MA PRIVATE WEALTH, LLC

Item 1 – Cover Page FIRM BROCHURE PART 2A of FORM ADV 1355 San Carlos Avenue, Suite A San Carlos, CA 94070 (650) 232-2021 www.maprivatewealth.com telephone at This brochure provides information about the qualifications and business practices of MA Private Wealth, LLC. If you have any questions regarding the contents of this brochure, please contact our Chief Compliance Officer, Erica Arroyo, by (650) 232-2021 or by email at erica@maprivatewealth.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. MA Private Wealth, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about MA Private Wealth Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. August 1, 2025  Item 2 – Material Changes Form ADV Part 2A requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since brochure since the last annual filing made February 27, 2025, the following materials changes were made to this brochure: • • • • Item 4 was updated to reflect that in June 2025, ownership of MA Private Wealth, LLC was transferred into MAPW Holdings, LLC, which itself is majority owned by MAPW LegacyCO, LLC, majority owned by Martin Miller. Item 4, the description of MAPW’s Wrap Program was amended. Items 4, 5, 8, 10 were updated to indicate that MAPW does not currently use Independent Managers, and to further define the authority through which it may elect to do so in the future. Items 10 and 12 were updated to disclose MAPW’s relationship with BlackRock Fund Advisors (“BFA”) and to define the resulting conflicts of interest. In August 2025, Erica Arroyo was named the Chief Compliance Officer. • MA Private Wealth encourages each client to read this Brochure carefully and to call us witih any questions you might have.  Item 3 - Table of Contents Item 1 – Cover Page ................................................................................................................................ 1 Item 2 – Material Changes ....................................................................................................................... 2 Item 3 - Table of Contents ....................................................................................................................... 3 Item 4 - Advisory Business ...................................................................................................................... 4 Item 5 - Fees and Compensation .............................................................................................................. 6 Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................ 9 Item 7 - Types of Clients ......................................................................................................................... 9 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .................................................... 9 Item 9 – Disciplinary Information .......................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions ............................................... 13 Item 12 – Brokerage Practices ............................................................................................................... 14 Item 13 – Review of Accounts ............................................................................................................... 17 Item 14 – Client Referrals and Other Compensation............................................................................... 17 Item 15 – Custody ................................................................................................................................. 18 Item 16 – Investment Discretion ............................................................................................................ 18 Item 17 – Voting Client Securities ......................................................................................................... 18 Item 18 – Financial Information............................................................................................................. 19  MA Private Wealth Advisors, LLC Disclosure Brochure Item 4 - Advisory Business Description of the Advisory Firm MA Private Wealth Advisors, LLC (“MAPW” or the “Firm”) is a limited liability company organized in the State of Delaware. MAPW is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). MAPW is majority owned by MAPW Holdings, LLC, which itself is majority owned by MAPW LegacyCo, LLC, majority owned by Martin S. Miller. Types of Advisory Services MAPW provides holistic and personalized discretionary and non-discretionary investment advisory services to individuals, including high net worth individuals, and entities, including, but not limited to, family offices, trusts, estates, and private foundations. Investment Management Services MAPW offers investment management services on a discretionary basis and non-discretionary basis. All investment advice provided is customized to each client’s investment objectives and financial needs. MAPW tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. MAPW consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by MAPW to determine the appropriate portfolio asset allocation and investment strategy for the client. Clients are advised to promptly notify MAPW if there are changes in their financial situation. MAPW primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, but may also utilize individual fixed income instruments, UITs, in addition to the maintenance of cash or cash equivalent postions for liquidity or other needs in accordance with their stated investment objectives. MAPW, through the authority granted by the client through the executed Investment Management Agreeement (“IMA”) and when it is in the best interest of the client, may further recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“Independent Managers”). Currently MAPW does not utilize the services of Indendent Managers, but may do so in the future. The client may be required to enter into a separate agreement with the Independent Manager(s), which will set forth the terms and conditions of the client’s engagement of the Independent Manager. MAPW generally renders services to the client relative to the discretionary selection of Independent Managers. MAPW also assists in establishing the client’s investment objectives for the assets managed by Independent Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by MAPW, if applicable. In certain circumstances, MAPW may implement investment advice on behalf of clients in certain held-away accounts – for example, 401(k) or 529 plan accounts – maintained either at the custodians with whom we have an institutional relationship or at other independent third-party custodians. We have the capability to review, monitor, and manage these held-away accounts in a 4  MA Private Wealth Advisors, LLC Disclosure Brochure fashion similar to the way in which we review, monitor, and manage accounts that are not held away. When MAPW provides investment advice to a client regarding a client’s retirement plan account or individual retirement account, MAPW is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way MAPW makes money creates some conflicts with client interests, so MAPW operates under a special rule that requires the Firm to act in the client’s best interest and not put the Firm’s interest ahead of theirs. Investment Management Services to Retirement Plans MAPW offers discretionary advisory services to qualified plans, which may include profit sharing and 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment policy statements, working with plan service providers, and providing general investment education to plan participants. Financial Planning and Consulting Services MAPW offers personal comprehensive financial planning services to set forth goals, objectives and implementation strategies for the client over the long-term. Depending upon individual client requirements, the comprehensive financial plan will include recommendations related to some or all of the following:  Retirement Planning  Business Planning  Cash Flow Forecasting  Risk Management  Trust and Estate Planning  Charitable Giving  Financial Reporting  Investment Consulting  Insurance Planning  Distribution Planning  Tax Planning  Manager Due Diligence MAPW prepares and provides the financial planning client with a written comprehensive financial plan and performs quarterly, semi-annual or annual reviews of the plan with the client, dependent on the client’s needs in accordance with the financial planning agreement. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. Clients are under no obligation to implement any of the recommendations provided in their written financial plan. