A. Firm Information Marino, Stram & Associates, LLC d/b/a MSA Financial (“MSA Financial” or the “Advisor”) is a registered investment advisor with the U.S. Securities Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of the Commonwealth of Massachusetts. In 1997 Richard E. Stram and Paul M. Marino co-founded MSA Financial and chose to affiliate with Securities America, Inc., an independent broker-dealer. MSA Financial became an LLC in Massachusetts on January 1, 2010 and in June 2011 MSA Financial became a registered investment advisor with the SEC in order to achieve a greater degree of independence and operational efficiency. MSA Financial is owned and operated by Richard E. Stram (Financial Advisor, Managing Director and Chief Compliance Officer), Paul M. Marino (Managing Director and Financial Advisor), Michael P. Cammarata (Financial Advisor, Partner) and Ryan A. Zimmerman (Financial Advisor, Partner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by MSA Financial. B. Advisory Services Offered MSA Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates, business entities, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. MSA Financial’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services MSA Financial provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and consulting services. The Advisor’s services are always provided based on the individual needs of each Client. This means, for example, that the Client is given the ability to impose restrictions on their account[s], including restricting specific investment selections and sectors. MSA Financial works with the Client on a one-on-one basis through interviews and questionnaires to determine the investment objectives and suitability information of the Client. MSA Financial will then implement a strategy, consisting of diversified mutual funds, variable annuities certificates of deposit (“CDs”), United States government securities and/or exchange- traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks and bonds to meet the needs of its Clients. The Advisor may also retain certain legacy investments based on portfolio fit and/or tax considerations. MSA Financial’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. MSA Financial will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. 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 Advisor. MSA Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. MSA Financial may recommend, on occasion, redistributing investment allocations to diversify the portfolio. MSA Financial may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. MSA Financial may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 At no time will MSA Financial accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 – Brokerage Practices. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), 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). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor 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 Advisor. Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce Clients to Goldman Sachs Private Bank Select, a non-purpose loan program available through Goldman Sachs Bank USA (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. Managed Account Programs – When deemed to be in the Client’s best interest, MSA Financial will recommend to Clients that all or a portion of their portfolio be implemented by utilizing one or more unaffiliated money managers participating in a managed accounts program at the Client's Custodian (the “Program Sponsor”). The Client will then enter into a program and investment advisory agreement with the Program Sponsor and the participating money manager[s]. The Advisor will assist and advise the Client in establishing investment objectives for the account, the selection of the money manager[s], and defining any restrictions on the account. MSA Financial will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of the unaffiliated money managers. These

money managers will develop an investment strategy to meet those objectives by identifying appropriate investments and monitoring such investments. In consideration for such services, the Program Sponsor will charge a program fee that includes the investment advisory fee of the money managers, the administration of the program and trading, clearance and settlement costs. The Program Sponsor will add MSA Financial‘s investment advisory fee (described below in Item 5) and will deduct the overall fee from the Client’s account[s], generally at the start of each calendar quarter. The asset-based program fee is tiered and varies depending on the size of the account, the asset class of the underlying securities and the sub-advisor selected. The overall fee (including the Advisor's investment advisory fee) will not exceed 3% annually. MSA Financial may receive monetary compensation from these unaffiliated money managers or the Program Sponsor, other than MSA Financial’s investment advisory fee, as described in Item 5 below. The additional compensation comes in the form of flights or hotels for meetings. The Client, prior to entering into an agreement with a Program Sponsor, will be provided with the Program Sponsor's Form ADV Part 2A (or a brochure that makes the appropriate disclosures). In addition, MSA Financial and its Client will agree in writing that that selected Program Sponsor will manage the Client's account[s] on a discretionary basis. Retirement Plan Advisory Services Page 6 MSA provides advisory services to retirement plans (each a “Plan”) and the company sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services Certain of these services are provided by MSA 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 MSA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Financial Planning and Consulting Services MSA Financial will typically provide a variety of financial planning or consulting services to Clients, either as a component of investment management or pursuant to a written Financial Planning or Consulting Agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. MSA Financial may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging MSA Financial to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor and that define the terms, conditions, authority and responsibilities of the parties. These services may include:
• Establishing an Investment Strategy – MSA Financial, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives. Page 7
• Asset Allocation – MSA Financial will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – MSA Financial will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – MSA Financial will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs MSA Financial does not sponsor a wrap fee program in connection with their investment management services. However, the Managed Opportunities Program offered by Securities America and certain Managed Account programs are wrap fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a Client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of Client transactions. Whenever a fee is charged to a Client for services described in this brochure (whether wrap fee or non-wrap fee), the Advisor will receive all or a portion of the fee charged. A complete description of these programs and related fees, charges, when due and termination procedures are described in the respective managers disclosure brochures, which you receive at or prior to the time a third-party managed account is established. E. Assets Under Management As of December 31, 2022, MSA Financial manages $870,408,679 in Client assets, $869,974,861 of which is managed on a discretionary basis and $433,817 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.