BERMAN MCALEER

Item 1. Cover Page Brochure Berman McAleer, LLC 9690 Deereco Road Suite 800 Timonium, Maryland 21093 Phone: (410)-560-9960 Website: http://www.bmcplanning.com Email: clientrelations@bmcplanning.com Date: January 26, 2026 This Part 2A of Form ADV (“Brochure”) provides you with information about the business practices, qualifications, and advisory services of Berman McAleer. Our firm is an investment adviser firm registered with the Securities and Exchange Commission. Registration does not imply a certain level of skill or training, only that we have filed registration documents in the appropriate jurisdictions and with the respective governmental entities. 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 Berman McAleer can be found on the Investment Adviser Public Disclosure website at adviserinfo.sec.gov using our CRD identification number 332906. If you have any questions about the content of this brochure, please contact us at the telephone number or email address shown above. 1  Item 2. Material Changes The purpose of this Item 2 of Form ADV Part 2A is to highlight material changes in our business that are reflected in this updated Form ADV Part 2A. A change of ownership has occurred as of 1/1/2026 whereas Adam Murray has become an owner and Joseph McAleer’s ownership has decreased to below 25% controlling interest. Item 3. Table of Contents Item 1. Cover Page..................................................................................................................... 1 Item 2. Material Changes ........................................................................................................... 2 Item 3. Table of Contents ........................................................................................................... 2 Item 4. Advisory Services ........................................................................................................... 3 Item 5. Fees and Compensation ................................................................................................. 4 Item 6. Performance Based Fees and Side-By-Side Management ............................................... 6 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 ........................................................... 9 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 ...................................................................................................... 12 Item 14. Client Referrals and Other Compensation ..................................................................... 12 Item 15. Custody ......................................................................................................................... 13 Item 16. Investment Discretion .................................................................................................... 13 Item 17. Voting Client Securities ................................................................................................. 13 Item 18. Financial Information ..................................................................................................... 13 2  Item 4. Advisory Services Berman McAleer, LLC (“BMc” “We” “Our” or “Firm”) is a Maryland limited liability company which was founded in 2002. BMc registered as a Registered Investment Adviser in 2025. The Firm has nine members (owners), none of which owns twenty-five percent or more of the Firm. Executive officers include Mr. McAleer, who is the Firm’s Chief Personnel Officer, David L. Berman, who services as the Chief Executive Officer, and William F. Bruns, III, who is both the Chief Financial Officer and Chief Compliance Officer. BMc’s services center around a holistic financial planning approach for each client, followed by the management of a client’s investment assets through BMc’s specific investment approach. The introductory process for each new client begins with a planning process, as BMc believes that through the discovery phase of the planning process, a client’s advisor will gain information related to the client’s individual needs, current status and goals. Financial planning is performed on an individual basis, with each client receiving specific aspects of financial planning (retirement planning, education planning, insurance needs, investment analysis, and more). Accordingly, any written document produced for one client as part of the planning process will likely not be exactly the same as for another client. BMc believes its real value is the knowledge and judgment our advisors have gained from their respective years of experience. That judgment is utilized in inquiries to clients, the process by which a plan is created, and ultimately, implementation. The BMc process for planning is not to simply put data into a single software which produces a template plan. We provide advice after a thorough, human evaluation of each client’s needs, circumstances, and objectives. Once a financial planning objective is agreed upon, BMc begins work on transitioning the client’s investment assets to BMc through an account at a separate broker-dealer/custodian. The asset management process, which is discussed in more detail in Item 8 of this Brochure, is somewhat specific to each client, as each client’s needs differ. While BMc might not currently recommend a given asset class or security type, BMc’s professionals recognize that no security type or asset class is, in itself, “good” or “bad”, but rather each has a time and place for the right client circumstance. While BMc employs a systemized process to help each client meet their