Advance Capital Management Inc.

Advance Capital Management ADV Brochure One Towne Square, Suite 444 Southfield, MI 48076 800-345-4783 www.acadviser.com This brochure provides information about the qualifications and business practices of Advance Capital Management. If you have any questions about the contents of this brochure, please contact us at 1-800-345- 4783. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Advance Capital Management also is available on t h e SEC’s website at w ww. adviserinfo.sec.gov . The searchable IARD/CRD number for Advance Capital Management is 110767. The date of this Brochure: March 2026  Item 2: Summary of Material Changes to ADV Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. The following material changes have been made to this brochure since the annual updating amendment on March 12, 2025.  The firm added a new disclosure regarding disciplinary information. (Item 9)  The Adviser may delegate the management of all or part of the Account to one or more third- party managers subject to the supervision and direction of the Adviser, provided, however, that the Adviser shall remain responsible for providing the services described in this Agreement. (Items 4 & 5)  ACM has updated this brochure to expand on its best execution obligation and economic benefits received from Charles Schwab. (Items 12 & 14)  Table of Contents Item 4: Advisory Business 4 Item 5: Fees and Compensation 6 Item 6: Performance-Based Fees and Side-By-Side Management 7 Item 7: Types of Clients 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 7 Item 9: Disciplinary Information 9 Item 10: Other Financial Industry Activities and Affiliations 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 10 Item 12: Brokerage Practices 11 Item 13: Review of Accounts 11 Item 14: Client Referrals and Other Compensation 11 Item 15: Custody 13 Item 16: Investment Discretion 13 Item 17: Voting Client Securities 13 Item 18: Financial Information 13 Business Continuity Plan 13 Customer Identification and Verification 14 Who to Contact 14 Privacy Policy 15  Item 4: Advisory Business Advance Capital Management, Inc. (“ACM”, “Management”, “we” or “us”) provides investment advice to many types of clients including individuals, investment advisers, investment companies, pension, profit sharing and other forms of retirement plans, trusts, estates, charitable organizations, and corporations. ACM was founded in 1986 and since that time have offered investment advisory and consulting services. We are owned by Advance Capital Group, Inc. (“ACG”). The principal owner (person who owns 25% or more) of ACG is the ACG Employee Stock Ownership Plan (“ESOP”). The remaining shares are owned by Raymond A. Rathka, and Christopher M. Kostiz. As of December 31, 2025, we managed a total of $ 4,980,840,651 in assets. This includes approximately $ 4,904,620,288 in assets managed on a discretionary basis, and approximately $ 76,220,363 managed on a non-discretionary basis. Advance Capital Management, Inc. is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Advance Capital Management, Inc. may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees. Individuals We specialize in financial planning. Financial planning involves providing individualized investment advice based upon each client’s needs and objectives. Discussions normally begin with an analysis of the client’s risk tolerance, income objectives and growth expectations. In most cases a detailed financial plan is created based on these objectives. The plan is used as the cornerstone from which we derive specific investment recommendations, projected asset growth, income projections, expected tax implications and other detailed financial information. Financial planning services are generally limited to advice and recommendations on those securities for which fees are charged, and recommended securities are generally limited to mutual funds and exchange traded funds (“ETFs”). In certain client specific circumstances, we may provide investment advice on a range of securities beyond mutual funds and ETFs. These securities may include exchange listed and over-the-counter securities, foreign issues, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities and U.S. Government securities, commodities, precious metals, public and private real estate, private debt and private lending vehicles, private equity funds, structured products, and crypto currencies and other digital assets. Clients may request restrictions on investing in certain securities or types of securities. We will review the feasibility of such restrictions and inform the client as appropriate. 4  Institutional Investment Consulting We act as investment advisers or sub-adviser to various institutional clients such as other financial services firms, banks, foundations, endowments, and pension funds. In this capacity, we offer our consulting services on a discretionary and non-discretionary basis based on the client’s investment policy statement and after general discussions with the client. Our services may include investment policy statement review and construction, asset allocation review, investment manager research and selection, portfolio construction, reporting, performance review, trading, and other ancillary services as agreed upon. Platform Advisory Services (Sub-Advisory Services): We offer our investment strategy and portfolio modeling services to other investment advisers on a sub- advisory basis. In these cases, we are contracted by the client for our investment management services and the use of our investment models and asset allocation strategies. We will also provide the necessary training on those strategies, quarterly updates, and limited sales support to promote the use of the strategies by advisers using the investment manager’s suite of services. Use of Independent Managers We may utilize or recommend that clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a client’s