MCA ADV PART 2A

Item 1 – Cover Page Midwest Capital Advisors, LLC 688 Cascade West Parkway SE Grand Rapids, Michigan 49546 616.454.9600 www.midwestcap.com Date of Brochure: October 30, 2026 This Brochure provides information about the qualifications and business practices of Midwest Capital Advisors, LLC (“MCA,” “we,” or “us”). If you have any questions about the contents of or would like a copy of this Brochure, please contact us at 616.454.9600 or info@midwestcap.com. 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. We are a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information that will help you determine whether to hire or retain an adviser. Additional information about us is also available on the SEC’s website at www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with us who are registered, or are required to be registered, as investment adviser representatives. Our complete brochure is available free of charge by contacting our office at 616/454- 9600 or info@midwestcap.com.  Item 2 - Material Changes Pursuant to SEC rules, we will ensure that you receive a summary of any material changes to this and subsequent brochures within 120 days of the close of our business’s fiscal year. We may also provide other ongoing disclosure information about material changes as necessary. We will provide you our brochure, at any time, without charge. ii  Item 3 - Table of Contents Item 1 – Cover Page ............................................................................................................................................... i Item 2 - Material Changes .................................................................................................................................. ii Item 3 - Table of Contents ................................................................................................................................. iii Item 4 – Advisory Business ............................................................................................................................... 1 Item 5 – Fees and Compensation .................................................................................................................... 7 Item 6 – Performance-Based Fees and Side-by-Side Management ................................................ 10 Item 7 – Types of Clients ................................................................................................................................. 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 11 Item 9 – Disciplinary Information ............................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations ......................................................... 14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................................................................................................. 14 Item 12 – Brokerage Practices ...................................................................................................................... 15 Item 13 – Review of Accounts ....................................................................................................................... 17 Item 14 – Client Referrals and Other Compensation ........................................................................... 18 Item 15 – Custody .............................................................................................................................................. 18 Item 16 – Investment Discretion ................................................................................................................. 19 Item 17 – Voting Client Securities ............................................................................................................... 19 Item 18– Financial Information .................................................................................................................... 19 iii  Item 4 – Advisory Business Our Firm and Owners MCA is a Michigan limited liability company that was formed in 2003 and has been in business continuously since then. Our office is located at 688 Cascade West Parkway SE, Grand Rapids, Michigan 49546. Michael DeSmyter, Mark R. Satkoski, and Jack N. Tunge, each a principal owner, owning more than twenty-five percent (25%) of our firm’s membership interests. Henry G. Swain and Jeffrey A. Gietzen hold minority membership interests in our firm. Our Advisory Services investment adviser representatives. Only our General. We provide consulting and investment management services to our clients. We investment adviser do this through representatives are authorized to give investment advice to clients. Information about our investment adviser representatives can be found in the Supplements that are included at the end of this Brochure. We do not categorically limit our advice or management to any particular type of investments. Instead, we provide consultation and management services on any investments with respect to which we feel qualified and capable and that we believe are appropriate for our clients. We may include open-end mutual funds, exchange-traded funds, closed-end funds, collective trusts, private and alterative funds, and similar investment vehicles (each, a “fund”) in our clients’ portfolios. Wealth Management Clients. We assist individuals with the management of their retirement (e.g., IRAs) and non-retirement investment assets. Under our investment management agreement, we provide a certain level of financial planning services to our wealth management clients. When we mutually agree that financial planning services are desirable and would be helpful to the client, we will develop a financial plan (“Financial Planning Services”). The Financial Planning Services may encompass one or more areas of need, including, but not limited to, investment planning, retirement planning, estate and estate tax planning, charitable giving planning, educational funding planning, cash flow and asset/liability analysis, risk tolerance assessment, assessing insurance coverage and other areas upon which the client and we may agree. Because our Financial Planning Services recommendations will be based on the information that the client provides to us, we rely on the client to provide us with complete and accurate information that we do not independently verify. The client will discuss with us his or her current financial resources and projected needs and provide copies of any financial documents that we may reasonably request as necessary to evaluate the client’s financial circumstances and to provide any Financial Planning Services. The basic Financial Planning 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5) 1  Services if included, shall be provided as part of the overall management fee (as described below under Item 5 – Fees and Compensation). If a client has not engaged in the more robust Financial Planning Services described above, we will engage in a planning process (“Planning Process”) to discuss and help to identify the client’s financial needs and objectives based upon