goals, clients are free to place reasonable restrictions on the management of their accounts and to make whatever deposits or withdrawals they wish at any time. Asset management services are performed on a discretionary basis. This means that BMc will make changes in client accounts without first contacting each client for permission. This enables the Firm and its professionals to work efficiently and quickly as circumstances require. BMc may allow a client to hold certain assets that are to be deemed non-discretionary or unmanaged, as a courtesy to that client. However, BMc does not accept clients that are, in their entirety, non-discretionary contracts. BMc participates in the Fidelity Charitable Investment Advisor Program and when suitable will recommend clients to open a Giving Account® through the Fidelity Charitable®. Fidelity Charitable is a sponsoring organization of donor-advised funds described in the Internal Revenue Code Section 4996(d)(2). When BMc is selected as the Advisor Firm for the Giving Account, BMc shall have discretion to supervise and direct the investment of the assets in the Giving Account but has no independent authority or ability to recommend grants from the Giving Account. The Giving Account has administrative fees, but BMc does not receive any of the administrative fees. Because BMc can recommend a client to open a Giving Account and collect an advisory fee as the Advisor Firm on the Giving Account, BMc has a conflict of interest in making the recommendation due to a financial incentive. 3  BMc does not participate in a wrap program. BMc offers fee based qualified retirement plan services that provide non-discretionary and discretionary investment fiduciary services to sponsors and trustees of qualified retirement plans. As an ERISA 3(38) investment manager, services are designed to allow the plan fiduciary to delegate responsibility for managing, acquiring, and disposing of plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974 (“ERISA”). If appointed as an ERISA 3(38) Investment Manager, BMc would have full discretionary authority to select, monitor, and remove the investment options offered in a qualified retirement plan. As of December 31, 2025, BMc manages $1,821,801,181 on a discretionary basis. Item 5. Fees and Compensation A. Fees and Compensation Asset Management Services Asset management fees are calculated and paid monthly in advance based on the total gross value of the assets under management for the Client as of the last day of the prior month as calculated in the portfolio administration system, including cash balances. The fees are calculated according to the following fee schedule: Assets Under Management Annual Fee $0-$2,500,000* 1.00% $2,500,001-$7,500,000 0.75% $7,500,001-$15,000,000 0.50% $15,000,001-$$25,000,000 0.30% $25,000,001 + 0.20% *A supplemental fee of 0.40% will be added for clients onboarded after January 1, 2025 with total assets under management less than our$1,500,000 minimum. This can be waived in the sole discretion of BMc. In determining the tiered annual fee percentage, the client’s total assets under management will be aggregated. Asset management fees are negotiable in the sole discretion of the Firm depending upon the complexity of the client’s financial situation and the scope of services rendered. Please note these fees have “tiers,” meaning that if your assets exceed the maximum of the first tier, your overall fee will be a blended percentage rate that is the result of being charged the corresponding fee for the first level of assets, plus the different corresponding fee for the next level of assets, and so on. Third party manager fees, if applicable in the management of Client assets, are in addition to the asset management fee charged by BMc. 529 plans and Fidelity Charitable asset accounts are charged 0.50% annually for an asset management fee regardless of the size of the account(s) or other portfolio assets. 4  BMc has an alternative tiered fee schedule with a starting point of 1.22% that was applied to legacy clients upon the formation of BMc as an independent registered investment advisor in 2024 in circumstances where it was in the best interest of the legacy client and was agreed upon between the legacy client and BMc. Asset values provided by BMc’s portfolio administration software, for purposes of calculating fees, may vary in comparison to the custodian statement value. This is due to the reporting timing methods used by BMc’s portfolio administration system and the custodian when trades or transactions, such as dividends or accrued interest payments, are made at the end of the month. BMc uses the value reported in the portfolio administration system for fee calculation. Financial Planning Services BMc charges new clients a flat fee for initial financial planning and/or consulting services, ranging from $3,500 to $15,000. Our planning fees are negotiable based on the scope and complexity of the engagement with the client. After the initial financial planning process, we do not charge additional flat fees for planning. BMc prefers to enter into long-term, holistic relationships with clients, in which its financial planning services are part of its overall engagement for investment management services. If a client engages BMc for financial planning services outside the normal scope, the services will be provided on an hourly basis ranging from $450 to $700 per hour. Retirement Plan Consulting Services BMc charges either a flat annual advisory fee for ERISA retirement plan consulting services, not to exceed 1.25% of