Madison Advisory Services, Inc. (hereinafter referred to as “Madison Advisory”) is an investment advisory firm offering a variety of advisory services customized to your individual needs. A. Madison Advisory was established in June of 2004. Madison Advisory is wholly owned by Madison Family Holdings LLC, and principal owner of Madison Family Holdings LLC is Gary Robert Schwartz. B. Madison Advisory offers the following advisory services. Each of the services is more fully described below.
• Investment Supervisory Services / Asset Management
• Analysis, Recommendation and Monitoring of Third Party Managed Programs
• Financial Planning and Advisory Services Non-pension accounts advisory services are offered through Envestnet, Aria Wealth, SEI and AssetMark on a wrap fee basis and a non-wrap fee basis. Pension account advisory services offered through Aspire, Newport Group and American Funds. There will be no wrap fees charged for non-pension account advisory services. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Madison Advisory tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. We may refuse to accept or manage your account if we determine such restrictions are unreasonable. In the event that we are unable to accept your restriction, we will give you the opportunity to modify or withdraw the restriction. 5 of 25 Madison Advisory will meet with you and conduct an interview and data gathering session to gather financial information and history about you. You will be asked to bring to your meeting with Madison Advisory documentation such as tax returns, W2s, financial and bank statements, wills and trusts, and other supporting documentation as requested by Madison Advisory. The information gathered by Madison Advisory will assist Madison Advisory to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, Madison Advisory will gather various financial information and history from you including, but not limited to:
• Retirement and financial goals
• Investment objectives
• Investment horizon
• Financial needs
• Cash flow analysis
• Cost of living needs
• Education needs
• Savings tendencies
• Other applicable financial information required by Madison Advisory in order to provide the investment advisory services requested. D. Wrap Fee Programs Madison Advisory does not sponsor a wrap account program. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. Envestnet, Aria, AssetMark and SEI may offer wrap programs. E. As of December 2022, we have approximately $ 354,907,541of client assets under our discretionary management and approximately $ 278,440of non-discretionary client assets under management. Investment and Supervisory Services Madison Advisory offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. The firm creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy • Asset allocation
• Asset selection • Risk tolerance
• Regular portfolio monitoring Madison Advisory evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Madison Advisory will request discretionary authority from 6 of 25 clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. MF/ETF Program Profile and Proposal Process Your relationship generally begins with you completing an Investor Profile Questionnaire (IPQ). The purpose of the IPQ is to assist your Advisor in understanding your investment objectives, financial situation, risk tolerance, investment time horizon and other pertinent information. The information that we gather will also be used to propose an appropriate MF/ETF Program asset allocation strategy. Once you receive the proposal and meet with your Advisor, you will determine whether to adopt, modify or reject the recommended asset allocation strategy. Investment Management Philosophy Our Program provides you with the opportunity to participate in an asset allocation program using a strategic model, or a combination of tactical and strategic models. Strategic Asset Allocation Strategic asset allocation is a portfolio strategy that involves the periodic rebalancing of your portfolio in order to maintain a long-term goal of a chosen asset allocation mix. The initial investments are chosen based on your risk tolerance. Because the value of the assets can change based on market conditions, the portfolio constantly needs to be re-adjusted to meet the policy. This is often called rebalancing and may be done at regular intervals. The Model Provider does not purposely deviate from the original determined asset allocation percentages. The emphasis is on preserving this initial chosen asset allocation mix because the mix ultimately relates to a larger performance objective based on historical data. Tactical Asset Allocation Tactical asset allocation is a portfolio strategy that involves the rebalancing of assets held in various categories in order to take advantage of market pricing anomalies or strong market sectors, as chosen by the portfolio managers. This strategy allows the Model Provider the opportunity to try and create extra value by taking advantage of these potential situations in the markets. It is a moderately active strategy and may use short-term trading methods. The investment philosophy is usually based on the belief that investor psychology and market forces can lead to periods of misevaluation. A tactical allocation process attempts to capture these misevaluations. It is not a fixed asset weight mix and the allocation and risk level of the portfolio may change quite dramatically. Deposits and/or Withdrawals Unless specifically stated, you may make additions to or withdrawals from your account at any time. If your account falls below the minimum required account value, we may terminate your account. You may also add securities to your account; however, note that we reserve the right to not accept particular securities into your account. Trading Authorization We will assist you in determining an appropriate investment strategy to follow. By completing the account opening documentation, you authorize us to act as your agent and attorney-in-fact to direct the investment and reinvestment of the assets in your account. Pershing is currently utilized for clearing and trade execution services. Folio will rebalance your account whenever the account moves up or down 25% from the target allocation designed by the Model Provider 7 of 25 In-Kind Transfers The MF/ETF Program allows for in-kind transfers to fund accounts. For in-kind transfers, your Advisor may be charged a nominal fee. This creates a conflict of interest for the Advisor as he or she bears the cost if this option is used. Third Party Advisory Services We offer our clients the services of various third party investment advisors (“Third-Party Advisory Services”) for the provision of certain investment advisory programs including mutual fund wrap and separately managed account programs. If you are interested in learning more about any of these services, please note that a complete description of the programs, services, fees and payment structure, and termination