the general background and financial information the client provides to us to develop Investment Guidelines (“Guidelines”) for clients. For clients that have engaged in the Financial Planning Services, we will develop Guidelines from the Financial Planning process. Using the Guidelines, we will determine which (if any) of our then-current strategies is appropriate for the client. Determining if a strategy is appropriate for and agreed to by a client is a requirement of opening and maintaining an investment account with us. Clients must advise us promptly, in writing, if their circumstances change. We use this information to evaluate if and to what extent the current strategy is still appropriate. Each client’s portfolio will represent a balance of risk and potential return and have an appropriate amount of asset diversification that is consistent with the client’s objectives and ability to tolerate risk. We periodically re-allocate and/or re-balance investment portfolios in light of our then-current investment strategies, market conditions, and other factors. A client’s portfolio will not necessarily follow the same investment strategy or be made up of the same investments as other clients. There will also be differences between the portfolios of clients with similar circumstances and investment objectives due to availability of some investments, when a client becomes a client, when purchases and sales are made and the size of the portfolio. Clients will either open an investment management account by depositing cash or securities into a brokerage or other custodial account or provided the custodian written authorization permitting us to manage and trade the account, subject to the Guidelines. Clients may direct that any investment that does not fit with our agreed upon investment strategies be sold immediately and the net sales proceeds be held for reinvestment. Alternatively, we and the client may agree on an interim strategy pending sale or reinvestment. Otherwise, we may defer the sale and reinvestment of non-conforming investments until a time we deem appropriate. We are not responsible for investment or tax losses incurred with respect to the sale of any securities that clients place into their accounts. When providing Financial Planning Services or engaging in the Planning Process we do not provide legal, estate, actuary, tax, or tax preparation services but, as appropriate, we may make referrals to third-party professionals if their products or services are appropriate for the client. We are not responsible for any action or omission of any third-party professional implementing our recommendations. Neither our Financial Planning Services nor our Planning 2 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  Process include implantation of any recommendations with respect to assets not under our management. Other than with respect to the accounts that are managed on a discretionary basis by us, clients are solely responsible for deciding whether to implement any of the recommendations provided as a component of our Financial Planning Services through service providers of his or her choice. Held-Away Assets. At a client's request, and for an additional fee, we may provide discretionary investment management for certain accounts, such as employer-sponsored retirement plan accounts ("held-away accounts") through a third-party order management platform (the “Platform”). We are not affiliated with the Platform's provider and do not receive any compensation from it. See Item 5 – Fees and Compensation for the fees for this service. For employer-sponsored plans, our investment decisions are limited to the investment options that the plan's sponsor or fiduciary makes available. We do not select, and cannot change, the plan's recordkeeper or custodian. The Platform allows us to conveniently communicate trades in your held-away account. However, there is a risk that the Platform’s access to the account may be terminated by the broker, custodian or recordkeeper (the “Institution”) at any time. If the Institution terminates access to the Platform, we are unable to communicate trades and will notify the client of the termination and will cease providing this service. Clients may also disconnect an account from the Platform at any time. If access is disconnected, we will discuss alternative methods for managing the held-away accounts. Trades in held-away accounts may take longer to complete than trades in accounts at our primary custodian. The time the institution takes to process a trade depends on its own procedures, cutoff times, and fund settlement practices. Trades can be delayed by the institutions for a variety of reason, including but not limited to, the institution's technical difficulties or when the Platform has high processing volumes or other operational issues. Most trades placed through the Platform are completed within two business days, but delays have occurred. Market prices may change during a delay, so the price a client receives may be higher or lower than if the trade had been completed sooner. We monitor the trades submitted through the Platform. Certain custodians have prohibited clients from sharing login credentials with third parties to access or trade their held-away accounts. If the client shares their username and password with the Platform, that share may violate the Institutions customer protection guarantee. We periodically monitor the terms and conditions of the Institutions and will notify the client and may recommend an alternative approach to managing the held-away accounts. To connect an account, we send the client a secure link, and the client enters his or her own login credentials directly on the Platform. Before linking an account, the client accepts the Platform’s terms of use and privacy notice, we strongly recommend that the client reviews the 3 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  foregoing before excepting. We do not have access to clients’ credentials and cannot use the Platform to withdraw money, transfer assets out of the account, or change beneficiaries, therefore, do not have custody of the assets held in these accounts. Once the account is connected, we can view its holdings, allocation, and available investment options. When we consider it appropriate, we can also submit rebalancing or trade instructions through the Platform. The Platform then sends those instructions to the Institution. Annuities. Upon request, we review and evaluate annuities currently held by the client. If appropriate, we will recommend an annuity exchange, also known as a 1035 exchange. A 1035 annuity exchange allows for the direct exchange of accumulated, tax-deferred funds in a cash-value annuity contract to another annuity contract, without incurring taxes at that time on the gains in the client’s current contract. We have established a relationship with an independent unaffiliated insurance company that offers fee-based annuities. Under this arrangement, the client will authorize us to provide ongoing advice for an additional