the total plan assets placed under our advisement, or a tiered annual advisory fee. The exact fee amount and method of payment will be specified in the Retirement Plan Consulting Agreement. Fees are negotiable in the sole discretion of BMC based on the complexity of the retirement plan and services provided. Fees are calculated and billed monthly in advance based on the value of the plan assets the last day of the prior month as per the following: Assets Under Management Annual Fee $0-$2,500,000* 1.00% $2,500,000-$7,500,000 0.75% $7,500,000-$15,000,000 0.50% $15,000,000-$$25,000,000 0.30% $25,000,000 + 0.20% *A supplemental fee of 0.40% will be added for clients onboarded after January 1, 2025 with total assets under management less than our $1,500,000 minimum. This can be waived in the sole discretion of BMc. Please note this fee has “tiers,” meaning that if your assets exceed the maximum of the first tier, your overall fee will be a blended percentage rate that is the result of being charged the corresponding fee for the first level of assets, plus the different corresponding fee for the next level of assets, and so on. In determining the tiered annual fee percentage, the client’s total assets under management will be aggregated. For purposes of this section, “total assets” are defined to include plan assets under the Retirement Plan Consulting Agreement and any other separate assets the plan sponsor has under management with BMc pursuant to a separate Investment Advisory Agreement. Upon termination of 5  a Retirement Plan Consulting Agreement, the accounts will be refunded on a pro-rata basis for the number of days left in the month. B. Fee Payment As authorized in your Investment Advisory Agreement, the Firm will instruct the qualified custodian (the “Custodian”) to deduct advisory fees directly from your account(s). The Custodian may charge separate fees (for example, account or transaction fees), set and collected by the Custodian, and BMc does not receive any portion of them. The Custodian provides its current fee schedule, which clients should review. For more information about our brokerage practices, see Item 12. The Custodian will deliver account statements at least quarterly, directly to the client, showing all holdings, values, pricing, and all additions and withdrawals. Clients should review these statements carefully for accuracy. Each client’s advisory fee is stated in the client’s advisory agreement and applies to the assets in the portfolio or household (as defined in that agreement). In some cases, specific assets may be excluded from the fee calculation or billed at a reduced rate—for example, certain cash positions or securities held solely at the client’s request that BMc does not manage. Financial Planning Services BMc invoices clients for financial planning services where the client may pay for the services by check or credit card. If BMc determines the financial planning fee will be incorporated into the asset management fee, this will be disclosed to the client in the financial planning agreement. Retirement Plan Consulting Services Fees for retirement plan consulting services are paid by the Client in accordance with the retirement plan consulting agreement. C. Compensation for Sale of Securities or Other Investment Products Our Firm and representatives do not sell securities for a commission. There are a number of other expenses charged by the custodian that can be associated with holding and investing in securities. The Client will be responsible for any expenses such as transaction fees, none of which are paid to BMc.. Expenses of a fund will not be included in management fees, as they are deducted from the value of the shares by the mutual fund or ETF manager. For complete discussion of expenses related to each mutual fund or ETF, you should read a copy of the prospectus issued by that fund. BMc will provide or direct you to a copy of the prospectus for any fund that it recommends to you. Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial issues. Item 6. Performance Based Fees and Side-By-Side Management BMc does not accept performance-based fees, nor does it engage in side-by-side management. Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Side-by-side management occurs when advisers manage both accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee or 6  an asset-based fee. Item 7. Types of Clients BMc provides investment advisory services to individuals, high net worth individuals, business entities, trusts, and estates. The minimum relationship opening balance is $1,500,000, which may be negotiable at the discretion of the Firm. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss Investing in securities involves risk of loss, including loss of principal, that clients should be prepared to bear. The universe of available investments is almost infinite. We distill that universe into client portfolios through various methods of analysis. For example, we use “fundamental analysis” and “quantitative analysis” along with our other general research and experience. We believe that these methods, combined with our overall experience and evaluation of a client’s needs, helps us make the best decisions we can for our clients. There are two prongs to our investment approach: Our Investment Committee, which determines the securities it believes should be included in each asset allocation segment, and each individual financial advisor, who determines an appropriate allocation for each client from among the three segments produced by the investment department. Investment