investment portfolio, based on the client’s needs and objectives. The Independent Manager is designated as a sub- adviser to such clients’ accounts, and provides advisory, asset allocation, and administrative services to clients through our oversight and supervision. Both ACM and the Independent Manager share responsibility for rendering advisory and administrative services. In most cases, we will have the authority to hire or terminate an Independent Manager’s relationship without specific client consent. We will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with the client’s investment objectives and overall best interests. We will also assist the client in the development of the initial policy recommendations and managing the ongoing client relationship. When selecting an Independent Manager, we will generally recommend GeoWealth Management, LLC (“GeoWealth”). Clients will be provided with the Independent Manager's Form ADV Part 2A Brochure at the inception of service. This document provides important disclosures about GeoWealth’s services, portfolio models, fees, conflicts of interest, disciplinary history (if any), and other important information that would help clients understand the scope of sub-advisory services provided by GeoWealth. We have also contracted with GeoWealth to provide technology platform services which include trade execution, reporting, fee-debiting and other back-office support services. We compensate GeoWealth for its platform services based on our assets under management. Retirement Plans We provide a full set of consulting and investment advisory services to retirement plan sponsors, whose plans are typically subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The specific services we provide to a plan sponsor and its plan participants may vary and are governed by the specific terms and conditions of the Retirement Plan Investment Advisory Agreement (“Plan Agreement”) we execute with each plan sponsor. IRA-based retirement plans (SEP IRAs, SIMPLE IRAs, etc.) are supported through our individual service platform. Our core advice service is designed to assist the plan sponsor with their fiduciary responsibilities and to give their employees substantial opportunities to save for retirement. Based on fi360's "Prudent Practices for Investment Advisors" handbook (www.fi360.com), our advice covers: investment safe harbors,  the investment line-up,  plan design and provisions, including automatic enrollment, escalation, etc.,  the Investment Policy Statement (IPS),  the Qualified Default Investment Alternative (QDIA),   plan cost analysis and benchmarking,  plan administration guidance,  employee enrollment and education (within the meaning of the U.S. Department of Labor guidance in Interpretive Bulletin 96-1), and  Third-party vendor review and coordination (recordkeeper, TPA, etc.). Investment lineup services involve the selection, monitoring, removal, and or replacement of investment options under the plan in accordance with the governing written investment objectives. Advance Capital 5  Management conducts these services as a fiduciary and either as a discretionary 'investment manager" under ERISA 3(38) or as a non-discretionary "investment consultant" under ERISA 3(21), per the arrangement agreed to by the plan sponsor and set forth in the Plan Agreement. Our "Chief Retirement Officer" service is an enhanced offering geared towards improving the retirement plan effectiveness and employees' overall financial wellness. Through results-based strategies designed to encourage employee engagement and to monitor overall retirement readiness, we work with the plan sponsor and individually with plan participants to attain their specific goals and objectives. Item 5: Fees and Compensation Individuals Clients pay for our investment advisory services by paying us a fee based on the amount of assets under management. Our Annual Fee Schedule is generally: 1.0% of the first $500,000, 0.8% of the next $500,000, 0.65% for any remaining amount over $1,000,000. Households ("HH") under $200,000 are subject to an additional service fee as follows: $40 between $1,000 - $10,000 in HH assets, $50 between $10,000 - $50,000 in HH assets, or $100 between $50,000 - $200,000 in HH assets. We may also, in our discretion, negotiate fees based upon certain additional factors. Fees are separately billed at the end of each month based on the fair market value of the assets held in the client’s account(s) on the last day of the month that are managed by us. Fees are deducted directly from the client’s account(s) monthly through the custodian that holds the client’s assets. No fees are collected in advance of service. In addition to our fee, each client is responsible for paying any transaction costs associated with purchasing and selling securities, including mutual funds, as part of the fee-based service. Please see the section titled “Item 12: Brokerage Practices” for more information on the firm’s brokerage practices. When clients invest a portion of their portfolio in mutual funds or ETFs there will be a layering of management fees. This occurs because assets invested in mutual funds are also subject to various other fees and expenses that are described in the mutual fund’s prospectus. These fees and expenses are paid by the mutual fund but are ultimately borne by clients as shareholders of the mutual fund. These fees and expenses include investment advisory, administration, distribution, transfer agent, custodial, legal, audit and other customary fees and expenses related to mutual funds. Institutional Institutional clients and other investment advisers utilizing our model portfolios for their clients through intermediaries or custodian platforms pay a fee of 0.25% of assets under management. All other platforms will be charged according to the services offered through that platform and will typically range between 0.25% and 0.40%. We may also, at our discretion, negotiate