fee (see Item 5 – Fees and Compensation for the specific fees for this service). Prior to or at the time the client engages us for this service, we will provide, and review with the client, important supplemental disclosures regarding annuities, our services and fees, and the related conflicts. If the client elects to accept our recommendation, the client will grant us the authority to provide such services through an addendum to our investment management agreement. The client will also designate us as the adviser-of-record with the independent unaffiliated insurance company. As the adviser-of-record, the client authorizes and directs the independent unaffiliated insurance company to accept and execute our instructions. We will provide instructions to the insurance company through the insurance company’s website or other electronic platform or by telephone, electronic mail, or facsimile to transfer money and change premium allocations among the investment options available under the client’s annuity contract. All such transfers and allocation changes will be subject to the terms, conditions, restrictions, and limitations set forth in the annuity contract and imposed by the insurance company. Under our agreement, we will provide ongoing advice regarding the annuity’s role and integration with the client’s Guidelines and evaluate the annuity’s continued suitability. We will review and advise on other strategies as “best interest” factors may dictate over time. We will also provide account maintenance services related to the ongoing requirements of the annuity policy (e.g., distributions, address changes, and beneficiary changes). Retirement Plan Clients. We provide investment services to qualified and non-qualified profit-sharing and retirement plans, including 401(k), 403(b), 457, 401(a) and cash-balance plans (collectively, “retirement plans”). As part of our services, we may act as a fiduciary as 4 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  defined in Sections 3(21)(A) and 3(38) of Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If a retirement plan engages us as a 3(21) advisor, we will make recommendations, but it is ultimately up to the plan fiduciary to decide whether and how to act. As a 3(21) advisor, we will not have discretion to invest and reinvest the plan assets without the plan fiduciary’s prior consent. Thus, as a 3(21) advisor, we will share responsibility for the selection of investments. If we act as a 3(38) investment manager, the plan fiduciary gives us discretionary authority to manage the plan’s assets. This means that the plan fiduciary shifts its fiduciary responsibility to us for the selection of the plan’s investments. The plan fiduciary will determine whether services are provided at the plan level, the participant level, or both. Plan level services typically include consulting services related to the structure of the plan, ongoing plan review meetings and plan committee oversight, development of an appropriate investment policy statement (“IPS”), the custodial and recordkeeping platform, including plan fee analysis and benchmarking, and the establishment and monitoring of a lineup of investment offerings from which the plan participants can choose. Participant level services include ongoing educational content via our retirement plan dashboard, onsite and virtual group educational meetings, one-on-one asset allocation advice sessions, and retirement goal planning for participants approaching retirement. The scope of our services and fiduciary status is defined in our written agreement with the retirement plans. Not-for-Profits. We provide a range of consulting and investment management services to not-for-profit and charitable entities. These include an assessment of their near- and longer- term objectives and how best to meet them, as well as the IPS parameters that are appropriate for the portfolio. Services typically, but do not necessarily, include managing of the investment portfolio. Tailoring Advisory Services to Client Needs Before entering into an investment management relationship with a client, we will explain our then-current investment philosophies and strategies, and we encourage each prospective client and client to ask questions. We may change our investment strategies. While we generally advise our clients when these changes are made, as a discretionary advisor, we reserve the right to make and implement changes without prior notice or client approval. Each client is required to sign an investment management agreement that governs the terms of our relationship. Investment management agreements generally give us broad discretionary management authority. See Item 16 – Investment Discretion below for more information on our discretionary authority. 5 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  When clients establish an investment management relationship with us, and at least annually thereafter, they may place reasonable restrictions on what kinds of securities (for example, excluding a specific company’s securities) may be held in the account, so long as those restrictions are not inconsistent with our overall investment strategy and are otherwise acceptable to us. Any such limitations must be in writing. Investment Strategies. Typically, our strategies, available to wealth management clients, take the form of one (or a combination) of our risk-managed strategies, which are a combination of equity (e.g., stock investments) and fixed income (e.g., bond investments, cash) ranging from very conservative (substantially all fixed income) to very aggressive (substantially all equity). We also do custom allocations where circumstances warrant or clients request them. We do not separately charge for planning or custom allocation services unless the scope of the required or requested services is beyond that which we typically provide, and then only pursuant to a separate written agreement with the client. Private and Alternative Investments. We have established a relationship with an “Independent Manager” which we recommend, on a non-discretionary basis, to certain clients who may be interested in or where private and alternative investment opportunities are appropriate. A private offering is an offering of unregistered securities to a limited pool of investors. In a private offering, a company sells shares of stock in the company, warrants, limited partnership interests, bonds, or other interests. Alternative investments commonly include, among others, certain specialty open-end and closed-end mutual funds, interval funds, master limited partnership (MLP) shares, and non-traded securities such as real estate investment trusts (REITs), business development companies (BDCs), and unit investment trusts (UITs). In addition, private equity funds, venture capital funds, hedge funds, and other private funds also offer investments in their pools of investors’ funds and further invested in underlying private companies, securities, and other asset classes. Private offerings are not and will not be registered under the Securities Act of 1933, state securities laws, or the securities laws of any other jurisdiction, do not publicly report information under the Securities Exchange Act of 1934, and are not publicly traded. If a client invests in a private or alternative investment, the amount invested in such investment will be included in our fee calculation (as described below under Item 5 – Fees and Compensation). For important information regarding the risks associated with these types of investments see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss below. Assets Under Management As of December 31, 2025, the amount of client assets we manage was approximately $1,110,560,207 on a discretionary basis and approximately $246,016,111 on a non- discretionary basis, for a total of approximately $1,356,576,318. 