Firm Information Founded in September 2009, by Shawn P. McLaughlin, as McLaughlin Ryder Advisory Services, LLC (MRAS), MRAS was then merged with McLaughlin Ryder Investments, Inc. (MRI, McLaughlin Ryder, Firm), in January 2016. McLaughlin Ryder Investments, Inc., is a full-service investment advisory and financial planning firm registered with the U.S. Securities and Exchange Commission (“SEC”), located at 1421 Prince Street, Alexandria, Virginia 22314. MRI is considered a dually registered firm, which means that we operate a full-service broker-dealer division, as well as an investment advisory division. MRI’s current CEO is Shawn P. McLaughlin. MRI is wholly owned by The McLaughlin Companies, LLC, its parent company. With the exception of our advisory services for ERISA plans and ERISA plan participants, all of our investment advisory business is processed through our broker-dealer division. Investment advisory business of MRI is not processed through any other broker-dealer. All clients who wish to enroll in a wrap fee program with MRI are required to establish a brokerage account for this purpose. The wrap fee programs offered by MRI are a combination of proprietary programs and also programs offered through MRI’s clearing firm, Pershing LLC (“Pershing”). Some programs may include the services of an outside third-party investment manager. What is the difference between an Investment Advisory Firm and a Broker-Dealer? Broker-dealers play an important role in helping investors organize their finances, accumulate, and manage retirement savings, and invest toward other important long-term goals, such as buying a house or funding a child’s college education. Broker-dealers offer a wide variety of brokerage (i.e., agency) services and dealer (i.e., principal) services and products to both retail and institutional customers. Specifically, the brokerage services provided to retail customers range from execution-only services to providing personalized investment advice in the form of recommendations of securities transactions or investment strategies involving securities to customers. Investment advisers play a similarly important, though distinct, role. As described in the Fiduciary Interpretation, investment advisers provide a wide range of services to a large variety of clients, from retail clients with limited assets and investment knowledge and experience to institutional clients with very large portfolios and substantial knowledge, experience, and analytical resources. As a general matter, broker-dealers and investment advisers have different types of relationships with investors, offer different services, and have different compensation models when providing investment recommendations or investment advisory services to customers. Broker-dealers typically provide transaction-specific recommendations and receive compensation on a transaction-by-transaction basis (such as commissions) (“transaction-based” compensation or model). A broker-dealer’s recommendation may include recommending transactions where the broker-dealer is buying securities from or selling securities to retail customers on a principal basis, or recommending proprietary products, although it is noteworthy that McLaughlin Ryder carries no proprietary products. Investment advisers, on the other hand, typically provide ongoing, regular advice and services in the context of broad investment portfolio management and are compensated based on the value of assets under management (“AUM”), a fixed fee or other arrangement (“fee-based” compensation or model). This variety is important because it presents investors with choices regarding the types of relationships they can have, the services they can receive, and how they can pay for those services. It is also common for a firm, like McLaughlin Ryder, to provide both broker-dealer and investment adviser services. Importantly, regardless of whether a retail investor chooses a broker-dealer and/or an investment adviser, the retail investor will be entitled to a recommendation (from a broker-dealer) or advice (from an investment adviser) that is in the best interest of the retail investor and that does not place the interests of the Firm or the financial professional ahead of the interests of the retail investor. Fiduciary Duty and Regulation Best Interest McLaughlin Ryder provides advisory services to individuals, families, trusts, estates, charitable organizations, businesses, and retirement plans (each referred to as a “Client”). McLaughlin Ryder provides individualized services to each Client, which are determined during initial conversations, and updated over the course of the relationship as needed or requested by the Client. McLaughlin Ryder serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Firm upholds a duty of care, loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. Each investment adviser must always serve the best interest of their client and not subordinate their client’s interest to their own. The fiduciary duty follows the contours of the relationship between the adviser and their client, and the adviser and the client may shape that relationship by agreement, provided there is full and fair disclosure and informed consent. An investment adviser’s duty of care includes the: (i) duty to provide advice that is in the best interest of the client; (2) duty to seek best execution of a client’s transactions when the adviser has the responsibility to select broker-dealers to execute client trades; and (2i) duty to provide advice and monitoring over the course of the relationship. The duty to provide advice that is in the best interest of the client, includes a duty to provide advice that is suitable for the client, based on a reasonable understanding of the client’s financial and investment profile and objectives. At all times, the adviser must have a reasonable belief that the advice they are providing is in the best interest of the client. The investment adviser has the responsibility to seek best execution of a client’s transaction when selecting broker- dealers to execute client trades; without placing its own interest ahead of its client’s interest. The adviser also has the duty to provide advice and account monitoring over the course of the relationship.
