paper, bank certificates of deposit, municipal securities, U. S. government securities, foreign issuers, ETFs, and mutual funds. We provide investment advisory services through the Portfolio Management Program (PMP) on either a discretionary or a non-discretionary basis. Moors & Cabot’s PMP generally involves a $50,000 account minimum, unless otherwise agreed to by Moors & Cabot and the client. We document the discretionary authority we have within the written investment advisory PMP client agreement we have in place with you. For non-discretionary clients, we are obligated to obtain your specific consent (either verbally or in writing) prior to placing a transaction for your investment advisory account. As a result, you must be available to us during regular business hours when the securities markets are open. If you are not available, we cannot sell or purchase securities, and, as a result, you may suffer economic losses. Services are provided by determining your needs, objectives, and risk tolerance. We then align your responses and other information provided (via the New Account Application and the Investment advisory PMP client Agreement) in a portfolio aligned with meeting your stated objectives / needs (an appropriate asset allocation strategy). For example, a client with a long-term investment view, interested in long-term capital appreciation, will need a strategy that is substantially different from an investor with a shorter- term investment view who is interested in generating income. See Item 8 of this Part 2A for additional information. The program may use the services of third-party investment advisors to manage some (or all) of the assets in PMP. These advisors include: Adviser Description Eagleclaw Capital Management An affiliated registered advisor. One of our RRs, David W. Donahue, Jr., is the owner, portfolio manager, and an IAR of Eagleclaw. http://www.eagleclaw.com First Trust Investment Solutions, LP First Trust Investment Solutions, LP is a registered investment adviser headquartered in Naples, FL. which provides access to a variety of asset classes and investment strategies in a single account with the ability to customize a portfolio to a client’s investment objectives. First Trust, which acquired Gyroscope Capital Management Group, LP, provides low volatility, equity income and custom hedging solutions for individuals and institutional investors. https://www.ftsma.com/ Moors & Cabot advisors may also use one or more third party so-called Wrap Fee programs sponsored by un-affiliated third-party broker dealers / investment advisors as listed below to manage your assets. Programs available include the following (as of the date of this Part 2A Brochure) and are available only on a fee-only basis: Wrap Fee Program Name Sponsor Separately Managed Account Programs offered through RBC Correspondent Services are listed below:
• RBC Advisor
• RBC Unified Portfolios
• RBC Consulting Services RBC Capital Markets (“RBC CM”), a securities broker dealer registered with the SEC and FINRA. Please see Item 5 at “Wrap Fee Programs” and the Part 2A, Brochure Supplement that we provide to you for each of these programs (the so-called Wrap Fee Disclosure Brochure). Those disclosures identify the relevant fees, expenses, and other charges (and how the program works) to you. PMP “Advice Only” Certain clients have assets held at custodians other than RBC (“Held Away Assets”) (for information on our clearing firm, see Items 12 and 14, below). We will provide advice only on these assets. We do not manage them per se (we are not involved in the actual buy or sell decisions) but make recommendations to the client, who has the sole responsibility to decide whether to follow the recommendation and to implement any buy, sell or reallocation recommendation. A separate agreement is required for this service; you are billed separately for these services (see Item 5). Financial Planning Services We offer fee-based financial planning services. This service may include the following (which are selected by a client receiving the service):
• Written evaluation and analysis of information provided related to investment goals, objectives, and current financial circumstances.
• Analysis / recommendations related to tax planning, estate planning, investment planning, educational funding, retirement planning, and risk management (insurance). In providing these services, we do not provide legal, tax, or accounting advice. Please seek out your other professionals for that advice (attorney, CPA). We may, but are not obligated to, engage the services of outside consultants in the determination of or the delivery of your financial planning services or the engagement. In providing financial planning services, we gather information by asking you to provide a complete personal, family, and financial picture for us to work with. We do this by conducting in-depth personal interviews. Information gathered includes your current financial status, tax status, future goals, return objectives, and attitudes towards risk. Our financial plan recommendations are not limited to any specific product or service offered by or through

Moors & Cabot or any of our representatives. Please note that, to the extent that a client decides to implement any recommendation made by us, the client may use any investment adviser firm or broker-dealer that the client chooses, whether that is Moors & Cabot or some other firm. However, please note that our representatives have an incentive to recommend that the client use our services to implement the recommendations in the financial plan because that increases the representative’s compensation. That is a conflict of interest. In providing financial planning advice, we rely on the information provided by the client. We are not responsible for actions taken or not taken based upon incomplete, inaccurate, or false information provided by the client. Typically, the financial plan will be presented to the client within 90 days of the contract date, provided that the client has promptly provided all information needed to prepare the financial plan. Consulting Services Clients can also receive investment advice on a more limited basis. This may include advice on a targeted area(s) such as estate planning, retirement planning, and review of a client’s existing portfolio or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, we provide advice on non- securities matters such as estate planning, insurance, and annuities. Typically, the consulting service will be completed within 90 days of the contract date, if all information needed to complete the consulting engagement has been promptly provided by the client. Services in General We tailor all of our financial planning and consulting recommendations to the individual needs of each client. Please notify us immediately whenever your personal circumstances change (e.g., new job or loss of a job, marriage or divorce, death in the family, birth of a child, inheritance, college planning, etc.). Accounts opened or closed during a calendar quarter will have advisory fees due and payable by charging you for the days that services were provided. If fees are charged in advance, you will receive a refund of pre-paid and unearned advisory fees upon termination. For accounts opened during a calendar quarter, if fees are charged in advance, your fee will be charged at the inception of the account for the number of days the services are provided. Advisory fees are typically (except for financial planning) directly debited from your brokerage / custodial account at RBC for our investment management services, as you authorize in the written advisory agreement, we have with you. Fees for wrap fee programs are charged by the sponsor, debited from your custodial account, with Moors & Cabot’s share of the wrap fee paid to us by the sponsor (pursuant to your authorization in the wrap fee program agreement). All debits and credits into and out of your accounts are included in the statements your custodian sends directly to you on a monthly basis. If you do not receive your statements, please contact your custodian or your Moors & Cabot advisor immediately. It is very important that you receive your account statements directly from your custodian. Retirement Accounts. When the Adviser provides investment advice to clients regarding Employee Retirement Income Security Act (“ERISA”) retirement accounts or individual retirement accounts (“IRAs”), the Adviser is a fiduciary within the meaning of Title I of the ERISA and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the client’s best interest, the Adviser will provide investment advice to a client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Adviser will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Adviser. Investment Advisory Fees (PMP) Moors & Cabot generally charges management fees according to the following description. Asset-Based Fee In an advisory account, we charge either a flat percentage across all assets or an asset-based fee on a quarterly basis based on a tiered fee rate schedule. The fee is negotiable on a case-by-case basis, dependent upon a number of variables (e.g., account size, geographic region, types of securities / complexities, etc.) as negotiated between each client and his/her Moors & Cabot representative. The fee structures are set forth in the following Schedules. Schedule A — Flat Advisory Fee Schedule: Negotiated Annual Fee % on Total Account Value ____ % Or, Schedule B — Tiered Advisory Fee Schedule: Tier Account Value Range Negotiated Annual % Fee* 1 $0 To $249,999.99 2 $250,000 To $499,999.99 3 $500,000 To $999,999.99 4 $1,000,000 To $2,999,999.99 5 $3,000,000 To +