features is available via the applicable Third Party Advisory Service’s disclosure brochures, investment advisory contracts, and account opening documents. In connection with these arrangements, we will provide assistance in the selection and ongoing monitoring of a particular Third-Party Advisory Service. Factors that we consider in the selection of a particular third-party advisor may include but may not be limited to: i) our assessment of a particular Third-Party Advisory Service; ii) your risk tolerance, goals, objectives and restrictions, as well as investment experience; and, iii) the assets you have available for investment. You should know that the services provided by us through the use of Third-Party Advisory Services are under certain conditions directly offered by them to you. The fees charged by Third-Party Advisory Services who offer their programs directly to you may be more or less than the combined fees charged by the Third Party Advisory Service and us for our participation in the investment programs. However, when using the services of Third-Party Advisory Services directly, you do not receive our expertise in developing an investment strategy, selecting a Third-Party Advisory Service, monitoring the performance of your account and changing a Third-Party Advisory Service provider when appropriate. SEI Investments Management Corporation Madison Advisory offers an asset allocation and managed programs (Managed Account Solutions and Integrated Managed Account) (the “Program”) and MAS Custom Portfolios through SEI Investments Management Corporation and Aria. Madison Advisory provides the following services:
• Assist the client to evaluate and determine one or more of the SEI programs or build an investment model tailored to the client using the SEI platform.
• Assist the client to determine the asset allocation model best suited to each client’s investment objectives and risk tolerance. Clients may accept, reject or modify asset allocations.
• Provide SEI with information concerning the client’s financial situation, investment objectives and any restrictions
• Monitor and manage the managed account.
• Meet with the client at least annually to review the account and update the client’s suitability information 8 of 25
• Make changes to the selected asset allocation and/or selected managers (i.e. hire and fire managers) as Madison Adviser deems appropriate
• Assist the client with account set up and completion of the Account Application.
• Communicate client requests and instructions to SEI. It is important clients refer to the Disclosure Brochures of SEI and selected asset managers for additional information about the services and management program. Additionally, the SEI Account Application and the Investment Management Agreement contain important details about the program. ARIA ENVESTNET Aspire – 403(b) business, no account minimum -pension 401 Services – Newport Group and American Funds Participant Directed Retirement Plans. Madison Advisory may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a written agreement between Madison Advisory and the plan. For such engagements, Madison Advisory shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by Madison Advisory), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process. Participant Account Management (Discretionary) in association with Ponterra - We use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. ARIA/Envestnet- Through a relationship with ARIA we use their institutional version of Envestnet. We are able to custody at Pershing or Schwab. We currently use Madison models only although we do have the ability to use Envestnet’s models if we choose so. Envestnet will debit clients accounts quarterly in advance. ARIA receives part of the platform fee and then pays Madison the advisory fee. In all cases Madison does not directly bill nor custody the assets 9 of 25 Financial Planning and Advisory Services Madison Advisory offers various financial planning and consulting services including but not limited to: ▪ Financial Planning ▪ Estate Planning ▪ Tax Planning ▪ Retirement Planning ▪ College Planning ▪ Consulting Services ▪ Asset Allocation Services ▪ Annual Advisory and Consulting Services Advisory Services are based on your financial situation at the time and are based on financial information disclosed by you to Madison Advisory. You are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. Madison Advisory cannot offer any guarantees or promises that your financial goals and objectives will be met. Further, you must continue to review the plan and update the plan based upon changes in your financial situation, goals, or objectives or changes in the economy. Should your financial situation or investment goals or objectives change, you must notify Madison Advisory promptly of the changes. You are advised that the advice offered by Madison Advisory may be limited and is not meant to be comprehensive. Therefore, you may need to seek the services of other professionals such as an insurance adviser, attorney and/or accountant. You are not obligated to implement advice through Madison Advisory or Advisory Representatives. Should you implement the plan with Madison Advisory’s Advisory Representatives commissions or other compensation may be received in addition to the advisory fee paid to Madison Advisory. General Information You are advised the investment recommendations and advice offered by Madison Advisory are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform Madison Advisory promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify Madison Advisory of any such changes could result in investment recommendations not meeting your needs. MISCELLANEOUS PROVISIONS Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, Madison

Advisory will generally provide financial planning and related consulting services regarding matters such as tax and estate planning, insurance, etc. Madison Advisory will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions can and will occur based upon assets under management, extraordinary matters, special projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional financial planning fee per Item 5 below). Please Note. Madison Advisory believes that it is important for the client to address financial planning issues on an ongoing basis. Madison Advisory’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Madison Advisory. Please Also Note: Madison Advisory does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Madison Advisory does not prepare legal documents or tax returns, not doe sit offer or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including Madison Advisory’s representatives 10 of 25 in their separate individual capacities as registered representatives of Lion Street Financial, LLC (“Lion Street”), an SEC registered and FINRA member broker-dealer, and as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. Please Note-Conflict of Interest: The recommendation that a