Committee The Investment Committee has created three “segments”: Equity, fixed income, and alternatives. The equity sleeve, labeled as Long-Term, is intended to reflect exposure to the broad equity markets, both public and private, including both U.S. and international securities. Most typically, these securities will be in the form of ETFs and mutual funds, but could be specific equities. The fixed income sleeve, labeled Short-Term, is intended to be an exposure to the fixed income (bond) and money markets. Securities included in this segment can include ETFs, mutual funds, or any other security BMc’s Investment Committee believes will behave as a fixed income security would be expected to behave. The alternative segment, labeled Intermediate, is comprised of securities that could come from any sector or security type not covered in the equity or fixed income segments, including interval funds (for exposure to private equity funds), cryptocurrency ETFs, traded real estate funds, and more. The alternatives segment is intended to add a tactical or flexible element to the portfolio.. The Investment Committee will make changes to the position sizing of each segment on an as needed basis, which may mean some securities may be held for shorter or longer time periods. Each client’s financial advisor(s) will identify a specific asset allocation based on that client’s needs as determined during the planning process. The advisors do not trade client accounts directly. Instead, they will change the asset allocation and the investment team will make appropriate trades to adjust the client’s portfolio to the new asset allocation. Advisors work with clients directly in order to remain informed about changes in the client’s financial circumstances, as well as to assist the client in making sound financial decisions based on their financial circumstances. It is therefore important for clients to respond to contacts and otherwise keep their BMc advisor aware of any changes to their financial circumstances, however minor. 7  Risk of Loss • Concentration Risk. To the extent a portfolio is concentrated in assets related to a particular industry or geographic region, the portfolio will be subject to additional volatility risks associated with such industry or region. In addition, concentrating in a single industry or group of industries may be more susceptible to any single economic, market, political or regulatory occurrence affecting that industry or group of industries. • Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Interest Rate Risk. Movements in interest rates may directly cause prices of fixed income and other securities to fluctuate. These changes can be unpredictable and may cause the loss of principal that would be otherwise unexpected. • Credit Risk. If debt obligations held by an account are downgraded by ratings agencies or go into default, or if management action, legislation or other government action reduces the ability of issuers to pay principal and interest when due, the value of those obligations may decline, and an account’s value may be reduced. Because the ability of an issuer of a lower- rated or unrated obligation (including particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain than for an issuer of a higher-rated obligation, lower rated and unrated obligations are generally more vulnerable than higher- rated obligations to default, to ratings downgrades, and to liquidity risk. • Purchasing Power Risk. Purchasing power risk is the risk that an investment’s value will fail to keep pace with the price of goods and services (inflation). The investment’s value itself does not necessarily decline, but its relative value does. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Some securities are highly liquid while others are highly illiquid. Illiquid investments carry more risk because it can be difficult to sell them. Liquid investments can become less liquid during times of market stress or factors related to the specific security. Political Risk. Most investments have a global component, even domestic stocks. Political • events anywhere in the world may have unforeseen consequences to markets around the world. Risks Related to Investment Term. If the client requires a liquidation of their portfolio during a • period in which the price of the security is low, the client will not realize as much value as they would have had the investment had the opportunity to regain its value, as investments frequently do, or had it been able to be reinvested in another security. • Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Independent Manager Risk. As stated above, the Firm may select certain Independent Managers to manage a portion of its clients’ assets. In these situations, we continue to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, we do not have the ability to supervise the Independent Managers on a day-to-day basis. Finally, In certain instances, the agreement between the Firm and Independent Managers may limit the Independent Manager’s liability with respect to advice provided to the client’s account or otherwise limit the client’s 8  rights. • Cryptocurrencies and Digital Assets: Cryptocurrencies are digital currencies using decentralized control meaning they are not controlled by any one person or government. All Cryptocurrency investments (direct holdings as well as through fund structures) come with exposure to risks such as cybersecurity, regulatory and governmental risk, extreme price volatility, tax implications, transactional or ownership complications, and