6 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  Item 5 – Fees and Compensation How We Are Compensated for Our Services We receive fees from our clients for the investment management services we provide to them. We establish the specific manner in which we charge our fees in the written investment management agreement signed with us prior to beginning our relationship with the client. Fees for Investment Management Services to Wealth Management Clients. Generally, annualized fees will be based on the market value of the account, including cash and cash equivalents, as reported by the custodian as of the end of the preceding calendar quarter or month (in other words, “in arrears”), depending on the terms of the agreement. Our fee schedule will also apply to assets in held-away accounts managed through the third-party platform and private or alternative investments, as applicable. Our management fee includes the financial planning services as described above under Item 4 – Advisory Business. Our annuity-related advisory fees are calculated using the same annualized fee specified in the client’s agreement. The fee rate is applied to the principal value of the client’s annuity contract and is generally deducted directly from the annuity contract to the extent permitted under the terms of the annuity contract or from a taxable account designated by the client for such purposes. The specific fee terms and arrangements are explained in the addendum to our agreement which will be signed by the client and us. If the investment management agreement is executed at any time other than the first day of a calendar quarter, our fees will be pro-rated for the number of days which the agreement was in effect. We will also make pro-rated adjustments to our fees when a client adds or withdraws assets to or from their account. We negotiate our fees with each client. Negotiated fee structures are based on a number of factors including the amount of assets under management, the nature and extent of management services, the complexity of investments and other unique characteristics of the proposed engagement. We reserve the right to charge different fees to different clients, to reduce the fee for larger accounts, to aggregate or combine related accounts for fee calculation purposes, to charge lower fees where additional funds are expected to come under management and to charge a lower fee on accounts owned or controlled by our principals or investment adviser representatives. We may amend our fee schedules upon thirty (30) days’ prior written notice. Clients may terminate their agreement without penalty prior to the effective date of any fee increase. 7 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  Our standard wealth management client fee schedule is as follows: Assets under Management Annual Fee First $1,000,000 0.90% $1,000,001 - $2,000,000 0.75% $2,000,001 - $5,000,000 0.60% Over $5,000,000 0.50% Minimum annual fee is $5,000. Fees for Investment Management Services to Retirement Plans. Currently, our annual advisory fees for retirement plans are calculated and charged either based on an annual percentage of the fair market value of the assets in the plan at the end of each month or quarter and/or a flat dollar amount. We negotiate our annual advisory fees based on several factors, including, but not limited to, the plan’s demographics, total plan assets, contribution rates, and the number of participants. When agreed upon, the plan’s recordkeeper will calculate the amount of our fee based on the terms of our agreement with the plan fiduciary. Our advisory fee is paid either monthly or quarterly in arrears, as specified in the investment management agreement with the plan. Because we are compensated based on the total value of assets we are managing for you, a conflict arises whenever a client seeks advice from us that would reduce the assets under our management - because reducing the assets under our management will, in turn, reduce our fees. For example, if a client withdraws funds to pay off a home mortgage, our investment management fees will be reduced. Payment of Fees Generally, fees for investment management services are paid by having the client’s custodian deduct the fees from the investment management account. If requested by the custodian for clients for whom we calculate the fee, we provide the custodian with a copy of the investment management agreement (or other documentation) as evidence of the client’s agreement to the fee deduction. We do not directly debit our fee from held-away accounts. Instead, our fee is deducted from the client’s other managed taxable accounts. If the client does not have a taxable account, our fee will be billed directly to the client. 8 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  For those retirement plan clients that have assets held at a custodian that calculates the fee, the custodian calculates the fee based on the agreement signed by the client and then remits the fee to us. In all other cases, we send our fee invoice and/or the amount of the invoice to the client’s custodian. If any fee deduction authorization is terminated, the client must pay the invoice within 10 days after receipt. As discussed above, fees are billed and deducted quarterly or monthly depending on the specifics of the client relationship. Other Fees and Expenses Fees we receive from clients are in addition to and exclusive of brokerage commissions, transaction fees, and other related costs and expenses that clients will pay. Clients may also pay fees imposed by custodians, brokers, third-party investment providers and other third-parties on brokerage accounts and securities transactions. These may include such things as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes. Funds also charge fees and expenses. Each fund prospectus describes the fees and expenses charged by the fund’s sponsor. These fees typically include management fees, shareholder servicing fees, other fund expenses, and may include initial, deferred or asset-based sales charges for distribution and related expenses. These “fund level” expenses are borne by all investors in the fund and reduce the investment return to those investors. Investment management fees