client purchase a securities or insurance commission product from a Madison Advisory’s representative in his/her individual capacity as a representative of Lion Street and/or as an insurance agent, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment and/or insurance products based on commissions to be received, rather than on a particular client’s need. The fees charged and compensation derived from the sale of such insurance and/or securities products is separate from, and in addition to, Madison Advisory’s investment advisory fee. No client is under any obligation to purchase any securities or insurance commission products from any of the Madison Advisory’s representative. Clients are reminded that they may purchase securities and insurance products recommended by a Madison Advisory’s representatives through other, non-affiliated broker-dealers and/or insurance agents. ANY QUESTIONS: Madison Advisory’s Chief Compliance Officer, Gary Schwartz, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. If the client engages any such affiliated or unaffiliated professional, and a dispute arises thereafter relative to such engagement, the engaged professional (and not Madison Advisory) shall remain exclusively responsible for resolving any such dispute with the client. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Madison Advisory recommends that a client roll over their retirement plan assets into an account to be managed by Madison Advisory, such a recommendation creates a conflict of interest if Madison Advisory will earn new (or increase its current) compensation as a result of the rollover. If Madison Advisory provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Madison Advisory is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Madison Advisory, whether it is from an employer’s plan or an existing IRA. Madison Advisory’s Chief Compliance Officer, Gary Schwartz, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Custodian Charges-Additional Fees. When requested to recommend a broker-dealer/custodian for client accounts, Madison Advisory generally recommends that SEI serve as the broker-dealer/custodian for client investment management assets. When not providing services as part of a wrap program, broker-dealers such as SEI can charge brokerage commissions, transaction, and/or other type fees for effecting transactions for client accounts. These fees/charges are in addition to Madison Advisory’s investment advisory fee at Item 5 below. Madison Advisory does not receive any portion of these fees/charges. ANY QUESTIONS: Madison Advisory’s Chief Compliance Officer, Gary Schwartz, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity. Madison Advisory has a fiduciary duty to provide services consistent with the client’s best interest. Madison Advisory will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Madison Advisory determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by the Madison Advisory will be profitable or equal any specific performance level(s). Other Assets. To the extent that the Madison Advisory provides advisory monitoring or review services for client investment assets for which the Madison Advisory does not maintain custodian access or trading authority ((including initial and ongoing consideration of such assets as part of the client’s asset allocation), the Madison Advisory may determine to include such assets in its advisory fee calculation per Item 5 below. Independent Managers. The Madison Advisory may recommend that clients allocate a portion of their investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets, including, to the extent 11 of 25 applicable, proxy voting responsibility. Madison Advisory shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that Madison Advisory shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note. The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, Madison Advisory’s investment advisory fee disclosed at Item 5 below. ANY QUESTIONS: Madison Advisory’s Chief Compliance Officer, Gary Schwartz, remains available to address any questions that a client or prospective client may have regarding the allocation of account assets to an Independent Manager(s), including the specific additional fee to be charged by such Independent Manager(s). Interval Funds/Risks and Limitations: Where appropriate, Madison Advisory may utilize interval funds (and other types of securities that could pose additional risks, including lack of liquidity and restrictions on withdrawals). An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct Madison Advisory, in writing, not to purchase interval funds for the client’s account. Please Note: Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that maintain an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Madison Advisory), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Madison Advisory does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. Please Note-Use of Mutual and Exchange Traded Funds: Madison Advisory utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Madison Advisory’s investment advisory fee described below, and applicable transaction and/or custodial fees discussed above (when not providing services as part of a wrap program), clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Please Note: Cash Positions. Madison Advisory continues to treat cash as an asset class. As such, unless determined to the contrary by Madison Advisory, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Madison Advisory’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Madison Advisory may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Madison Advisory’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Madison Advisory’s Chief Compliance Officer, Gary Schwartz, remains available to address any questions that a client or prospective may have regarding the above fee billing practice 12 of 25 Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Madison Advisory does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Madison Advisory does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Madison Advisory:
• by taking the loan rather than liquidating assets in the client’s account, Madison Advisory continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by Madison Advisory, Madison Advisory will receive an advisory fee on the invested amount; and,
• if Madison Advisory’s advisory fee is based upon the higher margined account value, Madison Advisory will earn a correspondingly higher advisory fee. This could provide Madison Advisory with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Client Obligations. In performing our services, Madison Advisory shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Madison Advisory if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Madison Advisory) will be profitable or equal any specific performance level(s). Disclosure Brochure. A copy of Madison Advisory’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and Madison Advisory