exposure to illegal activities such as fraud and money laundering. Item 9. Disciplinary Information BMc is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of our advisory business or the integrity of our management. Neither our Firm nor our management have any required disclosures to report in response to this Item. Item 10. Other Financial Industry Activities and Affiliations A. Broker-dealer None of the principals of BMc, BMc itself, or any of its associated persons are registered, or have an application pending to register, as a broker dealer or as an associated person of a broker-dealer. B. Futures Commission Merchant/Commodity Trading Advisor None of the principals of BMc, BMc itself, or any of its associated persons are registered, or have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons Neither the principals of BMc, nor any related persons have relationships or arrangements to disclose. D. Recommendations of Other Advisers BMc may recommend the use of an independent third-party manager if it is deemed in the best interests of the client. BMc will not recommend any third-party manager in exchange for any sort of referral fee or revenue sharing, and third-party manager fees are deducted from accounts by the third-party manager. Licensed Insurance Brokers Certain professionals of BMc are separately licensed as independent insurance brokers. As such, these professionals may conduct insurance product transactions for BMc clients, in their capacity as licensed insurance agents, and the company will receive customary commissions for these transactions. Commissions from the sale of insurance products will not be used to offset advisory fees. BMc’s professionals therefore have incentive to recommend insurance products, which presents a conflict of interest. BMc attempts to mitigate this conflict of interest by disclosing the conflict to clients and informing the clients that they are always free to purchase insurance products 9  through other agents that are not affiliated with BMc, or to determine not to purchase the insurance product at all. BMc also attempts to mitigate the conflict of interest by requiring employees to acknowledge their fiduciary duty to clients in the firm’s Code of Ethics, which requires that employees put the interests of clients ahead of their own or those of the firm. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, trading guidelines, and limits on political contributions, gifts, and entertainment. 401(k) Rollovers and Conflict of Interest By recommending that you rollover your Employer Plan assets to an IRA, BMc is recommending a change that would result in BMc earning an asset-based fee. In contrast, leaving assets in your Employer Plan or rolling the assets to a plan sponsored by a new employer likely results in little or no compensation to the firm. Therefore, we have an economic incentive to encourage investors to rollover Employer Plan assets into an IRA maintained at our firm. We mitigate this conflict of interest by explaining that clients are under no obligation to rollover Employer Plan assets to an IRA managed by BMc. BMc’s advice must be based on the investment objectives, risk tolerance, financial circumstances, and needs of the retirement investor. We do this by reviewing the options available to the investor and disclosing them on a rollover disclosure form. Our fiduciary duty obligates us to make recommendations exclusively in the best interests of our clients. Not applicable. BMc does not recommend to clients that they invest in any security in B. which BMc or any principal thereof has any financial interest. C. On occasion, an employee of BMc may purchase for his or her own account securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. On occasion, an employee of BMc may purchase for his or her own account securities D. which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. 10  Item 12. Brokerage Practices A. Selection and Recommendation BMc recommends that clients utilize the brokerage and clearing services of Fidelity Brokerage Services, LLC (“Fidelity”). Fidelity is a qualified Custodian. Factors which the Firm considers in recommending Fidelity or any other broker-dealer to clients include their respective financial strength, breadth of service, technology, existing relationships, execution, pricing, research, and resources available. Not all investment advisers recommend that a client use a particular broker- dealer. B. Research and Additional Benefits Although not a material consideration when determining whether to recommend a particular broker- dealer or custodian, BMc receives support services and products from Fidelity without cost or at a discount, some of which assists BMc to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by BMc may be investment-related research, pricing information, market data, software and other technology that provide access to client account data, compliance and/or practice management- related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings and other educational and/or social events, marketing support, computer hardware and /or software and /or other products used by BMc in furtherance of its investment advisory business operations. Berman McAleer’s clients do not pay more for investment transactions and/or assets maintained at Fidelity as a result of this agreement. There is no corresponding commitment made by BMc to Fidelity or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products. Fidelity Brokerage Services, LLC (“FBS”) has also agreed to provide Berman McAleer