MFA was formed in 2014 and is wholly owned by Christopher McMahon. The Firm is registered as an investment adviser with the Securities and Exchange Commission and, as of December 31, 2023, MFA managed $479,062,563 in client assets on a discretionary basis and $263,047 on a non-discretionary basis. GENERAL: MFA provides discretionary investment advisory services on a fee basis. MFA's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of MFA), MFA may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. To commence the investment advisory process, MFA will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, MFA provides ongoing supervision of the account(s). Before engaging MFA to provide investment advisory services, clients are required to enter into an Investment Management Agreement with MFA setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, MFA will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. MFA will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional fee). Please Note. MFA believes that it is important for the client to address financial planning issues on an ongoing basis. MFA’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 MFA. Please Also Note: MFA does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, MFA does not prepare legal documents, prepare tax returns, 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 MFA representatives in their separate individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from MFA and/or its representatives. Please Also Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not MFA, shall be responsible for the quality and competency of the services provided. Please Further Note-Conflict of Interest: The recommendation by an MFA representative that a client purchase an insurance product from an MFA representative in his/her individual capacity 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 products is separate from, and in addition to, MFA’s investment advisory fee. No client is under any obligation to purchase any insurance products from an MFA representative. Clients are reminded that they may purchase insurance products recommended by a MFA representative through other, non-affiliated insurance agents. ANY QUESTIONS: MFA’s Chief Compliance Officer, David Reichert, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. 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). When MFA provides investment advice to clients regarding retirement plan accounts, MFA is 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. If MFA recommends that a client rolls over their retirement plan assets into an account to be managed by MFA, such a recommendation creates a conflict of interest if MFA will earn new (or increase its current) compensation as a result of the rollover, therefore MFA abides by the following provisions to act in each client’s best interest:
• 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. No client is under any obligation to roll over retirement plan assets to an account managed by MFA. MFA’s Chief Compliance Officer, David Reichert, 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. Portfolio Activity. MFA has a fiduciary duty to provide services consistent with the client’s best interest. MFA 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 MFA determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities 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 few 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 MFA), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, MFA will consider investment in a corresponding exchange traded securities and/or private funds that provides cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications with codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Cryptocurrency is currently considered to be a speculative investment. The speculative nature of cryptocurrencies notwithstanding, MFA may (but is not obligated to) utilize crypto exposure in one or more of its asset allocation strategies for diversification purposes. Please Note: Investment in cryptocurrencies is subject to the potential for liquidity constraints, extreme price volatility and complete loss of principal. Notice to Opt Out. Clients can notify MFA, in writing, to exclude cryptocurrency exposure from their accounts. Absent MFA’s receipt of such written notice from the client, MFA may, but is not obligated to, utilize cryptocurrency as part of its asset allocation strategies for client accounts. Mutual and Exchange Traded Funds: MFA utilizes mutual funds and exchange traded funds for its client portfolios. In addition to MFA’s investment advisory fee described below, and transaction and/or custodial fees discussed below, 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). Wrap Program-Conflict of Interest. MFA provides services on a wrap fee basis as a wrap program sponsor. Under MFA’s wrap program, the client generally receives 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 client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in MFA’s Wrap Fee Program Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by MFA to the account custodian/broker-dealer, MFA could have an economic incentive to maximize its compensation by seeking to minimize

the number of trades in the client's account. See separate Wrap Fee Program Brochure. MFA’s Chief Compliance Officer, David Reichert, remains available to address any questions that a client or prospective client may have regarding a wrap fee arrangement and the corresponding conflict of interest. Transaction Fees. Beginning in October 2019, our clients’ custodian, Charles Schwab, stopped charging transaction fees for individual equities (i.e., common stocks and ETFs). As the result, total transaction fees paid by MFA under the MFA wrap program decreased. MFA did not alter its advisory fee schedule as result of this change. Either party may terminate the agreement for services at any time by providing written notice to the other party. Termination is effective immediately upon receipt of the termination notice. Fees are prorated based on the number of days that services were actually provided during the final quarter and any prepaid, unearned fees are promptly refunded to you. ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS: Trustee Directed Plans. MFA may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, MFA will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). MFA will generally provide services on an “assets under management” fee basis per the terms and conditions of a Discretionary Investment Management Agreement between the Plan and the Firm. Participant Directed Retirement Plans. MFA may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between MFA and the Plan. For such engagements, MFA 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 MFA), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Client Retirement Plan Assets. If requested to do so, MFA shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, MFA shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. MFA’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. MFA will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify MFA of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage MFA on a non- discretionary investment advisory basis must be willing to accept that MFA cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that MFA would like to make a transaction for a client’s account, and client is unavailable, MFA will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Please Note: Cash Positions. MFA treats cash as an asset class. As such, all cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating MFA’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), MFA 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, MFA’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: MFA’s Chief Compliance Officer, David Reichert, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. 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 its 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, MFA does not recommend such borrowing unless it is for specific short- term purposes (i.e. a bridge loan to purchase a new residence). MFA 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 MFA:
• by taking the loan rather than liquidating assets in the client’s account, MFA 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 MFA, MFA will receive an advisory fee on the invested amount; and,
• if MFA’s advisory fee is based upon the higher margined account value, MFA will earn a correspondingly higher advisory fee. This could provide MFA 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, MFA 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 MFA 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 MFA) will be profitable or equal any specific performance level(s). Use of Independent Managers. MFA may select certain Independent Managers to actively manage a portion of its clients' assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. MFA evaluates a variety of information about Independent Managers, which includes the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers' investment strategies, past performance, and risk results in relation to its clients' individual portfolio allocations and risk exposure. MFA also takes into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. MFA continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. MFA seeks to ensure the Independent Managers' strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. Schwab Donor-Advised Fund Advisory Services. MFA participates as an investment adviser in the Schwab Charitable program for donor-advised fund accounts aimed to assisted clients with their philanthropic goals. Schwab Charitable is an independent nonprofit organization. The donor-advised fund account program allows clients to contribute cash or securities to a charitable account to realize potential tax benefits the year of the contribution to the donor-advised fund, while supporting their selected charities. Following regulations regarding charitable contributions set forth in the Internal Revenue Code of 1986, as amended, Schwab Charitable requires that contributions become the sole property of Schwab Charitable. Thus, all contributions accepted by Schwab Charitable are both irrevocable and unconditional. Once contributions are accepted, they are not refundable and become assets owned and held by Schwab Charitable. Moreover, they are subject to the exclusive legal authority and control of Schwab Charitable as to their use and distribution. Clients with an account size of $250,000 or more may designate MFA to manage their donor-advised fund account contributions. MFA will facilitate the opening and investment management of the donor-advised fund account in accordance with Schwab Charitable Investment Policy Guidelines. MFA receives no other compensation or benefits from Schwab Charitable related to this arrangement. Please Note: MFA does not provide tax, legal or accounting advice. Before engaging in any charitable giving program, clients should review carefully the terms and conditions of the Schwab Charitable program that is accessible from Schwab and consult with their tax, legal, and accounting advisors regarding their individual situation.