fees based upon certain additional factors which could include a flat fee. For institutional clients and other investment advisers, our advisory fee is billed on a quarterly or annual basis, as specified in your Investment Advisory Agreement. Advisory fees may be deducted directly from your account, or in some circumstances billed directly for such fees. In addition to our fee, each client is responsible for paying any transaction costs associated with purchasing and selling securities as part of the fee-based service. Use of Independent Managers As noted in Item 4, we may implement all or a portion of a client’s investment portfolio utilizing one or more Independent Managers. In these arrangements, we will be compensated via a fee share from the advisors to which we direct those clients. This creates a conflict of interest in that we have an incentive to direct clients to the Independent Managers that provide us with a larger fee split. We will always act in the best interests of the client, including when determining which Independent Manager to recommend to clients. For client accounts implemented through an Independent Manager, the client’s overall fees will include our investment advisory fee plus investment advisory fees charged by the Independent Manager. The Independent Manager will assume responsibility for calculating the client’s fees and deduct all fees from the client’s account. 6  Retirement Plans For management of a company’s retirement plan a minimum annual fee of $1,500 will be applied. Fiduciary Investment Management Fee Schedule: The fees under the Agreement are payable at an annual rate based as a percentage of the market value of the Plan’s total assets, in accordance with the following progressive schedule: Plan Assets Annual Fee First $2,000,000 0.50% Next $3,000,000 0.30% Assets over $5,000,000 0.10% Chief Retirement Officer Employee Program Schedule (optional and additional): Plan Assets Annual Fee All Assets 0.05% We may also, in our discretion, negotiate fees based upon certain additional factors which could include a different schedule or a flat fee. All fees are either paid directly by the plan sponsor, charged directly to the participants through the plan’s record-keeper or deducted directly from the client's account through the custodian that holds the client's assets. All fees are payable quarterly in arrears based on the market value of the Plan’s total assets on the last business day of the previous quarter. The fees for any quarter will be payable as of the beginning of the month immediately following t h e p r i o r quarter end. The advisor will prorate fees for the Plan b a s e d o n t h e d a t e the Account is initiated or terminated during a calendar quarter. Unless indicated, flat fees are subject to an annual inflation adjustment. The fees above reflect our only compensation and do not include any third-party brokerage commissions, transaction fees, and other related costs and expenses incurred in connection with providing investment management services to the Plan. Mutual funds and ETFs also charge internal management fees, which are disclosed in the fund’s prospectus. Such charges, fees and commissions are in addition to the annual investment management fee. Item 6: Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees. Item 7: Types of Clients We provide investment advice to individuals, investment advisers, investment companies, pension, profit sharing and other forms of retirement plans, trusts, estates, charitable organizations, and corporations. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Individual accounts are actively managed under an investment advisory agreement that grants ACM discretionary authority. Institutional and Retirement Plan accounts may be served on a discretionary or non-discretionary basis, designated in our Agreement. Most investment recommendations consist primarily of mutual funds and ETFs on our list of recommended funds. We may also utilize alternative investments to enhance diversification. Our Investment Committee screens virtually all open-end mutual funds and ETFs with respect to such criteria as Morningstar (or other applicable rating agencies) fund ratings, risk- adjusted performance, fund size, manager tenure and availability of the fund to new investors. Once these funds have been identified, further fundamental analysis narrows the list of funds into a select group of funds known as the Recommended List. From this list, we build model portfolios based upon a client’s risk tolerances, investment objectives, investment time horizon, income needs and tax circumstances. The Recommended list and subsequent portfolios are reviewed quarterly for appropriateness by our investment committee. Custom portfolios may be constructed as customer circumstances and strategies require differing approaches to investing such as those required by high net worth individuals or “qualified investors”. We 7  may also use other securities such as individual stocks, corporate bonds, municipal bonds, U.S. government and agency securities, certificates of deposit and other securities that are added to our Recommended List as client needs or circumstances may dictate. Investments are held in portfolios until it is determined that the strategy of the portfolio may be adversely affected by continuing to hold the security or other opportunities are identified which may better accomplish the goals of the portfolio. Asset classes and allocations of the portfolio may be shifted to take advantage of market opportunities or to take defensive positions against loss of principal. Clients should be aware that investing in securities involves the risk of loss that they should be prepared to bear. Investments are not FDIC insured against loss and principal values at the time of redemption will fluctuate and may be worth more or less than original investments. Diversification cannot eliminate all risks associated with