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have MAPW implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. MA Private Wealth may recommend clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage MA Private Wealth or its affiliates to provide additional services for compensation. MAPW cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. Client-Tailored Advisory Services 5  MA Private Wealth Advisors, LLC Disclosure Brochure Clients may impose reasonable restrictions on the management of their accounts if MAPW determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for MAPW’s management efforts. Information Received From Clients MAPW will not assume any responsibility for the accuracy or the information provided by clients. MAPW is not obligated to verify any information received from a client or other professionals (e.g., attorney, accountant) designated by a client, and MAPW is expressly authorized by the client to rely on such information provided. Under all circumstances, clients are responsible for promptly notifying MAPW in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. In the event that a Client notifies MA Private Wealth of any changes, MA Private Wealth will review such changes and implement any necessary revisions to the Client’s portfolio. Wrap Fee Program MAPW primarily makes investment management services available pursuant to a wrap fee program whereby MAPW serves as both the sponsor and portfolio manager of the wrap fee program. A wrap fee program is an advisory program under which a specified fee not based directly upon transactions in a client’s account is charged for investment advisory services and the execution of client transactions. Accounts managed through the Wrap Program are done so in substantially the same manner as those managed under a non-wrap arrangement. When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total program fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. The utilized custodians generally do not charge commissions or transaction fees for online trades of U.S. exchange-listed securities (including U.S. exchange-listed ETFs), options, and no-transaction-fee (“NTF”) funds. This means that, in most cases, when we buy these types of securities, we can do so without paying any commissions. We encourage you to review Fidelity and Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. Please refer to MAPW’s Form ADV Part 2A Appendix 1 for information regarding this wrap fee program. Assets Under Management As of December 31, 2024, client assets under management for the firm totaled $584,116,623, of which $581,960,053 was managed on a discretionary basis. Item 5 - Fees and Compensation MAPW charges fees based on a percentage of assets under management as well as fixed fees, depending on the particular types of services to be provided. The specific fees charged by MAPW for services provided will be set forth in each client’s Agreement. Participants in the Wrap Program are generally subject to the the same fee schedule as non-wrap accounts. Investment Management and Financial Planning Services Fees for Investment Management Services 6  MA Private Wealth Advisors, LLC Disclosure Brochure MAPW charges an annual advisory fee that is agreed upon with each client and set forth in an agreement executed by MAPW and the client, based on a percentage of the value of assets under management. The advisory fee for the initial quarter shall be paid, on a pro rata basis, in advance, based on the value of the net billable assets under management at the time the account becomes subject to the management of MAPW, including cash, accrued interest, accrued dividends, and securities purchased on margin. For subsequent quarters, the advisory fee shall be paid, in advance, based on the asset value of the client’s accounts as of the last business day of the preceding quarter as provided by third-party sources, such as pricing services, custodians, fund administrators, and client-provided sources. Following is MAPW’s asset based fee schedule for Investment Management Services: PORTFOLIO VALUE Up to $250,000 $1,000,000 $250,001 - $2,500,000 $1,000,001 - $2,500,001 - $5,000,000 $5,000,001 - $10,000,000 $10,000,001 - $20,000,000 $20,000,001 - $30,000,000 $30,000,001 - $40,000,000 Above $40,000,000 BASE FEE 1.50% 1.25% 1.00% 0.85% 0.80% 0.75% 0.70% 0.65% Negotiable Notwithstanding the foregoing, MAPW and the client may choose to negotiate an annual advisory fee that varies from the ranges and schedule set forth above. Factors upon which a different annual advisory fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. In addition, some legacy clients may be grandfathered under the fee schedules as listed in their individual account agreements in effect at the time they became a client, which may result in fees higher or lower than those listed above. The advisory fee charged by the Firm will apply to all of the client’s assets under management, unless specifically excluded in the client agreement. The advisory fee may include the financial planning services described above. Although MAPW believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. For certain clients, we charge an advisory fee for services provided to the held-away accounts mentioned above in Item 4, just as we do with client accounts held at our primary custodian(s). The specific fee schedule charged by us is provided in the client’s investment advisory agreement with us. The investment advisory agreement between MAPW and the client may be terminated at will by either MAPW or the client upon written notice. MAPW does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. Fees for Financial Planning and Consulting Services MA Private Wealth generally charges a fixed ongoing fee for providing financial planning and consulting services under a stand-alone engagement. The fee charged for such services are negotiable and depend upon the complexity of a client’s plan and services provided. Clients receive invoices reflecting the amount of the fee due and payable. The terms and conditions of the financial planning and/or consulting engagement are set forth in the client agreement with MA Private Wealth. Fees are due semiannually and billed in arrears in 7  MA Private Wealth Advisors, LLC Disclosure Brochure June and December every year, regardless of when the agreement is signed and accepted. MAPW does not prorate or rebate financial planning fees. If during the course of the year, a new client enters into a new Financial Planning agreement, MAPW will not collected prorated fees, and will delay billing until the scheduled June or December billing cycle, whichever comes first. Further, if a client elects to terminate an agreement, there are no rebates given (as billing is in arrears). Payment of Fees MAPW generally deducts its advisory fee from a client’s investment account(s) held at his/her custodian. Upon engaging MAPW to manage such account(s), a client grants MAPW this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or properly calculated. A client may utilize the same procedure for financial planning or consulting fees if the client has investment accounts held at a custodian. Although clients generally are required to have their investment advisory fees deducted from their accounts, in some cases, MAPW will directly bill a client for investment advisory fees if it determines that such billing arrangement is appropriate given the circumstances. The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating eparate line items for all amounts disbursed from the client's account(s), including any fees paid directly to MAPW. Clients may make additions to and withdrawals from their account at any time, subject to MAPW’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets at any time on notice to MAPW, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. MAPW may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers In connection with MAPW’s management of an account, a client will incur fees and/or expenses separate from and in addition to MAPW’s advisory fee. These additional fees may include transaction charges and the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, separate account manager (and the manager’s platform manager, if any), limited partnership, or other advisor, transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account. While not currently utilized, for Independent Managers, clients should review each manager’s Form ADV 2A disclosure brochure and any contract they sign with the Independent Manager (in a dual contract relationship) when applicable. The client is responsible for all such fees and expenses. Please see Item 12 of this brochure regarding brokerage practices. Prepayment of Fees 8  MA Private Wealth Advisors, LLC Disclosure Brochure As noted in Item 5(B) above, MAPW’s advisory fees generally are paid in advance. Upon the termination of a client’s advisory relationship, MAPW will issue a refund equal to any unearned management fee for the remainder of the month, or otherwise applicable period. The client may specify how he/she would like such refund issued (i.e., a check sent directly to the client or a check sent to the client’s custodian for deposit into his/her account). As specified above, for MAPW’s planning fees, which are charged in arrears, no balances will be collected upon termination. Outside Compensation for the Sale of Securities or Other Investment Products to Clients MAPW does not buy or sell securities and does not receive any compensation for securities transactions in any client account, other than the investment advisory fees noted above. Item 6 - Performance-Based Fees and Side-by-Side Management MAPW does not charge performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of a capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. MAPW’s fees are calculated as described in Item 5 above. Item 7 - Types of Clients MAPW offers investment advisory services to individuals, including high net worth individuals, families, trusts, and business enitities. MAPW does not impose a minimum portfolio size or a minimum initial investment to open an account. However, MAPW does reserve the right to accept or decline a potential client for any reason in its discretion. Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis and Risk of Loss A primary step in MAPW’s investment strategy is getting to know the clients – to understand their financial condition, risk profile, investment goals, tax situation, liquidity constraints – and assemble a complete picture of their financial situation. To aid in this understanding, MAPW offers clients financial planning that is highly customized and tailored. This comprehensive approach is integral to the way that MAPW does business. Once MAPW has a true understanding of its clients’ needs and goals, the investment process can begin, and the Firm can recommend strategies and investments that it believes are aligned with the client’s goals and risk profile. MAPW primarily employs fundamental analysis methods in developing investment strategies for its clients. Research and analysis from MAPW is based on numerous sources, including third-party research materials and publicly-available materials, such as company annual reports, prospectuses, and press releases. For MA Private Wealth, this process typically involves an analysis of an issuer’s management team, investment strategies, style drift, past performance, reputation and financial strength in relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, evolving market conditions may negatively impact the security. MAPW generally employs a long-term investment strategy for its clients, as consistent with their financial goals. At times, the Firm may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the fundamentals of the security, sector or asset class. lient portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer 9  MA Private Wealth Advisors, LLC Disclosure Brochure objectives, time horizon and choice of custodian are all factors that influence MAPW’s investment recommendations. Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. Material Risks Involved Investing in securities involves a significant risk of loss which clients should be prepared to bear. MAPW’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small- stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset- backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment objective. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by MAPW include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. • • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They 10  MA Private Wealth Advisors, LLC Disclosure Brochure • also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held. • Management risk, which is the risk that the investment techniques and risk analyses applied by MAPW may not produce the desired results and that legislative, regulatory, or tax developments, affect the investment techniques available to MAPW. There is no guarantee that a client’s investment objectives will be achieved. • • Real estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. Investment companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Commodity risk, generally commodity prices fluctuate for many reasons, including changes in market and economic conditions or political circumstances (especially of key energy-producing and consuming countries), the impact of weather on demand, levels of domestic production and imported commodities, energy conservation, domestic and foreign governmental regulation (agricultural, trade, fiscal, monetary and exchange control), international politics, policies of OPEC, taxation and the availability of local, intrastate and interstate transportation systems and the emotions of the marketplace. The risk of loss in trading commodities can be substantial. 11  MA Private Wealth Advisors, LLC Disclosure Brochure • Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of MAPW and its service providers. The computer systems, networks and devices used by MAPW and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. • Alternative investments/private funds risk, investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; • lack of liquidity in that there may be no secondary market for the investment and none expected to develop; • volatility of returns; • restrictions on transferring interests in the investment; • potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized; • absence of information regarding valuations and pricing; • delays in tax reporting; • less regulation and higher fees than mutual funds; • risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments. • Closed-end funds risk, Closed-end funds typically use a high degree of leverage. They may be diversified or non-diversified. Risks associated with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of leverage. Additionally, closed-end funds may trade below their net asset value. There also are risks surrounding various insurance products that are recommended to MAPW clients from time to time. Such risks include, but are not limited to loss of premiums. Prior to purchasing any insurance product, clients should carefully read the policy and applicable disclosure documents. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. MAPW does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. 12  MA Private Wealth Advisors, LLC Disclosure Brochure Use of Independent Managers MAPW may in the future select certain Independent Managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, MAPW generally may not have the ability to supervise the Independent Managers on a day-to-day basis. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. MAPW has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations MAPW utilizes the services of unaffiliated model provider BlackRock Fund Advisors (“BFA”) for research and materials. BFA provides Models and materials at no charge to MAPW, as long as MAPW maintains 250 million in assets under management across the Models, subject to BFA’s discretion. MAPW has no other business relationship with BFA that is material to our advisory business except as outlined in this brochure. Advisor pays no direct compensation to Blackrock or its affiliates, however clients will indirectly bear fund expenses associated with their allocation to specific BlackRock Funds within a Model. A Model will include BlackRock Funds, some of which will pay fees to BlackRock for providing management, administrative, or other services. MAPW is not obligated to exclusively use BlackRock Funds and incorporates other holdings into client portfolios when appropriate. BFA may target maximum exposure to BlackRock Funds, and has an incentive to select BlackRock affiliated funds with higher fees over BlackRock affiliated funds with lower fees, as the fees that BlackRock and its affiliates receive from investments in the Affiliated BlackRock funds constitute BlackRock’s compensation with respect to the model portfolios. Although MAPW clients are not required to utilize BlackRock Funds in their portfolios, the use of such is a conflict as this practice could cause MAPW to focus on BlackRock Funds in order to continue receiving no cost research materials. MAPW attempts to mitigate this conflict by acting in the client’s best interest, conducting their own due diligence, and exercising their fiduciary duty when making investment recommendations. Recommendation of Independent Managers MAPW does not currently, but may in the future recommend that clients use Independent Managers based on clients’ needs and suitability, pursuant the authority granted by the client within their executed IMA. MAPW does not receive separate compensation, directly or indirectly, from such Independent Managers for recommending that clients use their services. MAPW does not have any other business relationships with the recommended Independent Managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions Description of Code of Ethics MAPW has a Code of Ethics (the “Code”) which requires MAPW’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. 13  MA Private Wealth Advisors, LLC Disclosure Brochure Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to MAPW for review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. MAPW will provide a copy of the Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers MA Private Wealth generally recommends that its investment management clients utilize the custody and brokerage services of an unaffiliated broker/dealer custodians (a “BD/Custodian”) with which MAPW has an institutional relationship. Currently, this includes Fidelity Brokerage Services LLC (“Fidelity”), and Charles Schwab & Co. (“Schwab) for investment management accounts, which are “qualified custodians” as that term is described in Rule 206(4)-2 of the Advisers Act. Each BD/Custodian provides custody of securities, trade execution, and clearance and settlement of transactions placed on behalf of clients by MAPW. If your accounts are custodied at Fidelity or Schwab, Fidelity or Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. Clients will pay fees tothe custodian for custody and the execution of securities transactions in their accounts. In making BD/Custodian recommendations, MAPW will consider a number of judgmental factors, including, without limitation: 1) clearance and settlement capabilities; 2) quality of confirmations and account statements; 3) the ability of the BD/Custodian to settle the trade promptly and accurately; 4) the financial standing, reputation and integrity of the BD/Custodian; 5) the BD/Custodian’s access to markets, research capabilities, market knowledge, and any “value added” characteristics; 6) MAPW’s past