Firm Description MTAM is an independent investment advisory firm that provides investment management and financial planning services. MTAM was acquired in March 1985 by Jed Bandes, and the firm was registered with the State of Florida in 2002 as a Registered Investment Adviser. Please see the section titled “Types of Advisory Services” below for more information about our services. Assets under management of MTAM are held primarily at Fidelity Brokerage, Schwab, and Hilltop Securities. While clients often provide us with discretionary authority to manage their accounts, the fact that their accounts remain in their names means clients retain access and control over their accounts at all times. Principal Owner Jed E. Bandes is the President and 100% owner of MTAM. Jed E. Bandes is also the sole owner of the affiliated Broker-Dealer, firm Mutual Trust Company of America Securities. Please refer to the rest of this Form ADV and specifically Item 12 regarding specific conflicts of interest related to the affiliated relationship and how it will affect you. Types of Advisory Services MTAM provides investing services to individuals, families, and their related entities, trusts and estates, retirement plans, charitable organizations, and small businesses. MTAM provides two types of services, Investment Advisory & Financial Planning: Investment Advisory Services: MTAM provides investment management services, which entails management of accounts, the purchase and sale of individual securities, and the selection and dismissal of sub-advisors, by the principals of the firm. Investment advisory services start with the evaluation and assessment of the client’s financial position and tolerance for risk. After a review of a client’s personal data, an investment strategy is developed, and specific investments are recommended. The strategy is then implemented on a discretionary basis. Investment portfolios and strategies are reviewed periodically. MTAM may recommend outside money managers. MTAM will have the discretion to hire and dismiss sub-advisors. Financial Planning: When performing financial planning services, MTAM works with clients to define financial objectives and develop strategies for reaching those objectives. Where appropriate, these strategies will be implemented over a period of time. Strategies could include wealth accumulation, investment planning, retirement planning, distribution planning, college funding planning, risk management analysis, income tax and estate planning implications, cash flow and debt management, and company benefit plan optimization. A portion of the fees for such planning is charged in advance, with the balance due upon completion. Should recommendations from such plans include insurance or brokerage services, representatives earn commissions, if the representative is securities and/or insurance licensed. Earning commissions causes a conflict of interest; we seek to remediate, mitigate, and disclose all such conflicts of interest. We have an inherent conflict of interest whenever we provide Financial Planning services to a client that also has retained our Investment Advisory services or our brokerage services, via our

affiliated broker. It could be in our best interest not to recommend paying down debt that would directly reduce the Assets Under Management that we manage and charge a percentage fee for, or on products we recommend and earn a commission for. We mitigate this conflict by providing an overall plan suitable and in the best interest of the client. Whenever we provide Financial Planning Services, we shall: 1. Document the scope of work in an agreement. 2. Prepare a questionnaire to understand the client’s needs. 3. Conduct a reasonable level of due diligence when referring other professionals to the Financial planning client. 4. Disclosure any and all compensation methods we shall receive. 5. Conduct reasonable due diligence when recommending or using technologies when providing professional CFP® services to a client. 6. Periodically monitor the CFP Board’s Code of Ethics and Standard of Conduct Whenever MTAM makes a recommendation for the Financial Planning client to utilize the services of a third-party as mentioned above, MTAM shall:
• Have a reasonable basis for the recommendation or Engagement based on the person’s reputation, experience, and qualifications.
• Disclose to the Client, at the time of the recommendation or prior to the Engagement, any arrangement by which someone who is not the Client will compensate or provide some other material economic benefit to the CFP® professional, the CFP® Professional’s Firm, or a Related Party for the recommendation or Engagement; and
• When engaging a person to provide services for a Client, exercise reasonable care to protect the Client’s interests. When selecting or using and recommending technology MTAM shall document the due- diligence process which will include:
• Exercising reasonable care and judgment when selecting, using, or recommending any software, digital advice tool, or other technology while providing Professional Services to a Client.
• Having a reasonable level of understanding of the assumptions and outcomes of the technology employed.
• Having a reasonable basis for believing that the technology produces reliable, objective, and appropriate outcomes. The CFP® professionals of MTAM will also review the complete CFP Board Code of Ethics and Standards of Conduct and the Practice Standards to ensure proper implementation within the firm. Tailored Relationships At MTAM, advisory services are tailored to the individual needs of clients. Client goals and objectives are clarified in meetings and via correspondence and are used to determine the course of action for each individual client. The goals and objectives for each client are documented in client files. In some cases, clients have the ability to impose restrictions on investing in certain securities or types of securities. For additional information on the Fees for the services described above, please see Item 5 Fees and Compensation below. Assets Under Management As of December 31, 2023, MTAM managed approximately $241,372,086 in assets under management for 1915 accounts, all of which are managed on a discretionary basis.