clients pay to us are separate from and in addition to these fund-level expenses that are paid by clients who own these funds. In other words, clients that own funds pay two levels of investment management fees: one level to us for our management services and a second level of fees to the funds in which they are invested. With the exception of Dimensional Fund Advisors funds and collective trusts, which are not available except through approved advisers (such as us), clients could avoid paying an investment management fee to us by investing directly in the funds without using our services. In this scenario, the retail share class of the fund may have a higher expense ratio than the institutional share class we have access to as an advisory firm. Some funds will have the same expense ratio regardless of whether it is purchased directly by the client or through our management. Item 12 – Brokerage Practices below further describes the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation. Termination of Services Investment management agreements remain in effect until terminated by either us or the client. Investment management agreements for wealth management services may be terminated by the client or by us upon fifteen (15) days’ prior written notice. Our agreements with retirement plans may generally be terminated by either party by providing 30 days’ 9 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  written notice to the other party. In that event, the agreement will terminate on the month end immediately following the 30-day notice period. In the event of a termination, we will charge a prorated fee based on the number of days that services were rendered during the partial billing period based on the value of the account at the normal month-end closest to the termination date. Upon termination we will have no further responsibilities with respect to the client’s investments. If clients choose to change custodians, they will be responsible for paying any transfer fees and charges imposed by the client’s custodian. Compensation for Sales of Securities Neither MCA nor any of our investment adviser representatives are compensated (for example, through commissions, 12b-1 or similar fees) by third parties for the sale of investment product or securities. However, if we specifically recommend a client utilize a 1035 exchange from an existing annuity, such a recommendation creates a conflict of interest if the client accepts the recommendation, as we earn fees on the principal value of the annuity which would not be earned if the annuity were not under our management. To address this conflict, our investment adviser representative must review, compare, and document the current annuity contract, fee structure, and investment options to determine if the exchange is in the best interest of the client. Item 6 – Performance-Based Fees and Side-by-Side Management We do not currently charge or receive any performance-based fees (in other words, fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients We provide investment management services to individuals, high net worth individuals, corporations, businesses, plan participant retirement accounts, trusts, charitable organizations, profit-sharing plans, public institutions, 401(a) plans, 401(k) plans, 403(b) plans, 457 plans, cash-balance plans, and other tax-deferred retirement plans. We do not have strict minimum account size restrictions for our wealth management clients, but we do reserve the right to charge a minimum annual fee of $5,000 on all or some accounts, which will tend to discourage smaller accounts. In such cases, if the fee charged on a percentage basis is greater than the minimum fee, the annual fee will be based solely on a 10 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  percentage of assets under management. For more information about our fees see Item 5 – Fees and Compensation above. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies We use a variety of methods of investment and statistical analysis, in part depending on the type of investment. Our investment vehicle selection targets solutions which are efficient, cost-effective, and accurately express targeted exposures across both active and passive to diversify sources of return. We use a variety of factors and methods to evaluate and select funds that are used in our clients’ portfolios. These include analysis of absolute and relative risk- adjusted net returns over varying periods, manager tenure, risk profile, fiduciary measures, fund expenses, portfolio turnover, fund composition, fund “style drift,” consistency of management philosophy, process and personnel, information contained in fund prospectuses and, if necessary, meetings and/or conversations with fund company representatives. When using actively managed funds, we place particular emphasis on a manager’s ability to generate alpha and provide an attractive expected rate of return net of fee in their respective asset class. When requested, we customize portfolios that can include funds focused on socially responsible objectives. For example, Environmentally, Social, and Governance (ESG) funds or Principle-based funds. Services to Wealth Management Clients. Our portfolio allocation construction starts with a long-term strategy. This strategic asset allocation begins with a broad benchmark and tilts to rewarded sources of return that reflect our long-term views. From there, we adapt to changing market conditions by considering a relatively small tactical asset allocation. This portion of the portfolio takes a disciplined approach with qualitative and quantitative ingredients to seek opportunities and downside protection based on short- and medium-term investment views. We look at quantitative signals, such as sentiment, fundamental momentum, factor rotation, interest rates, and credit. We also consider qualitative signals such as the market outlook and economic trends, along with insights from policy experts. Services to Retirement Plan Clients. We will select, monitor, remove, and replace the plan’s investment options, including a qualified default investment alternative as defined in ERISA 404(c)(5) and DOL Regulation 2550.404c5 consistent with the IPS. The designated investment alternatives will offer a broad risk/return spectrum to allow participants to effectively diversify their portfolios according to their own personal risk and return objectives. We most commonly utilize mutual funds and collective investment trusts, analyzing various criteria further detailed in this Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. These criteria are 11 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  measured against an investment’s peer group to determine overall quality. Additional quantitative and qualitative criteria may also be used. We provide ongoing monitoring of the investments to confirm that they remain appropriate for the plan, and as a 3(38) investment manager we retain full discretionary authority to make changes to the designated investment