which includes (in summary): i) instruction from the client to the Financial Institution; ii) client authorization to the Firm to direct transfers to the third party; iii) the Financial Institution performs appropriate verification of the instruction and provides a transfer of funds notice to the client promptly after each transfer; iv) the client has the ability to terminate or change the instruction; v) the Firm has no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the Financial Institution sends the client an initial and annual notice confirming the instruction. In addition, CTS is deemed to have custody over clients’ assets (for reasons other than those discussed above), so the Firm is required to engage an independent accounting Firm to perform a surprise annual examination of those assets and accounts over which it maintains custody. Any related opinions issued by an independent accounting Firm are filed with the SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website. CTS does not have direct access to client funds as they are maintained with an independent qualified custodian. Item 16. Investment Discretion CTS is given the authority to exercise discretion on behalf of clients. CTS is considered to exercise investment discretion over a client’s account if it can effect transactions for the client without first having to seek the client’s consent. CTS is given this authority through a power-of-attorney included in the agreement between CTS and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). CTS takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17. Voting Client Securities CTS is required to disclose if it accepts authority to vote client securities. CTS does not vote client securities on behalf of its clients. Clients receive proxies directly from the Financial Institutions. © MarketCounsel 2025 Page 20  CTS Financial Planning, Inc. Disclosure Brochure Item 18. Financial Information CTS does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, CTS is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. CTS has no disclosures pursuant to this Item. © MarketCounsel 2025 Page 21  CTS Financial Planning, Inc. Disclosure Brochure CTS Financial Planning, Inc. a Registered Investment Adviser Prepared by: © MarketCounsel 2025 Page 22