experience with the BD/Custodian; and 7) MAPW’s past experience with similar trades. Recognizing the value of these factors, clients may pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction. In exchange for using the services of Fidelity, MAPW may receive, without cost, computer software and related systems support that allows MAPW to monitor and service its clients’ accounts maintained with Fidelity. Fidelity also makes available to the Firm products and services that benefit the Firm but may not directly benefit the client or the client’s account. These products and services assist MAPW in managing and administering client accounts. They include investment research, both Fidelity’s own and that of third parties. MAPW may use this research to service all or some substantial number of client accounts, including accounts not maintained at Fidelity. In addition to investment research, Fidelity also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. • • provide pricing and other market data; • • 14  MA Private Wealth Advisors, LLC Disclosure Brochure Fidelity also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events; technology, compliance, legal, and business consulting; • • • publications and conferences on practice management and business succession. Fidelity may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to the Firm. Fidelity may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Any benefits received by MAPW through its participation in the Fidelity or Schwab custodial platforms do not depend on the amount of brokerage transactions directed to Fidelity or Schwab. In addition, there is no corresponding commitment made by MAPW to Fidelity or Schwab to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of participation in the program. While as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at Fidelity or Schwab will be based in part on the benefit to MAPW of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity or Schwab. The receipt of these benefits, if any, creates a potential conflict of interest and may indirectly influence MAPW’s choice of Fidelity for custody and brokerage services. MAPW will periodically review its arrangements with the BD/Custodians and other broker-dealers against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its clients. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker- dealer’s services, including, but not limited to, the following: • • • • • a broker-dealer’s trading expertise, including its ability to complete trades, execute and settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual market conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory manner; a broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and settlement process, and capacity to accommodate unusual trading volume; a broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such as whether a broker-dealer can maintain and commit adequate capital when necessary to complete trades, respond during volatile market periods, and minimize the number of incomplete trades; a broker-dealer’s ability to provide research and execution services, including advice as to the value or advisability of investing in or selling securities, analyses and reports concerning such matters as companies, industries, economic trends and political factors, or services incidental to executing securities trades, including clearance, settlement and custody; and a broker-dealer’s ability to provide services to accommodate special transaction needs, such as the broker-dealer’s ability to execute and account for client-directed arrangements and soft dollar arrangements, participate in underwriting syndicates, and obtain initial public offering shares. MAPW’s clients may utilize qualified custodians other than MAPW for certain accounts and assets, particularly where clients have a previous relationship with such qualified custodians. 15  MA Private Wealth Advisors, LLC Disclosure Brochure Brokerage for Client Referrals MAPW does not select or recommend BD/Custodians based solely on whether or not it may receive client referrals from a BD/Custodian or third party. Client-Directed Brokerage Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage MAPW to manage on a discretionary basis, MAPW has full discretion with respect to securities transactions placed in the accounts. This discretion includes the authority, without prior notice to the client, to buy and sell securities for the client’s account and establish and affect securities transactions through the BD/Custodian of the client’s account or other broker-dealers selected by MAPW. In selecting a broker- dealer to execute a client’s securities transactions, MAPW seeks prompt execution of orders at favorable prices. A client, however, may instruct MAPW to custody his/her account at a specific broker-dealer and/or direct some or all of his/her brokerage transactions to a specific broker-dealer. In directing brokerage transactions, a client should consider whether the commission expenses, execution, clearance, settlement capabilities, and custodian fees, if any, are comparable to those that would result if MAPW exercised its discretion in selecting the broker-dealer to execute the transactions. Directing brokerage to a particular broker-dealer may involve the following disadvantages to a directed brokerage client: • MAPW’s ability to negotiate commission rates and other terms on behalf of such clients • could be impaired; such clients could be denied the benefit of MAPW’s experience in selecting broker-dealers that are able to efficiently execute difficult trades; • opportunities to obtain lower transaction costs and better prices by aggregating (batching) • the client’s orders with orders for other clients could be limited; and the client could receive less favorable prices on securities transactions because MAPW may place transaction orders for directed brokerage clients after placing batched transaction orders for other clients. In addition to accounts managed by MAPW on a discretionary basis where the client has directed the brokerage of his/her account(s), certain institutional accounts may be managed by MAPW on a non- discretionary basis and are held at custodians selected by the institutional client. The decision to use a particular custodian and/or broker-dealer generally resides with the institutional client. MAPW endeavors to understand the trading and execution capabilities of any such custodian and/or broker-dealer, as well as its costs and fees. MAPW may assist the institutional client in facilitating trading and other instructions to the custodian and/or broker-dealer in carrying out MAPW’s investment recommendations. Trade Errors MAPW’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs, MAPW endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at Fidelity, or another BD, as the case may be. In the event an error is made in a client account custodied elsewhere, MAPW works directly with the broker in question to take corrective action. In all cases, MAPW will take the appropriate measures to return the client’s account to its intended position. Trade Aggregation 16  MA Private Wealth Advisors, LLC Disclosure Brochure To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Firm. Item 13 – Review of Accounts Periodic Reviews Investment Management Account Reviews While investment management accounts are monitored on an ongoing basis, MAPW’s investment adviser representatives seek to have at least one annual meeting with each client to conduct a formal review of the clients’ accounts. Accounts are reviewed for consistency with the investment strategy and other parameters set forth for the account and to determine if any adjustments need to be made. All investment advisory clients are encouraged to discuss their needs, goals and objectives with MA Private Wealth and to keep the Firm informed of any changes thereto. Financial Planning and Consulting Services Account Reviews Upon completion of the initial financial plan, ongoing annual review services are established, if provided for in the client agreement. Generally, we meet with our clients on an annual basis; however, more frequent reviews are not uncommon. The nature of the annual review is to evaluate the client’s progress from the previous year based on their goals and objectives. MAPW will collaborate with the client to update their financial information (i.e. insurance, investments, assets, income and expenses) and craft their yearly financial planning reports. Financial planning reports are written and may consist of a net worth statement, cash flow statement, estimated tax projections, education analysis, retirement analysis, insurance needs analysis, estate tax calculation, and an investment analysis. Reviews are conducted by an advisor of MAPW who is appropriately licensed to provide financial planning services. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in an account holder’s personal, tax or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company- specific events. Clients are encouraged to notify MAPW of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, or time horizon. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each brokerage account transaction unless confirmations have been waived. MAPW may also determine to provide account statements and other reporting to clients on a periodic basis. MAPW also provides account reports during client meetings. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by MAPW. MAPW statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 14 – Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients 17  MA Private Wealth Advisors, LLC Disclosure Brochure MAPW utilizes the services of unaffiliated model provider BlackRock Fund Advisors (“BFA”) for research and materials. These services and products, how they benefit us, and the related conflicts of interest are described above, see Item 10. You do not pay more to MAPW as a result of this arrangement, however we benefit because the cost of these services would otherwise be borne directly by us. You should consider these conflicts when selecting to implement a Model recommendation. Compensation to Non-Supervised Persons for Client Referrals MAPW does not currently provide compensation to non-supervised third-party solicitors. Item 15 – Custody All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct MAPW to utilize the custodian for the client’s securities transactions. MAPW’s agreement with clients and/or the clients’ separate agreements with the B/D Custodian may authorize MAPW through such BD/Custodian to debit the clients’ accounts for the amount of MAPW’s fee and to directly remit that fee to MAPW in accordance with applicable custody rules. The client’s account custodian has physical custody of client assets, but the SEC deems MAPW to have legal custody over client assets if they are authorized to instruct the custodian to deduct MAPW advisory fees directly from clients’ custodial accounts, when Firm personnel serve as trustee for advisory clients, when Firm serves as a general partner of a private investment fund, and when clients have authorized the Firm to instruct the custodian to transfer assets to third parties pursuant to standing letters of authorization (“SLOA”). MAPW reports having custody of client assets under Item 9 of Part 1 of Form ADV and is required under Rule 206(4)-2 to obtain a custody audit to verify client assets over which the Firm has authority as general partner or trustee. Currently MAPW reports no assets that would qualify as requiring a custody audit. For the remaining assets, the SEC has exempted advisers from the custody audit requirement by rule or no-action relief. Clients will receive account statements directly from the custodian at least quarterly. They will be sent to the email or postal mailing address clients provide to the custodian. Clients should carefully review those statements promptly upon receipt and to compare them with any reports they receive from us. Clients are encouraged to note that the account custodian does not verify the accuracy of MAPW’s advisory fee calculation. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices.” Item 16 – Investment Discretion Clients have the option of providing MAPW with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in MAPW’s client agreement. By granting MAPW investment discretion, a client authorizes MAPW to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of MAPW if MAPW determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for MAPW. See also Item 4(C), Client-Tailored Advisory Services. Item 17 – Voting Client Securities MAPW does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client portfolios. 18  MA Private Wealth Advisors, LLC Disclosure Brochure Item 18 – Financial Information MAPW is not required to disclose any financial information pursuant to this item due to the following: a) MAPW does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) MAPW is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) MAPW has never been the subject of a bankruptcy petition. 19 

Item 1 – Cover Page FIRM BROCHURE PART 2A of FORM ADV, APPENDIX 1 WRAP FEE PROGRAM 1355 San Carlos Avenue, Suite A San Carlos, CA 94070 (650) 232-2021 This wrap fee program brochure provides information about the qualifications and business practices of MA Private Wealth, LLC. If you have any questions regarding the contents of this brochure, please contact our Chief Compliance Officer, Erica Arroyo, by telephone at (650) 232-2021 or by email at erica@maprivatewealth.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. MA Private Wealth, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about MA Private Wealth, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. August 1, 2025  Item 2 – Material Changes Form ADV Part 2A requires registered investment advisers to amend their wrap fee program brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s wrap fee program brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the last annual filing made February 27, 2025, the following material changes were made to this brochure: • • • • • Item 4 was updated to reflect that in June 2025, ownership of MA Private Wealth, LLC was transferred into MAPW Holdings, LLC, which itself is majority owned by MAPW LegacyCO, LLC, majority owned by Martin Miller. Items 4A and 4B were updated to better describe MAPW’s Wrap Program and the role of Schwab and Fidelity, the “Financial Institutions”. Item 4C was updated to disclose the incentive we have to execute trades at certain Financial Institutions. Items 6, 7, and 8 were updated to indicate that MAPW does not currently use Independent Managers, and to further define the authority through which it may elect to do so in the future. Items 9B was updated to disclose MAPW’s relationship with BlackRock Fund Advisors (“BFA”) and the resulting conflicts of interest. In August 2025, Erica Arroyo was named the Chief Compliance Officer. • MA Private Wealth encourages each client to read this Brochure carefully and to call us with any questions you might have.  Item 3 - Table of Contents Item 1 – Cover Page ................................................................................................................................ 1 Item 2 – Material Changes ....................................................................................................................... 2 Item 3 - Table of Contents ....................................................................................................................... 3 Item 4 – Services, Fees and Compensation............................................................................................... 4 A. Description of the Program ......................................................................................................... 4 B. The Program Fee......................................................................................................................... 5 C. Compensation for Recommending the Program ........................................................................... 7 Item 5 – Account Requirments and Types of Clients ................................................................................ 7 Item 6 – Portfolio Manager Selection and Evaluation ............................................................................... 7 A. Advisory Services Offered by MAPW ........................................................................................ 7 B. Client Tailored Advisory Services ............................................................................................... 9 C. The Program ............................................................................................................................... 9 D. Performance-Based Fees and Side-By-Side Management .......................................................... 10 E. Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 10 F. Voting Client Securities ............................................................................................................ 13 Item 7 – Client Information Provided to Portfolio Managers .................................................................. 13 Item 8 – Client Contact with Portfolio Managers ................................................................................... 14 Item 9 – Additional Information ............................................................................................................ 14 A. Disciplinary Information ........................................................................................................... 14 B. Other Financial Industry Activities and Affiliations ................................................................... 14 C. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 14 D. Review of Accounts .................................................................................................................. 15 E. Client Referrals and Other Compensation .................................................................................. 15 F. Financial Information ................................................................................................................ 