alternatives or Model Portfolios offered under the plan or rebalance the assets in the plan without prior consultation with the plan fiduciary. The placing and execution of trades in the plan will be the responsibility of the plan’s custodian; provided, however, we may direct the custodian. Reports are generated and available to plan sponsors/fiduciaries on a quarterly basis. Types of Investments and Risks Involved Investing in securities involves risk of loss that clients must be prepared to bear! No method of investment analysis provides perfect information or foresight. All methods are subject to risks posed by the quality and accuracy of the information used, the methodologies used and the resulting conclusions reached. Investment strategies are somewhat a function of the quality of the investment analysis. And, in addition, they are subject to the risks normally attendant to investing such as market risk, diversification risk, business risk, interest rate risk, currency risk, political risk, natural event risk, legislative/regulatory risk, inflation risk, credit/default risk, call risk, reinvestment risk, liquidity risk and other risks that are discussed below. No investment strategy is perfect or can eliminate risk. No investment strategy can guarantee a positive result or that a client will not lose money. We believe that our methods of analysis and investment strategies do not involve significant or unusual risks beyond those that are present in any other methods or strategies. All investments have different types and degrees of risk. While our investment strategies are designed to provide appropriate diversification, some investments have significantly greater risk than others. Virtually all of our investment strategies are asset-class-based. This means we allocate an appropriate amount of each client’s portfolio among various broadly defined (e.g., equities vs. fixed income) and more narrowly defined (e.g., large-cap vs. small-cap equities, corporate vs. government bonds and long-term vs. shorter-term bonds) asset classes that we deem appropriate. The proportions of each asset class are dependent on the client’s objectives, time horizon, and tolerance for risk. The equity portion of a client’s portfolio is subject to “market” or “systematic” risk (i.e., the risk that an investment will lose value because of an overall market decline), which could be substantial, and potentially large swings in value. It is also subject to “non-systematic” risk (i.e., risks that are unique to a particular company, industry, or geographic area). These include business risk, political risk, currency risk, natural event, and legislative/regulatory risk. The fixed-income portion of a client’s portfolio is subject to its own set of risks including credit/default risk, interest rate risk, call risk, inflation risk, re- 12 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  investment risk, and event risk. Our usual practice is to use mutual funds or exchange traded funds as investment vehicles rather than individual securities. While this may provide for more diversification, it also adds a layer of cost (i.e., the fund operating expense) and does not guarantee that a loss in value of one or more of the holdings in that fund will not adversely affect the value of the fund as a whole since only “non-systematic” risk can be reduced through diversification. If clients want to pursue higher rates of return on investments, they must be able to accept higher levels of risk. Our investment strategies are designed to balance risk and potential return to achieve client objectives, but there is no assurance that they will do so. We encourage clients and prospective clients to ask questions about investment risks they do not understand. We use our best judgment on behalf of our clients. Still, we cannot assure clients that investments will be profitable or that there will not be losses in their investment portfolio. Past performance is one consideration with respect to any investment or investment adviser, but it is not a reliable predictor of future performance. We continuously strive to deliver outstanding long-term investment results but economic and market variables beyond our control can affect a portfolio’s investment performance. Private and Alternative Investments. The specific risks associated with any private or alternative investments that we recommend will be disclosed in the specific offering documents by the securities issuer or sponsor. We will also provide the client with an “Alternative Investment Risk Disclosure Addendum” explaining the services we provide, the related advisory fees, and risks associated with these types of investments, prior to the client investing in these types of investments. Particular Types of Securities. As mentioned in Item 4 – Advisory Business, we do not categorically limit our advice or management to any particular types of investments. Instead, we provide investment advice on any investment for which we feel qualified and capable and that we believe is appropriate for our clients. Item 9 – Disciplinary Information As a registered investment adviser, we are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We have no information that is required to be disclosed pursuant to this item. 13 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  Item 10 – Other Financial Industry Activities and Affiliations As a registered investment adviser we are required to disclose if we or any of our management personnel are registered (or planning to register) as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor or an associated person of any of these entities, or if we recommend (or have any other relationship with) any other investment adviser that might create a conflict of interest and receive compensation for doing so. We have no information that is required to be disclosed pursuant to this item. We are also required to identify and describe conflicts of interest related to any material relationship or arrangement that we or any of our management persons have with certain other persons in the financial, investment, banking, accounting, accounting, legal, insurance, real estate, or similar industries. We have no relationships or arrangements that are required to be disclosed. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We adopted a Code of Ethics which sets forth the standards of business conduct that we expect all officers, managers, members, investment adviser representatives, and employees to follow. It also describes certain reporting requirements with which certain particular individuals associated with us (our “access persons”) must comply. We will provide a copy of our Code of Ethics to any client or prospective client upon request at no charge. Requests should be directed to Michael DeSmyter, (616) 454-9600 or mdesmyter@midwestcap.com. MCA or our access persons may purchase for our or their own accounts (“proprietary accounts”) securities that we recommend to our clients, including clients that are related persons. Neither we nor any of our access persons are permitted to enter into or have an interest in an investment transaction that would create a conflict between our interests and our clients’ interests without fully disclosing the conflict to affected clients. Neither we nor our access persons are permitted to benefit, directly or indirectly, from transactions made for the account of others. Nonetheless, because MCA’s Code of Ethics permits access persons to invest for their own accounts in the same securities as clients, there is a possibility that the Code of Ethics would enable access persons to benefit from market movement that occurs as a result of our directed trades in client accounts. MCA’s CCO or a designee monitors access persons’ personal trading to ensure that such activity does not conflict with our obligations to our clients. 14 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  As discussed in Item 12 – Brokerage Practices below, periodically, we aggregate orders for accounts invested in our investment strategies. Under this circumstance, investments may only be purchased in proprietary accounts after the completion of the purchase of such investments for current client portfolios and may only be sold after completion of the sale of all client holdings of such investments. Exceptions are made for proprietary account trades that we believe do not involve potential conflicts of interest, such as Treasury securities, open-ended mutual funds, and securities that have very high market capitalizations and/or very high average trading volumes relative to the amounts involved. We believe that in such cases the potential for trades we make to materially affect the price of an investment is minimal or virtually non-existent. Exceptions may also be made in accordance with our trade allocation policy, which is discussed in Item 12 – Brokerage Practices below. Item 12 – Brokerage Practices Selecting Broker-Dealers While we use a variety of custodial and trading resources for retirement plan clients, we require that wealth management clients establish brokerage accounts with Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of SIPC, to custody client assets and to effect trades for their accounts. MCA is not affiliated with Schwab (or any other financial services company, for that matter). Schwab provides MCA with access to institutional trading and custody services and pricing, which are not typically available to Schwab retail customers. These services are generally available to independent investment advisers at no charge to them so long as the adviser’s clients’ assets are maintained in accounts at Schwab. They include brokerage, custody, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors that require a significantly higher minimum initial investment or that may be closed to retail investors. Schwab does not generally charge separately for custody but is compensated by account holders through commissions or other transaction-related fees for trades that are executed through Schwab or that settle into Schwab accounts. We typically recommend Schwab based on the quality and cost of its execution services. We believe that transaction fees and other charges imposed by Schwab are competitive and are at or below those charged by other broker-dealers. In addition, we believe that Schwab’s services and support, including data processing, order entry and reporting systems, are superior to and more cost effective than many other brokerage firms. Schwab’s systems allow us easy access to clients’ account information, permit easy order entry, generate good client reports, and facilitate our management of those accounts. 15 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  We engaged the professional assistance of BlackRock Fund Advisors (“BlackRock”) to assist the MCA Investment Committee in the construction of MCA’s investment strategies for our wealth management clients (e.g., strategies with allocations of various levels of risk). Through BlackRock’s team of investment professionals, MCA is provided research and on-going investment strategy support through the BlackRock portfolio managers. A conflict of interest is created when engaging BlackRock, as we must commit to using BlackRock funds (not exclusively, but in tandem with MCA-selected non-BlackRock funds) within the investment strategies to continue to receive the professional assistance. The agreement with BlackRock allows MCA to retain control of the selection of how many BlackRock funds are utilized and whether any non-BlackRock funds are utilized. While a conflict of interest is created, we believe the conflict is mitigated given our clients benefit from comprehensive investment strategies created through the investment research of BlackRock’s team and portfolio managers. For 403(b)/457 plans we typically use Broadridge Financial Solutions (including Matrix Financial Solutions and other affiliates) of Denver, Colorado, for custody and trading services given its expertise and experience in that area and low fee structure. Notwithstanding the foregoing, we regularly evaluate Schwab and other broker-dealers and custodians we use against services offered by competing custodians and broker-dealers, and we reserve the right to choose the broker-dealer(s) with whom we place securities transactions for client accounts. Not all advisers require clients to authorize their adviser to execute transactions through a specified broker-dealer. We are unwilling to accept accounts where not all transactions would be directed to the same broker-dealer because of the inherent difficulty in such circumstances of meeting our responsibility to obtain best execution for the client’s transactions. Clients who direct us to use a particular brokerage firm are responsible for negotiating brokerage commissions and charges. We cannot do this because we cannot effectively negotiate for lower brokerage expenses when the business cannot be taken to a lower cost brokerage service provider. Accordingly, clients that direct brokerage services may pay more (perhaps significantly more) for brokerage services, and/or perhaps receive less favorable pricing than clients for whom we can select the brokerage firm. Transactions for directed brokerage accounts cannot be aggregated with discretionary brokerage accounts under our trade allocation policy, which is described in the next section of this Item. Aggregation of Purchases and Sales. From time to time, we determine that the purchase or sale of a particular security utilized in our investment strategies is appropriate. We can, but are not obligated to, aggregate some or all of those wealth management client orders into one order for execution purposes. Aggregating orders can prevent an adverse effect on a security’s price when simultaneous separate and competing orders are placed. When 16 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  aggregating orders and subsequently allocating purchases or sales to individual client accounts, it is our policy to treat all accounts fairly and to achieve an equitable