investing, even when diversified pooled investment vehicles such as mutual funds and ETFs are used. Mutual funds and ETFs are primarily exposed to market risk, which cannot be reduced through diversification. Following are some of the risks associated with our investment approach: Mutual Funds – The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. ETFs – The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Alternative Asset Classes – Alternative investments are long-term in nature, often illiquid, subject to lockup periods, capital calls, and other terms that may limit or severely restrict redemption, control and marketability and be subject to management fees that are more than fees for Traditional Assets. Alternative investments can be subject to greater volatility and risk of loss than traditional securities. Private securities such as debt, equity or real estate are also subject to pricing risk due to its illiquidity and lack of publicly available pricing. Structured Products have the risk of loss due to market conditions, as well as counterparty risk of loss if the issuing firm has financial difficulties, they also have liquidity risk since they typically can only be sold back to the issuing firm. We may also utilize limited liquidity vehicles such as interval funds which only allow quarterly distributions of a limited amount that may force the investor to wait a long period of time for the return of their investment. Fixed Income – Investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This includes corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general the fixed income market is volatile, and fixed income securities carry significant interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting, but these bonds still carry a risk of losing share price value. Risks of investing in foreign fixed income securities also include the general risks inherent in non-U.S. investing. Annuities – These retirement products are for those who may have the ability to pay a premium now and want to guarantee they receive certain payments or a return on investment in the future. Annuities are contracts issued by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Direct Indexing – Advance Capital will sometimes recommend certain Independent Managers who employ direct indexing investment strategies that seek to enhance after-tax performance of a specific benchmark, which may be unable to harvest losses due to various factors. Market conditions may limit the ability to generate tax losses. A tax loss realized by a U.S. investor after selling a security will be negated if the investor purchases the security within thirty days. Although the manager attempts to avoid “wash sales” and temporarily restricts securities it has sold at a loss to prevent wash sales, a wash sale can occur inadvertently because of trading by a client in portfolios not managed by the manager, in other accounts managed by Advance Capital, or within other direct indexed accounts. 8  Direct indexed mandates of non-liquid securities (e.g., small cap U.S. equities, distressed companies, ADRs) can carry significant bid-ask spreads that detract from pre-tax performance. Direct Indexing performance can meaningfully deviate from the performance of the benchmark the strategy attempts to replicate. Cryptocurrency – Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not backed by real assets or tangible securities and are more volatile than traditional currencies and financial assets. Digital currency is a digital representation of value that functions as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender status. Digital currency is not backed or supported by any government or central bank. Digital currency’s price is completely derived by market forces of supply and demand, traded between consenting parties with no broker and tracked on digital ledgers commonly known as blockchains. Investing in digital currency comes with significant risk of loss that a client should be prepared to bear and, due to the nature of cryptocurrencies, clients are exposed to the risks normally associated with investing but also unique risks not typical of investing in traditional securities. These include, but are not limited to, volatile market price swings or flash crashes, market manipulation, economic, regulatory, technical, and cybersecurity risks. Please also see below for additional description/properties: • Unregulated – Digital currency markets and exchanges are not regulated with the same controls or customer protections available in fixed income, equity, option, futures, or foreign exchange investing. • Increased Price Volatility – The price of cryptocurrency is constantly fluctuating. Trades or balances can surge or drop suddenly. These fluctuations mean that the price can drop to zero. • Susceptible to Error/Hacking – Technical glitches, human error and hacking can occur, which typically do not affect traditional securities to the same extent. • Forks – This implies a splitting of the chain on which the cryptocurrency runs, which makes it go in a different direction, with different rules than the existing blockchain. • Soft Fork – only a protocol change; the cryptocurrency continues to work on the original blockchain rules. • Hard Fork – a permanent divergence in the blockchain. Cryptocurrency ETFs – For certain clients, Advance Capital may recommend ETFs that track the price performance of one or more cryptocurrencies by investing in a portfolio linked to their instruments. Crypto ETFs can track the value of cryptocurrencies by investing in futures contracts for digital currency, or by investing in digital currencies directly. Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not backed by real assets or tangible securities and are more volatile than traditional currencies and financial assets. In general, investing in instruments the value of which are derived from or based on crypto assets, is highly speculative and subject to numerous risks. Risks associated with Crypto ETFs include but are not limited to; the cost to own these ETFs may be more than owning the actual crypto (but may eliminate the risk of investors being hacked or losing passwords or private keys needed to access their investment when it is stored in a secure bitcoin wallet), the risk of the individual ETF fund company failure, (which would require liquidation of the fund and the costs associated with the failure of the company), risk of underlying assets being blocked by regulatory authorities, reinvestment risk, high transaction costs and limited historical data. Additionally, Crypto ETFs may have no earnings, dividends, or interest payments generated by underlying holdings. operational and management costs may decrease the value of the ETF. Expense ratios should be considered and understood as presented in the ETF Prospectus. Due to the above risk factors along with other associated risks, we have assessed that the value oft risk at any given time is always 100% downside, therefore, we must limit total exposure along with carefully considering the risks and needs of each individual investor. Item 9: Disciplinary Information On April 7, 2025, the Securities and Exchange Commission (“SEC”) agreed to accept ACM’s Offer of Settlement and entered an Order Instituting Proceedings (“OIP”) making findings which ACM neither admitted nor denied. In particular, the SEC found that ACM, in its former capacity as a registered investment adviser to the registered investment company Advance Capital I, Inc. (the “Fund”), caused the Fund to file with the SEC a materially false and misleading Form N-8F in March 2017 when the Fund was de-registered, in violation of Section 34(b) of the Investment Company Act of 1940. Specifically, the SEC found that ACM caused the Fund’s failure to disclose as undistributed assets certain pending and unresolved class action litigation settlement claims held by the Fund. To resolve the matter, ACM agreed to cease and desist from further violations of Section 34(b), and pay a civil monetary penalty of $200,000, disgorgement of $300,000, and prejudgment interest of $99,953 into a fair fund for distribution to certain former Fund shareholders as of the date of the decision of the Fund’s Board of Trustees to liquidate the Fund. ACM has engaged the services of a distribution agent to develop a plan subject to SEC approval in order to distribute the funds to those former shareholders. 9  Outside of the above-referenced settlement with the SEC on April 7, 2025, neither our firm nor any of our management personnel have been involved in any legal or disciplinary proceedings during the past 10 years that is material to a client (or a prospective client) evaluation of our advisory business or the integrity of our management. Specifically, there have been no other administrative proceedings before the SEC or any other foreign, federal, or state regulatory agency, and there have been no proceedings by a self-regulatory organization involving our firm or any of our management persons. Item 10: Other Financial Industry Activities and Affiliations We are not registered as a broker-dealer, and none of our management persons are registered representatives of a broker-dealer. Neither our firm nor any of our management are registered as (or associated with) a futures commissions merchant, commodity pool operator, or a commodity trading advisor. As noted in Item 4, we may implement all or a portion of a client’s investment portfolio with one or more Independent Managers. We will be compensated via a fee share from the advisors to which we direct those clients. This relationship will be disclosed in each contract between us and each Independent Manager. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that we have an incentive to direct clients to the Independent Managers that provide us with a larger fee split. We will always act in the best interests of the client, including when determining which Independent Manager to recommend to clients. We do not receive any compensation directly from Independent Managers in exchange for the utilization of sub-advisory services, but GeoWealth does offer services and benefits that are intended to directly benefit us, clients, or both. Such services include model portfolio creation and management, client billing, performance reporting, delivering market commentary, and custodial interfacing. GeoWealth also provides us with a technology platform and trade execution services. The availability of such services from an Independent Manager creates a conflict of interest to the extent we may be motivated to retain one Independent Manager or GeoWealth as opposed to an alternative Independent Manager (or one at all). We address this conflict of interest by performing appropriate due diligence on each Independent Manager to confirm its services are in the best interests of clients, periodically evaluating alternatives, and evaluating the merit of each Independent Manager without consideration for the benefits received by ACM. Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading We have adopted a Code of Ethics that complies with SEC Rule 204A-1. Our Code of Ethics governs the personal securities trading activities of our “supervised persons”, which include any owner, manager, employee, or other person who provides investment advice on our behalf and who is subject to supervision and control by us. The Code recognizes that all supervised persons owe a fiduciary duty to our clients, including a duty to conduct their personal securities transactions in a manner that does not interfere with the transactions of a client or otherwise take unfair advantage of the relationship with a client. The Code contains specific principles of conduct, prohibits certain types of securities trading activities by a supervised person, and requires “Access Persons” to file an initial holding report with our Chief Compliance Officer as well as quarterly transactions reports showing all personal trades made during each quarter or to provide copies of brokerage trade confirmations and monthly brokerage statements to the compliance department. A copy of our Code of Ethics will be provided without charge to any client who requests it by calling 800-345-4783 or by writing to the Chief Compliance Officer at One Towne Square, Suite 444, Southfield, MI 48076. We do not act as a principal in any transactions. In addition, we do not act as the general partner of a fund or advise an investment company. We do not have a material interest in any securities traded in client accounts. We allow supervised persons to purchase or sell the same securities that may be recommended to and purchased on behalf of clients. Owning the same securities that are recommended to clients presents a conflict of interest that, as fiduciaries, must be disclosed to clients and mitigated through policies and procedures. As noted above, we have adopted the Code to address and mitigate any potential conflicts that may arise. While we allow supervised persons to purchase or sell the same securities that may be recommended to and purchased on behalf of clients, such trades are typically aggregated with client orders or traded afterward. At no time will we, or any supervised person, transact in any security to the detriment of any client. Item 12: Brokerage Practices 10  Client assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. We generally require that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker- dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. While we generally require that clients use Schwab as custodian/broker, clients will decide whether to do so and will open an account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). We have a duty to seek “best execution” for client transactions, which is the obligation to seek to execute securities transactions for a client on terms that are the most favorable to the client under the circumstances. For best execution, the determining factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution. Therefore, we consider the full range and quality of a broker-dealer's services, including execution capability, commission rates, and the value of any research, economic responsibility, and responsiveness, among other things. Research and Other Soft Dollar Benefits: We do not have any soft dollar arrangements. Brokerage for Client Referrals: We do not receive client referrals from brokers. Directed Brokerage: We will use Schwab for custody and brokerage services for accounts that are fee based. With the use of Schwab for brokerage executions, we generally will not accept other directed brokerage requests from clients and cannot guarantee best execution in securities transactions beyond what can be obtained through Schwab. We may accept custody and brokerage services at our discretion in cases where client circumstances warrant acceptance and scenarios that are advantageous to us. Not all investment advisers require clients’ direct execution in securities transactions through one broker. Schwab generally does not charge clients separately for custody services but is compensated by charging clients commissions or other fees on trades that it executes or that settle into client Schwab account. Schwab is also compensated by earning interest on the uninvested cash in client accounts in Schwab's Cash Features Program. In addition to commissions, Schwab charges clients a fee for "prime broker" or "trade away" services for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a client’s Schwab account. These fees are in addition to the commissions or other compensation clients pay the executing broker-dealer. From time to time, we may be in the position of buying or selling the same security for several clients at approximately the same time. Because of market fluctuations, the prices obtained on such transactions on a single day may vary substantially. In such situations, some clients will receive prices more favorable than other clients. To more equitably allocate the effects of such market fluctuations, we may use an averaging procedure for certain transactions, under which purchases, or sales of a particular security will be combined (“batched”) for all accounts trading in the same security on the same day. In such cases, the prices shown on confirmation reports for these purchases or sales will be the average execution price for the batch. In certain situations, batched orders entered may not be completely filled, and in such event we will pro-rate the completed portion of the order to ensure that all clients participating in the batched order will receive an allocated portion of the completed transaction. Item 13: Review of Accounts Each individual account is generally reviewed annually, at a minimum, by the client’s financial adviser. Institutional accounts are generally reviewed and discussed with the client each quarter. Regular written reports are prepared on a quarterly basis for most advisory clients. Written reports contain the following information concerning the client’s portfolio: asset classes and allocations, portfolio holdings and market values, account activity summary and performance. Each quarter the Investment Committee reviews model portfolios and all securities on the Recommended List for appropriateness, however, no written report is sent to the client. Clients receive monthly or quarterly statements from the custodian containing account activity and balances. All retirement plan investment options undergo a due diligence review by our Investment Committee every quarter. Each plan sponsor is provided with regular due diligence reports of their specific plan lineup and a comprehensive plan review at least annually with their adviser. Clients may receive additional reviews if prudent based on complexity and additional factors. Item 14: Client Referrals and Other Compensation Client Referrals - We may directly compensate employees for client referrals. Clients do not pay additional advisory fees or expenses because of our existing referral arrangements, and referral fees paid to an employee are contingent upon clients entering into an advisory agreement with ACM. An employee, therefore, has a financial incentive to recommend our firm for advisory services. Although this conflict of interest exists, clients are not obligated to retain our firm for advisory services. 