with financial assistance related to certain legal, accounting and vendor expenses directly related to the transition of our client accounts to their platform. This support, which could total up to $900,000, will be available during the first 24 months from the start of the Firms relationship with Fidelity. Upon initial conversion, FBS will reimburse up to $107,125 in account termination fees charged to clients by the former custodian. This reimbursement will be available during the first 12 months from the start of BMc’s relationship with Fidelity. The above represents a conflict of interest. BMc mitigates this conflict by conducting best execution reviews and ensuring each recommendation is in the best interest of the client. Additionally, receipt of lower custodial pricing benefits all of BMc’s clients who use Fidelity. BMc uses the services described above to benefit all of its clients. By agreement, Fidelity would charge BMc an additional platform fee of $2,500 per quarter if BMc’s assets held with Fidelity should ever fall below $25 million at the end of any calendar quarter. This fee may be waived at Fidelity’s discretion. This presents a conflict as BMc has an incentive to ensure at least $25 million in assets are held with Fidelity. BMc mitigates that conflict by conducting a best execution review of its relationship with Fidelity. 11  C. Brokerage for Client Referrals The Firm does not receive client referrals or compensation of any kind from broker-dealers or other third parties in exchange for using any particular broker-dealer. D. Directed Brokerage We routinely recommend that the client direct our Firm to execute transactions through broker- dealers with which we have a business relationship. As such, we may be unable to achieve the most favorable execution of the client’s transactions and the client may pay higher brokerage commissions than the client might otherwise pay through another broker-dealer that offers the same types of services. In limited circumstances, our Firm will permit clients to utilize their own broker-dealer. Our Firm may be unable to achieve the most favorable execution of client transactions when we allow clients to direct brokerage. Additionally, Client-directed brokerage transactions may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our Firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. E. Order Aggregation Transactions for each client account can be implemented in the aggregate or independently. BMc’s general process is to make changes to each segment as a group, which would mean that most trades would be aggregated trades. Aggregated trades are also known as “batching” or “blocking” trades. This process can ensure all participating clients receive the same price. In the past, “batching” orders would also lead to more favorable commission rates. However, at the present time, with many transactions being “transaction free” trades, this benefit is minimized. Further, our team can trade in client accounts on an as needed basis at any time during any given day. This means that a client could purchase a security at a different time from another client, and one of those clients could receive a different price, especially if a client requests a self- directed trade In all cases, BMc’s representatives will seek to obtain the best price available for the client at the time. Item 13. Review of Accounts BMc reviews accounts on an as-needed basis, but accounts are reviewed in detail on at least an annual basis. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. We attempt to understand anything that may have changed in our clients personal, professional, or financial situations. Item 14. Client Referrals and Other Compensation BMc does not receive compensation, directly or indirectly, from any third party for client referrals. BMc 12  does not compensate others for referrals. Item 15. Custody There are two avenues through which BMc has custody of client funds: By directly debiting its fees from client accounts pursuant to applicable agreements granting such right, and potentially by permitting clients to issue standing letters of authorization (“SLOAs”). SLOAs permit a client to issue one document that directs BMc to make distributions out of the client’s account(s). Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee. We encourage clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on your semi-annual report prepared by BMc against the information in the statements provided directly from Fidelity. Please alert us of any discrepancies. Item 16. Investment Discretion Clients provide BMc with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, BMc is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with BMc’s written acknowledgement. Item 17. Voting Client Securities BMc does not vote proxies on client securities on behalf of its clients. We may express an opinion for a specific proxy vote but clients are responsible for making elections relative to election of directors, mergers, acquisitions, tender offers, bankruptcy proceedings, and other type events pertaining to the securities in their accounts. Clients receive proxies directly from the issuer or the custodian. Item 18. Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. As an advisory firm that maintains discretionary authority for client accounts, we are also required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. Currently, there are no such financial conditions that exist. Berman McAleer has not been the subject of a bankruptcy petition at any time during the past ten years. 13