distribution of aggregated orders. We allocate aggregated orders in accordance with policies and procedures intended to achieve fair treatment. Each affected account included in the aggregated order will participate in the aggregated order at the average price for all transactions in that security in the aggregated order. If an aggregated order is not filled in its entirety, it will be allocated on a pro rata basis. We will not aggregate orders for a client that has a directed brokerage relationship (such as a retirement plan account) with those of a client who does not have a directed brokerage relationship with the same broker-dealer. One consequence of this is that the client may not obtain as good a price in separate transactions as those obtained by clients whose orders have been aggregated. Clients or prospective clients that have questions about our trade allocation policy are invited to contact us. Item 13 – Review of Accounts We review our wealth management clients’ investments regularly, with a general review occurring quarterly and more specific reviews occurring less frequently, but at least annually. For Retirement Plan clients, we arrange committee meetings at least annually, but often will schedule semi-annual meeting, where we review the investment menu. Market, economic or geo-political events or developments may trigger a special review of some or all of our clients’ investments. We do not have a limitation on the number of accounts assigned to any particular person, nor is there a precise sequence or review schedule. Accounts are reviewed by one or more of our investment adviser representatives. Our Investment Committee meets several times throughout the year and as a result all accounts in our core models are being reviewed. Accounts in custom allocations are reviewed at least annually, but often semi-annually. We furnish (and/or make available through a client portal) written reports to our wealth management clients on a quarterly basis. These include a summary of portfolio performance and may include an analysis of macro- or microeconomic conditions, the impact on various asset classes or industry sectors, current and historical returns, comparative performance indices, and other matters we deem relevant. In addition, clients receive separate, periodic (typically monthly when there has been activity in the account; otherwise at least quarterly) accounting reports from their custodian. Custodial statements detail all cash and asset transactions and activities during the reporting period. Specific statement content varies between custodians. Clients can also request and receive interim account information from us or online via their custodian’s website. We strongly urge clients to carefully review such 17 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  statements and compare official custodial records to any account statements that we may provide to you. We are also happy to meet with wealth management clients upon request, either in person or by telephone or other electronic means. At least one of our investment adviser representatives is normally available during business hours to discuss investment matters and answer client questions. We strongly urge clients to contact us when questions arise or when a material change in their objectives, risk profile or other circumstances that may affect their investment plan are expected or have occurred. Item 14 – Client Referrals and Other Compensation Because we feel that doing so might create a potential conflict of interest or appear to impair our independence, we do not accept compensation (or other economic benefit) from any person other than our clients for providing investment management services to our clients. We do not consider referrals of new client relationships as an element of the compensation plan for our principals, employees, and investment adviser representatives. Our compensation is solely earned from investment management services to our clients. We do not engage any third-party promoter to market our services or compensate anyone for client referrals. Item 15 – Custody We do not maintain custody of client assets. Rather, each client appoints a qualified custodian to take possession of their funds and securities. We are, however, deemed to have constructive custody by virtue of the fact we have the authority to deduct client fees from client accounts (see Item 5 – Fees and Compensation above). We are also deemed to have custody when a client establishes a standing letter of instruction (“SLOAs”) or other asset transfer authorization arrangement with their qualified custodian, authorizing us to disburse funds to one or more third parties specifically designated by the client. As indicated in Item 13 – Review of Accounts above, clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains the clients’ investment assets. Any statements we might send to our clients might vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 18 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)  Item 16 – Investment Discretion Our investment management agreements generally provide us with discretionary authority to manage securities accounts on behalf of clients. This authority is broad and includes choosing the types of investments, the allocations between various categories of investments, the timing of investment decisions and trading strategies and techniques. Our discretionary authority is limited, however, in two important respects. First, such discretion can only be exercised in a manner that is consistent with the stated and agreed-upon investment objectives for the particular client account as set forth in and provided to us in writing in the client’s Guidelines. Second, investments may only be purchased, sold, or transferred in each client’s name, and proceeds from the sale or liquidation of securities may only be disbursed to a client’s custodian, not to us. As mentioned in Item 15 – Custody above, we are not permitted to have actual custody of client assets, so all checks, securities and other property must be transferred directly between the client and the client’s custodian. Item 17 – Voting Client Securities Unless otherwise agreed to in writing, as a matter of firm policy and practice, we do not take on authority for and do not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for all securities held in their accounts. We will not advise or act on a client’s behalf in any legal proceedings, including bankruptcies or class actions, involving securities held or previously held by the client or the issuers of these securities. Clients should receive proxy materials or other solicitations directly from their custodian or transfer agent. Clients may contact us with questions about a particular solicitation. Item 18– Financial Information We have no financial commitments that impair our ability to meet contractual and fiduciary commitments to clients. We have not been the subject of a bankruptcy proceeding. 19 2026 October Form ADV Part 2A - Midwest Capital Advisors(33621937.5)