11  We also participate in the Ramsey Solutions Smartvestor Pro program. In the program Advance Capital Management pays a monthly fee to Ramsey Solutions who provide the names of Smartvestor Pro participants when requested by visitors to the Ramsey Solutions website. The referral is based on geography so Advance Capital Management cannot pay a higher rate to receive priority referral positioning. This creates a conflict of interest as ACM has an incentive to engage clients referred through these programs. Other Compensation - From time to time, we are provided with marketing and due diligence support by Fund companies. Typically, that support is in the form of funds used to defray costs associated with client dinner events and travel costs associated with certain investment due diligence trips. The client dinner events, and due diligence may be used to benefit and service all or a substantial number of our accounts, including accounts not holding any Fund company shares. Our receipt of this additional compensation does not diminish our duty to act in the best interests of our clients. Participation in Schwab Institutional Advisor Platform - Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. Schwab's support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Following is a more detailed description of Schwab's support services: Services that benefit clients. Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab's services described in this paragraph generally benefit clients and client accounts. Services that do not directly benefit clients. Schwab also makes available to us other products and services that benefit us but do not directly benefit clients or client accounts. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both Schwab's own and that of third parties. We use this research to service all or a substantial number of our clients' accounts. In addition to investment research, Schwab also makes available software and other technology that:  Provide access to client account data (such as duplicate trade confirmations and account statements)  Facilitate trade execution and allocate aggregated trade orders for multiple client accounts  Provide pricing and other market data  Facilitate payment of our fees from our clients' accounts  Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:  Educational conferences and events  Consulting on technology and business needs  Publications and conferences on practice management and business succession  Access to employee benefits providers, human capital consultants, and insurance providers  Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party's fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If clients did not maintain accounts with Schwab, we would be required to pay for those services from our own resources. Item 15: Custody We do not maintain custody of any client funds or securities, other than the ability to authorize the custodian to deduct advisory fees from client accounts, or in certain circumstances where we have authority to transfer money from client account(s), which is authorized in writing by the client via a standing letter of authorization (SLOA). Accordingly, we will follow the safeguards specified by the SEC and forego an annual audit. At least quarterly, the custodian will send statements to clients for each account. Clients should review these statements carefully as all activity in the account will be reflected on these 12  statements. Item 16: Investment Discretion In fee-based accounts, individual clients have signed investment advisory agreements giving ACM discretionary investment authority over the account. Discretion refers to the authority of the investment adviser to make purchase and sale decisions (including which securities to select and how much to buy or sell) in the client’s account. We will not make any trades within client accounts until we have entered into an investment advisory agreement with a client. Institutional accounts and Retirement Plans may be served on a discretionary or non-discretionary basis, as designated in our Agreement. Item 17: Voting Client Securities In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Investment Advisers Act, we have adopted and implemented written policies and procedures governing the voting of client securities. All proxies that we receive will be treated in accordance with these policies and procedures. We have engaged the services of Broadridge’s ProxyEdge platform to vote and maintain records of all proxies. The Broadridge open architecture platform allows us to choose from several different proxy advisory firms to make recommendations on how our firm should vote for the proxies. We have selected “Glass Lewis” as the current adviser, who considers the reputation, experience, and competence of a company’s management and board of directors when it evaluates an issuer. Our complete proxy voting policy, procedures, and those of its proxy voting service providers, are available for client review. In addition, our complete proxy voting record is available to our clients, and only to our clients. Clients should contact us at the phone number listed with questions or to review documents. Item 18: Financial Information We are not required to include in this brochure our balance sheet for the most recent fiscal year, because we do not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance. We are not aware