The duty of loyalty includes the obligation of an investment adviser, including the: (i) duty to make full and fair disclosure of all material facts regarding the relationship, including the capacity in which the Firm is acting (investment adviser or broker-dealer); (2) duty to not favor its own interests ahead of its clients; and (2i) duty to identify conflicts and attempt to mitigate or eliminate those conflicts of interest, and, in the case where the conflict cannot be eliminated, disclose such conflict of interest to the client. McLaughlin Ryder’s fiduciary commitment is further described in the Firm’s Code of Ethics; for more information, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Types of Advisory Services Offered Investment Management Services McLaughlin Ryder collaborates closely with each Client to identify their investment goals and objectives, as well as risk tolerance and financial situation, in order to create a portfolio strategy. McLaughlin Ryder will then construct a portfolio, consisting of primarily active and passive mutual funds, exchange-traded funds (“ETFs”), individual equity securities, individual fixed income securities and other types of investments, as appropriate, to meet the needs of each Client. Evaluation of legacy investments will include a review of portfolio fit, tax situation and other considerations. The Firm may retain certain legacy investments based on portfolio fit and/or tax considerations. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Firm. McLaughlin Ryder will construct, implement, and monitor the portfolio on either a discretionary or non-discretionary basis, with respect to the Client’s advisory agreement. At no time will McLaughlin Ryder accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices and Item 15 – Custody. Financial Planning and/or Portfolio Management Financial Planning Services are at the core of the Client’s relationship with McLaughlin Ryder. Financial planning is an evaluation of a Client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans while also understanding personal values, goals, and objectives. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the Client. McLaughlin Ryder will provide financial planning and consulting services to Clients, as outlined in the Financial Planning Agreement. Services are offered in several areas depending on the Client’s goals and objectives. Generally, such financial planning services will involve a written report, which provides the Client with a detailed financial plan to assist the Client in achieving his or her financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to: financial position, risk tolerances, capital appreciation objectives, income and liquidity requirements, tax considerations, employee benefits, investment analysis, insurance analysis, retirement analysis, death and disability considerations, investment horizon, and estate planning. McLaughlin Ryder will then construct a portfolio, primarily consisting

of:
•active and passive mutual funds;
•exchange-traded funds (“ETFs”);
•individual equity securities;
•individual fixed income securities;
•Certificates of Deposit; and,
•other types of investments, as appropriate to meet the needs of each Client. Evaluation of legacy investments will include a review of portfolio, tax situation, and other considerations. The Firm may retain certain legacy investments based on portfolio fit and/or tax considerations. McLaughlin Ryder serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Firm upholds a duty of loyalty, fairness, and good faith towards each Client, and seeks to mitigate potential conflicts of interest. MRI’s fiduciary commitment is further described in the Firm’s Code of Ethics; for more information, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Financial planning and consulting recommendations pose a conflict between the interests of McLaughlin Ryder and the interests of the Client. For example, the Firm has an incentive to recommend that Clients engage the Firm for investment management services, or to increase the level of investment assets with the Firm, as it would increase the amount of advisory fees paid to the Firm. Implementation of financial planning recommendations is entirely at the Client’s discretion. If the Client elects to act on any of the recommendations made by the Firm, the Client is under no obligation to implement the transaction through the Firm. McLaughlin Ryder will collaborate with the Client, to implement recommendations and referrals to other professionals, where appropriate, to meet the Client’s needs. Retirement Plan Advisory Services MRI provides advisory services to retirement plans, subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), including participant-directed defined contribution plans, such as 401(k) plans, and defined benefit plans (“ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an advisory agreement with MRI (the “Advisory Agreement”), describing the services that MRI will perform for the ERISA plan and its participants. MRI provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. MRI’s fiduciary services include, providing ERISA Plan Clients with investment advice about asset classes and investments, assisting in the selection of investments, assisting in the development of an investment policy statement, and monitoring investment performance. MRI also provides investment advice to participants of ERISA participant-directed plans. The plan-level and participant- level investment advisory services, are provided on a non-discretionary basis, and the ERISA Plan Client and plan participant (in the case of participant-level advice) retain and exercise final decision-making authority and responsibility for the implementation (or rejection) of MRI’s recommendations. MRI’s non-fiduciary services include educating the ERISA Plan Client as to its fiduciary responsibilities, assisting the ERISA Plan Client in monitoring, selecting and supervising service vendors, and in the case of participant-directed plans, assisting in group enrollment meetings and educating plan participants about general investment principles and the investment alternatives under the plan. McLaughlin Ryder typically provides the following Plan Fiduciary Services, pursuant to the scope and terms of McLaughlin Ryder’s agreement with each Plan Sponsor:
• Vendor Analysis;
• Plan Participant Enrollment and Education;
• Investment Management Services;
• Investment Oversight Services; and,
• Performance Reporting. These services are provided by McLaughlin Ryder, serving in the capacity as a fiduciary, under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of McLaughlin Ryder’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation that the Firm reasonably expects, under the engagement. For a more detailed description of MRI’s services, the ERISA Plan Client should refer to the Advisory Agreement. Wrap Fee Programs MRI offers several different wrap fee programs, some internal and others through Pershing. A wrap fee program is an investment account where clients are charged a single, bundled, or “wrap” fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. While wrap fee programs may be called different names—such as asset allocation program, asset management program, investment management program, or separately managed account—the defining feature is that a wrap fee program offers bundled investment management and brokerage services for one fee. Our financial planning services practices are provided to our clients on an hourly, monthly, quarterly, annual, or flat fee basis for the services we provide. This is different than the wrap fee programs that we provide, in which the client is not charged a quarterly fee for the ongoing monitoring and management of their investment advisory account. Please refer to our Wrap Fee Brochure for additional information regarding the different wrap fee programs that MRI has to offer. Wrap fee programs can be either Discretionary or Non-Discretionary. A Discretionary investment advisory account is an account where buy and sell decisions are made by a portfolio manager, or the Financial Professional for the client’s account. The term "discretionary" refers to the fact that investment decisions are made at the portfolio manager or Financial Professional’s discretion. A Non-Discretionary investment advisory account is an account where buy and sell decisions are made by the client. This means that the client must direct all transactions to be completed on an account. The Financial Professional or portfolio manager does not have the ability to complete transactions without first getting permission from the client. We offer a number of wrap fee advisory programs that are designed to help clients meet their investment objectives and goals. They include Third-Party Management Programs, Financial Professional Directed Programs, and Non- Discretionary Client Directed Advisory Programs, as well as Discretionary Advisory Programs, which are described in the Wrap Fee brochure. Please refer to our Wrap Fee Brochure for additional information regarding the different wrap fee programs that MRI has to offer. How Services are Tailored to Fit Client Needs MRI's investment process is centered on the client. We collaborate with our clients to understand their financial circumstances and goals. Throughout this process, our Financial Professionals work with the client to create a specific plan tailored to their needs and goals. Specifically, our Financial Professionals focus on translating client goals into a set of investment objectives. These objectives involve risk tolerance from both a willingness and ability to accept financial risk, as well as return objectives. Once determined, these investment objectives provide a framework for MRI to discuss with the client, the processes we will utilize for monitoring, reviewing, and rebalancing their account. The Financial Professional will collaborate with the client to determine:
• How performance will be measured for the account;
• Benchmarks and the frequency of reporting the client would like to see; and,
• A plan for when and how often the client would like to meet with us to discuss their account. Clients may stipulate, if they would like to restrict the Firm from purchasing certain products or securities in their account. The Firm will comply with any reasonable instructions and/or restrictions provided by the client, when making recommendations for their account. Reasonable instructions generally include the designation of particular mutual fund/securities or types of mutual funds/securities that should not be purchased for the account. If the restrictions are unreasonable, or if we believe that the restrictions are inappropriate, the Firm will notify the client that, unless they are modified, we may remove their account from the program. Clients will not be able to provide instructions that prohibit or restrict the investment adviser of a security with respect to the purchase or sale of specific securities or types of securities within the security itself. Client Account Management Prior to engaging McLaughlin Ryder to provide investment advisory services, each Client is required to enter into one or more agreements with the Firm, which define the terms, conditions, authority, and responsibilities of the Firm and the Client. These services may include:
• Establishing an Investment Strategy – McLaughlin Ryder, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Portfolio Construction – McLaughlin Ryder will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – McLaughlin Ryder will provide investment management and ongoing oversight of the Client’s investment portfolio. McLaughlin Ryder will review Client portfolios at least annually.
•Financial Planning – McLaughlin Ryder provides initial and ongoing planning services, to assist Clients in meeting the financial goals. Management of Client Assets MRI investment advisory accounts are managed on either a discretionary or non-discretionary basis, determined at the time the account is opened, based on our client's written authorization, or in the case of ERISA Plan Clients, at the time the Advisory Agreement is executed. As of December 31, 2023, MRI had the following client assets under management (AUM):
• $418,978,393 non-discretionary assets under management
• $8,909,320 discretionary assets under management