16  MA Private Wealth, LLC Wrap Fee Program Brochure Item 4 – Services, Fees and Compensation MA Private Wealth Advisors, LLC (“MAPW” or the “Firm”) is a limited liability company organized in the State of Delaware. MAPW is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). MAPW is majority owned by MAPW Holdings, LLC, which itself is majority owned by MAPW LegacyCo, LLC, majority owned by Martin S. Miller. The MAPW Wrap Fee Program (the “Program”) is an investment advisory program sponsored by MAPW. Our Program allows you to pay a single fee that covers advisory services, trade execution, custody and other standard brokerage services. This Brochure describes the Program as it relates to clients receiving services through the Program. In addition to the Program, the Firm offers a variety of advisory services, which include financial planning and consulting services and investment management services under different arrangements then those described in this Brochure. Information about these services is contained in the Firm’s Form ADV Part 2A. Description of the Program A. MAPW provides investment management services as the sponsor and manager of the Program. Accounts managed through this Program are done so in substantially the same manner as those managed under a non- wrap arrangement. The Program primarily allocates client assets among various mutual funds, exchange- traded funds (“ETFs”), individual debt and equity securities, but may also utilize individual fixed income instruments, UITs, in addition to the maintenance of cash or cash equivalent positions for liquidity or other needs in accordance with their stated investment objectives. MAPW is the sole portfolio manager in the Program. Clients of the Program may also receive the other more varied advisory services of the Firm as described in the Firm’s Form ADV Part 2A. Under the Program the client pays a single fee (“Program Fee”) for MAPW’s investment advice, custody and commissions for securities transactions executed through the Program custodian/broker-dealer, as described below. See Additional Fees and Expenses below for information regarding fees and expenses not included in the Program Fee. Prior to receiving services under the Program, clients are required to enter into a written agreement with MAPW setting forth the relevant terms and conditions of the advisory relationship. Clients must also open a new securities brokerage account and complete a new account agreement with Fidelity Brokerage Services LLC (“Fidelity”), or Charles Schwab & Co. (“Schwab”), a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC, both of which are “qualified custodians” as that term is described in Rule 206(4)-2 of the Advisers Act, or another broker-dealer that MAPW approves under the Program (collectively “Financial Institutions”). In addition to the advisory services, the wrap fee program includes certain brokerage services of the Financial Institutions. We are independently owned and operated and not affiliated with Schwab or Fidelity. Schwab and Fidelity will act solely as a broker-dealer and not as an investment advisor to you. Schwab and Fidelity will have no discretion over your account and will act solely on instructions it receives from us, or you. Schwab and Fidelity have no responsibility for our services and undertakes no duty to you to monitor our firm’s management of your account or other services we provide to you. Schwab and Fidelity will hold your assets in a brokerage account and buy and sell securities and execute other transactions when we or you instruct them to. We do not open the account for you. In addition to compensating MAPW for advisory services, the wrap fee you pay us allows us to pay for brokerage and execution services provided by Schwab or Fidelity. 4  MA Private Wealth, LLC Wrap Fee Program Brochure The Program Fee B. We charge a single asset-based fee for services covered by the Program. The fee charged for the program is set forth below. The Program Fee covers MAPW’s advisory services, custody, and commissions for securities transactions effected through Fidelity and Schwab. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. A wrap fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of our wrap fee program to you, including the cost of our investment advice, custody and brokerage services if you purchased them separately, the types of investments held in your account, and the frequency, type and size of trades in your account. Note a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. The program could cost you more or less than purchasing our investment advice and custody/brokerage services separately. In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the agreed-upon Program Fee and any other costs associated with participating in our Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Program. MAPW does not charge its clients higher advisory fees based on their trading activity, but clients should be aware that MAPW may have an incentive to limit its trading activities in client accounts because MAPW is charged for executed trades. MAPW addresses this conflict of interest through this disclosure and by its policies and procedures which work to ensure that client assets are placed in the appropriate advisory service offered by MAPW, or otherwise are placed in accordance with the specific instructions of the client. Cash Positions At any specific point in time, depending upon perceived or anticipated market conditions or events (there being no guarantee that such anticipated market conditions/events will occur), MAPW may maintain cash positions for defensive or other purposes. All cash positions (money markets, etc.) will be included as part of assets under management for purposes of calculating the Program Fee. Fee Schedule MAPW charges an annual Program Fee that is agreed upon with each client and set forth in an agreement executed by MAPW and the client. The Program Fee is based on a percentage of the value of assets under management and the Program Fee for the initial quarter shall be paid, on a pro rata basis, in advance, based on the value of the net Program assets under management at the time the account becomes subject to the Program, including cash, accrued interest, accrued dividends, and securities purchased on margin. For subsequent quarters, the Program Fee shall be paid, in advance, based on the asset value of the client’s Program account(s) as of the last business day of the preceding quarter as provided by third-party sources, such as pricing services, custodians, 5  MA Private Wealth, LLC Wrap Fee Program Brochure fund administrators, and client-provided sources. Following is MAPW’s asset based fee schedule for the Program Fee: PORTFOLIO VALUE Up to $250,000 $1,000,000 $250,001 - $2,500,000 $1,000,001 - $5,000,000 $2,500,001 - $5,000,001 - $10,000,000 $10,000,001 - $20,000,000 $20,000,001 - $30,000,000 $30,000,001 - $40,000,000 Above $40,000,000 BASE FEE 1.50% 1.25% 1.00% 0.85% 0.80% 0.75% 0.70% 0.65% Negotiable Notwithstanding the foregoing, MAPW and the client may choose to negotiate a Program Fee that varies from the schedule set forth above. Factors upon which a different Program Fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. In addition, some legacy clients may be grandfathered under the fee schedules as listed in their individual account agreements in effect at the time they became a client, which may result in fees higher or lower than those listed above. The Program Fee charged by the Firm will apply to all of the client’s assets in the Program, unless specifically excluded in the client agreement. Although MAPW believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. For certain clients, we charge an advisory fee for services provided to held-away accounts, just as we do with client accounts held at our primary custodian(s). The specific fee schedule charged by us is provided in the client’s investment advisory agreement with us. Payment of Fees MAPW generally deducts the program fee from a client’s investment account(s) held at his/her custodian. Upon engaging MAPW to manage such account(s) a client grants MAPW this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or properly calculated. Although clients generally are required to have their investment advisory fees deducted from their accounts, in some cases, MAPW will directly bill a client for program fees if it determines that such billing arrangement is appropriate given the circumstances. MAPW does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. Fees for Financial Planning and Consulting Services MA Private Wealth generally charges a fixed ongoing fee for providing financial planning and 6  MA Private Wealth, LLC Wrap Fee Program Brochure consulting services under a stand-alone engagement. The fee charged for such services are negotiable and depend upon the complexity of a client’s plan and services provided. Clients receive invoices reflecting the amount of the fee due and payable. The terms and conditions of the financial planning and/or consulting engagement are set forth in the client agreement with MA Private Wealth. Fees are due semiannually and billed in arrears in June and December every year, regardless of when the agreement is signed and accepted. MAPW does not prorate or rebate financial planning fees. If during the course of the year, a new client enters into a new Financial Planning agreement, MAPW will not collect prorated fees, and will delay billing until the scheduled June or December billing cycle, whichever comes first. Further, if a client elects to terminate an agreement, there are no rebates given (as billing is in arrears). C. Additional Fees and Expenses Our wrap fee covers our advisory services and most brokerage services provided by Schwab and Fidelity, including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a result, we have an incentive to execute transactions for your account at Schwab or Fidelity. Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark- downs, spreads paid to market makers, fees (such as a commission or markup) for trades executed away from Schwab, Fidelity, or at another broker-dealer, margin interest, wire transfer fees and other cashiering fees and taxes on brokerage accounts and securities transactions. Furthermore, MAPW fees do not cover transaction fees or “trade away” fees imposed for trades placed away from Fidelity or Schwab. Compensation for Recommending the Program D. MAPW does not have any arrangements where it receives an economic benefit from a third party for recommending the Program. Item 5 – Account Requirements and Types of Clients MAPW offers investment advisory services to individuals, including high net worth individuals, families, trusts, and business entities. MAPW does not impose a minimum portfolio size or a minimum initial investment to open a Program account. However, MAPW does reserve the right to accept or decline a potential client for any reason in its sole discretion. Item 6 – Portfolio Manager Selection and Evaluation The Program currently does not select advisers in addition to MAPW, which is the only portfolio manager for the Program. Advisory Services Offered by MAPW A. MAPW provides holistic and personalized financial planning and discretionary and non-discretionary investment advisory services to individuals, including high net worth individuals, and entities, including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement plans. In addition to the Program, MAPW provides the following advisory services. 7  MA Private Wealth, LLC Wrap Fee Program Brochure Investment Management Services MAPW offers investment management services on a discretionary basis and non-discretionary basis. All investment advice provided is customized to each client’s investment objectives and financial needs. MAPW tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. MAPW consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by MAPW to determine the appropriate portfolio asset allocation and investment strategy for the client. Clients are advised to promptly notify MAPW if there are changes in their financial situation. MAPW primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, but may also utilize individual fixed income instruments, UITs, in addition to the maintenance of cash positions for liquidity or other needs in accordance with their stated investment objectives. MAPW, through the authority granted by the client through the executed Investment Management Agreement (“IMA”) and when in the best interest of the client, may further recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“Independent Managers”). Currently MAPW does not utilize the services of Independent Managers, but may do so in the future. The client may be required to enter into a separate agreement with the Independent Manager(s), which will set forth the terms and conditions of the client’s engagement of the Independent Manager. MAPW generally renders services to the client relative to the discretionary selection of Independent Managers. MAPW also assists in establishing the client’s investment objectives for the assets managed by Independent Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by MAPW, if applicable. In certain circumstances, MAPW may implement investment advice on behalf of clients in certain held-away accounts – for example, 401(k) or 529 plan accounts – maintained either at the custodians with whom we have an institutional relationship or at other independent third-party custodians. We have the capability to review, monitor, and manage these held-away accounts in a fashion similar to the way in which we review, monitor, and manage accounts that are not held away. When MAPW provides investment advice to a client regarding a client’s retirement plan account or individual retirement account, MAPW is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way MAPW makes money creates some conflicts with 8  MA Private Wealth, LLC Wrap Fee Program Brochure client interests, so MAPW operates under a special rule that requires the Firm to act in the client’s best interest and not put the Firm’s interest ahead of theirs. Investment Management Services to Retirement Plans MAPW offers discretionary advisory services to qualified plans, which may include profit sharing and 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment policy statements, working with plan service providers, and providing general investment education to plan participants. Financial Planning and Consulting Services MAPW offers personal comprehensive financial planning services to set forth goals, objectives and implementation strategies for the client over the long-term. Depending upon individual client requirements, the comprehensive financial plan will include recommendations related to some or all of the following:  Retirement Planning  Business Planning  Risk Management  Cash Flow Forecasting  Trust and Estate Planning  Charitable Giving  Financial Reporting  Investment Consulting  Insurance Planning  Distribution Planning  Tax Planning  Manager Due Diligence MAPW prepares and provides the financial planning client with a written comprehensive financial plan and performs quarterly, semi-annual or annual reviews of the plan with the client, dependent on the client’s needs in accordance with the financial planning agreement. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. Clients are under no obligation to implement any of the recommendations provided in their written financial plan. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have MAPW implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. MA Private Wealth may recommend clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage MA Private Wealth or its affiliates to provide additional services for compensation. MAPW cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. Client Tailored Advisory Services B. Clients may impose reasonable restrictions on the management of their accounts if MAPW determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for MAPW’s management efforts. C. The Program 9  MA Private Wealth, LLC Wrap Fee Program Brochure As described above, MAPW is currently the sole portfolio manager of the Program. The Program utilizes primarily individual equity securities and ETFs, but may also utilize other securities, such as mutual funds, individual fixed income instruments, UITs, in addition to the maintenance of cash positions for liquidity or other needs. Performance-Based Fees and Side-By-Side Management D. MAPW does not charge performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of a capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. MAPW’s fees are calculated as described in Item 5 above. Methods of Analysis, Investment Strategies and Risk of Loss E. Methods of Analysis, Investment Strategies MAPW employs various tools and materials in its analysis of investments for the Program. Security analysis methods include fundamental analysis of a security’s historical and present data, as well as relevant information regarding the issuer, such as management, competitive advantages, competitors and markets. In addition, MAPW reviews various market and economic data in determining the securities utilized for the Program. Risk of Loss Investing in securities involves a significant risk of loss which clients should be prepared to bear. MAPW’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s Program account. There can be no assurance that the client’s or the Program’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small- stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset- backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a ETF will achieve its investment objective. Past performance of investments is no guarantee of future results. 10  MA Private Wealth, LLC Wrap Fee Program Brochure Additional risks involved in the securities recommended/utilized by MAPW as part of the Program include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. • Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. • Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset 11  MA Private Wealth, LLC Wrap Fee Program Brochure values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held. • Management risk, which is the risk that the investment techniques and risk analyses applied by MAPW may not produce the desired results and that legislative, regulatory, or tax developments, affect the investment techniques available to MAPW. There is no guarantee that a client’s investment objectives will be achieved. • Real estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. • Investment companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Commodity risk, generally commodity prices fluctuate for many reasons, including changes in market and economic conditions or political circumstances (especially of key energy-producing and consuming countries), the impact of weather on demand, levels of domestic production and imported commodities, energy conservation, domestic and foreign governmental regulation (agricultural, trade, fiscal, monetary and exchange control), international politics, policies of OPEC, taxation and the availability of local, intrastate and interstate transportation systems and the emotions of the marketplace. The risk of loss in trading commodities can be substantial. • Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of MAPW and its service providers. The computer systems, networks and devices used by MAPW and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other 12  MA Private Wealth, LLC Wrap Fee Program Brochure financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. • Alternative investments/private funds risk, investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • • loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; lack of liquidity in that there may be no secondary market for the investment and none expected to develop; • volatility of returns; • restrictions on transferring interests in the investment; • potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized; less regulation and higher fees than mutual funds; • absence of information regarding valuations and pricing; • delays in tax reporting; • • risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments. • Closed-end funds risk, Closed-end funds typically use a high degree of leverage. They may be diversified or non-diversified. Risks associated with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of leverage. Additionally, closed-end funds may trade below their net asset value. Clients are advised that they should only commit assets for management in the Program that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. MAPW does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Use of Independent Managers MAPW may in the future select certain Independent Managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, MAPW generally may not have the ability to supervise the Independent Managers on a day-to-day basis. Voting Client Securities F. MAPW does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client Program portfolios. Item 7 – Client Information Provided to Portfolio Managers MAPW is currently the sole portfolio manager under the Program. While not currently utilizing other managers, in the future, clients participating in the Program may also grant MAPW the authority within their executed IMAs to discuss certain non-public information with select Independent Managers that may be engaged to manage their accounts. Depending upon the specific arrangement, the Firm may be 13  MA Private Wealth, LLC Wrap Fee Program Brochure authorized to disclose various personal information including, without limitation: names, phone numbers, addresses, social security numbers, tax identification numbers and account numbers. MA Private Wealth may also share certain information related to its clients’ financial positions and investment objectives in an effort to ensure that the Independent Managers’ investment decisions remain aligned with its clients’ best interests. This information is communicated on an initial and ongoing basis, or as otherwise necessary to the management of its clients’ portfolios. Item 8 – Client Contact with Portfolio Managers MAPW is currently the sole portfolio manager under the program. No restrictions are placed on a client’s ability to contact or consult with MAPW. If Independent Mangers are ever utilized pursuant to the authority granted by the client in the IMA, clients could generally contact the Independent Managers managing their portfolios through MA Private Wealth by providing the Firm with written request and identification of the questions or issues to be discussed with the Independent Managers. After receiving the client’s written request, MA Private Wealth, at its sole discretion, would contact the Independent Managers for the client or arrange for the Independent Managers and the client to communicate directly, where applicable Item 9 – Additional Information Disciplinary Information A. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. MAPW has no information applicable to this Item. B. Other Financial Industry Activities and Affiliations MAPW utilizes the services of unaffiliated model provider BlackRock Fund Advisors (“BFA”) for research and materials. BFA provides models and materials at no charge to MAPW, as long as MAPW maintains 250 million in assets under management across the Models, subject to BFA’s discretion. MAPW has no other business relationship with BFA that is material to our advisory business except as outlined in this brochure. Advisor pays no direct compensation to Blackrock or its affiliates, however clients will indirectly bear fund expenses associated with their allocation to specific BlackRock Funds. A Model will include BlackRock Funds, some of which will pay fees to BlackRock for providing management, administrative, or other services. BFA may target maximum exposure to BlackRock Funds, and has an incentive to select BlackRock affiliated funds with higher fees over BlackRock affiliated funds with lower fees, as the fees that BlackRock and its affiliates receive from investments in the Affiliated BlackRock funds constitute BlackRock’s compensation with respect to the model portfolios. Although MAPW clients are not required to utilize BlackRock Funds in their portfolios, the use of such is a conflict as this practice could cause MAPW to focus on BlackRock Funds in order to continue receiving no cost research materials. MAPW attempts to mitigate this conflict by acting in the client’s best interest, conducting their own due diligence, and exercising their fiduciary duty when making investment recommendations. C. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MAPW has a Code of Ethics (the “Code”) which requires MAPW’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other 14  MA Private Wealth, LLC Wrap Fee Program Brochure things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to MAPW for review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. MAPW will provide a copy of the Code of Ethics to any client or prospective client upon request. Review of Accounts D. While Program accounts are monitored on an ongoing basis, MAPW’s investment adviser representatives seek to have at least one annual meeting with each client to conduct a formal review of the clients’ Program, (and other, if applicable) accounts. Program accounts are reviewed for consistency with the Program strategy and other parameters set forth for the account and to determine if any adjustments need to be made. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in a Program account holder’s personal, tax or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company- specific events. Clients are encouraged to notify MAPW of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, or time horizon. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the Program account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each brokerage account transaction unless confirmations have been waived. MAPW may also determine to provide account statements and other reporting to clients on a periodic basis. MAPW also provides account reports during client meetings. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by MAPW. MAPW statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. E. Client Referrals and Other Compensation Client Referrals MAPW does not currently provide compensation to non-supervised third-party solicitors. 15  MA Private Wealth, LLC Wrap Fee Program Brochure Other Compensation As described above, MAPW requires that Program clients utilize Fidelity or Schwab as the custodian/broker-dealer for their Program account(s). In exchange for using or otherwise recommending the services of Fidelity or Schwab, MAPW may receive, without cost, computer software and related systems support that allows MAPW to monitor and service its clients’ accounts maintained with Fidelity and Schwab. Fidelity and Schwab also make available to the Firm products and services that benefit the Firm but may not directly benefit the client or the client’s account. These products and services assist MAPW in managing and administering client accounts. They include investment research, both Fidelity and Schwab’s own and that of third parties. MAPW may use this research to service all or some substantial number of client accounts, including accounts not maintained at Fidelity or Schwab. In addition to investment research, Fidelity and Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. • • provide pricing and other market data; • • Fidelity and Schwab also offer other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events; technology, compliance, legal, and business consulting; and • • • publications and conferences on practice management and business succession. Fidelity and Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to the Firm. Fidelity and Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. The benefits received by MAPW through its participation in the Fidelity or Schwab custodial platforms do not depend on the amount of brokerage transactions directed to Fidelity or Schwab. In addition, there is no corresponding commitment made by MAPW to Fidelity or Schwab to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of participation in the program. While as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at Fidelity or Schwab will be based in part on the benefit to MAPW of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity or Schwab. The receipt of these benefits, if any, creates a potential conflict of interest and may indirectly influence MAPW’s choice of Fidelity or Schwab for custody and brokerage services. F. Financial Information 16  MA Private Wealth, LLC Wrap Fee Program Brochure MAPW is not required to disclose any financial information pursuant to this item due to the following: a) MAPW does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) MAPW is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) MAPW has never been the subject of a bankruptcy petition. 17