of any financial condition that would impair our ability to meet our contractual commitments to our clients, and we have not been the subject of a bankruptcy petition at any time during the past 10 years. Business Continuity Plan The Advance Capital Companies (“Advance Capital”) have a Business Continuity Plan (“Plan”) in place which addresses how the firms will respond should there be a significant business disruption. Procedures are in place to safeguard employees’ lives and firm property, make financial and operational assessments, quickly recover and resume operations, protect books and records and allow customers to transact business. Advance Capital does not provide specific details of its Plan to maintain security. However, this Plan specifically addresses the ability of the firm to recover from various situations ranging from simple outages to major incidents and includes the following:  Alternative physical locations  Customer access to funds  Data back-up and recovery  Operational and financial assessments  Identification of mission-critical systems  Alternative communications with customers, employees, and regulatory agencies  Identification of critical business constituents and banks The Plan is reviewed as necessary, but no less frequently than annually, to ensure that it addresses any technological, business, and regulatory changes. 13  Customer Identification and Verification In addition to the information we must collect under the USA Patriot Act, we have established, documented, and maintained a written Customer Identification Program (“CIP”). Prior to opening an account, Advance Capital will collect certain minimum customer identification information; verify the identity of everyone who opens an account; record the customer identification information, verification methods and results; provide notice to customers that we will seek proper identification and compare that information with government-provided lists of individuals suspected of terrorist activity. Appropriate documents for verifying the identity of customers include, but are not limited to, the following: For an individual, an unexpired government-issued identification evidencing nationality, residence, and bearing a photograph or similar safeguard, such as a driver’s license or passport; and For a non-person, (i.e., Trust, Business, Foundation, etc.), documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument. Who to Contact Requests for information may be made via electronic mail on our website under the “Contact Us” heading at www.acadviser.com. 14  Rev. March 2026 FACTS WHAT DOES ADVANCE CAPITAL MANAGEMENT DO WITH YOUR PERSONAL INFORMATION? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. What? transaction history, account balances and account numbers The types of personal information we collect and share depend on the product or service you have with us. This information can include, but is not limited to: ■ Name, address and phone number[s] ■ Social security number and date of birth ■ ■ assets and income How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Advance Capital Management chooses to share; and whether you can limit this sharing. Does Advance Capital Reasons we can share your personal information Can you limit this sharing? Management share? YES NO For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus YES NO For our marketing purposes— to offer our products and services to you For joint marketing with other financial companies NO Not shared N/A Not shared For our affiliates’ everyday business purposes— information about your transactions and experiences For nonaffiliates to market to you NO Not shared ■ Call 800-345-4783 ■ Mail the form below To limit our sharing Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? Call 800-345-4783 or go to https://www.acadviser.com/ Mark any/all you want to limit: □ Do not share information about my creditworthiness with your affiliates for their everyday business purposes. □ Do not allow your affiliates to use my personal information to market to me. □ Do not share my personal information with nonaffiliates to market their products and Mail-in Form If you have a joint account, your choice(s) will apply to everyone on your account unless you mark below. services to me. □ Apply my Name Address choices only to me City, State, Zip Mail to: Advance Capital Management One Towne Square, Suite 444 Southfield, MI 48076 15  Page 2 Who we are Who is providing this notice? Advance Capital Management, Inc. What we do How does Advance Capital Management protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We collect your personal information, for example, when you ■ When you share information on applications or other forms; and/or How does Advance Capital Management collect my personal information? ■ When you seek advice about your investments; and/or ■ When you enter into an investment advisory contract. Why can’t I limit all sharing? Federal law gives you the right to limit only ■ sharing for affiliates’ everyday business purposes—information about your creditworthiness ■ affiliates from using your information to market to you ■ sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. Your choices will apply to everyone on your account—unless you tell us otherwise. What happens when I limit sharing for an account I hold jointly with someone else? Definitions Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Other important information Advance Capital Management clients may be entitled to other privacy protections under applicable state laws. We will endeavor to comply with relevant state laws that apply to the protection, use and disclosure of information about you.  (800) 345-4783 Southfield, Michigan (800) 345-483 Ann Arbor, Michigan (800) 444-1053 Grand Rapids, Michigan (800) 345-4783 Saginaw, Michigan (800) 457-4304 Independence, Ohio (800) 345-4783 Traverse City, Michigan (800) 327-3770 Lisle, Illinois (800) 345-4783 Dallas, Texas