MacH-1 Financial Group, LLC

Mach-1 Financial Group, LLC CRD No. 298195 1001 S. 52nd Street, Suite 100 Rogers, AR 72758 Website: https://mach-1financial.com/ Telephone: 479-876-2100 Email: info@mach-1financial.com March 30, 2026 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Mach-1 Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at 479- 876-2100. 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. Registration with the SEC or state regulatory authority does not imply a certain level of skill or expertise. Additional information about Mach-1 Financial Group, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated March 22, 2025, we have the following material changes to report: This brochure has been revised to limit its scope to estate planning services offered through Wealth.com and to add disclosure regarding fees charged by Mach-1 Financial for such services. All investment advisory and wrap fee services are disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure. For a complete copy of our current brochure, please contact the Chief Compliance Officer at the telephone number listed on the Cover Page. 2  Item 3 Table of Contents Item 1 Cover Page Item 2 Summary of Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Requirements for State-Registered Advisers Page 1 Page 2 Page 3 Page 4 Page 5 Page 5 Page 5 Page 6 Page 6 Page 6 Page 6 Page 6 Page 7 Page 7 Page 7 Page 7 Page 7 Page 7 Page 8 3  Item 4 Advisory Business Mach-1 Financial Group Mach-1 Financial Group, LLC ("Mach-1 Financial," and/or "the firm") is an Arkansas limited liability corporation owned by Mach-1 Holdings, Inc., Matthew Walters, CEO, and James Mackey, President and COO, and indirectly owned by David A. Lee as Trustee of The Lee Family Trust. The firm was first registered as an investment adviser in February 2020, and provides asset management services to high net-worth individuals, individuals, trusts, corporations, partnerships, and other legal entities. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Mach-1 Financial Group, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Estate Planning Access Mach-1 Financial provides estate planning referral and coordination services exclusively through a third-party technology platform operated by Wealth.com ("Wealth"). Estate Planning services generally entail the preparation of a revocable trust, will, living will, financial and health care powers of attorney, HIPPA documents, and in some cases, more advanced estate plans or estate tax plans, as requested by the client and to the extent applicable to the client's circumstances. Through this arrangement, Mach-1 Financial advisors refer clients to Wealth's estate planning platform, which allows clients to create, manage, and maintain estate planning documents through an online interface. Clients are guided through the estate planning process by Wealth and, where applicable, by unaffiliated attorneys made available through Wealth's platform. Clients electing to use the Wealth.com optional hybrid model can start the process digitally and, for a fee borne by the client, consult live with one of Wealth.com's local trust & estates attorney partners. No portion of such fee is paid to Mach-1 Financial. Mach-1 Financial does not provide legal advice, does not draft estate planning documents, and does not make legal determinations or selections on behalf of clients. Advisors can receive read-only access to a client's Wealth account for purposes of monitoring and identifying potential planning considerations. Tax Planning Services Mach-1 Financial also provides access to a tax planning professional. The tax planning and coordination services are limited in scope and include discussions on general tax planning concepts and the potential tax implications of investment strategies. We do not provide tax or legal advice, do not prepare tax returns, and do not represent clients before taxing authorities. Mach-1 can coordinate with third-party CPA firms, and in certain circumstances, Mach-1 will cover the cost of the third-party CPA firm. Clients are encouraged to consult their independent tax professionals regarding their specific tax circumstances. Scope Limitation / Excluded Services This Disclosure Brochure does not describe investment management services, wrap fee programs, portfolio management, retirement plan services, rollover recommendations, or any other investment advisory services offered by Mach-1 Financial. All investment advisory and wrap fee services are offered exclusively through Appendix 1 – the Wrap Fee Program Brochure, which should be reviewed carefully by clients engaging Mach-1 Financial for those services. 4  Sponsor and Manager of Wrap Program Mach-1 Financial Group is the portfolio manager and sponsor of a Wrap Fee Asset Management Program, which is a type of asset management program where clients pay a single fee that includes asset management fees and certain other brokerage costs. The overall cost you will incur if you participate in our Wrap Fee Program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. Mach-1 Financial Group manages wrap fee program accounts on a discretionary basis. Wrap fee program accounts are typically more appropriate for active accounts and are managed accordingly. Transactions for your account must be executed by one of our recommended custodians and/or broker-dealers. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by custodians or other broker-dealers, and the advisory fees charged by investment advisers. For more information concerning the Wrap Fee Program see Appendix 1 – the Wrap Fee Program Brochure. Client Assets Under Management As of December 31, 2025, we provide continuous management services for $546,345,461 in client assets on a discretionary basis. Item 5 Fees and Compensation Estate Planning Access Mach-1 Financial charges a fee for estate planning services provided through Wealth's platform. The fee will not exceed $1,000 and will be paid as agreed to in the client's estate planning agreement. The fee is negotiable and can be waived in certain circumstances. We will not require prepayment of a fee more than six months in advance and in excess of $500. Clients who elect to consult with unaffiliated attorneys made available through Wealth's platform can incur additional legal fees payable directly to the attorney or to Wealth, as applicable. Fees charged by third-parties are covered by Mach-1 in certain circumstances. Fees associated with Mach-1 Financial's investment advisory and wrap fee services are not described in this brochure and are disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure. External Compensation for the Sale of Insurance to Clients Mach-1 Financial's advisory professionals are compensated primarily through a salary and bonus structure and through asset-based fees generated from client accounts. Some of Mach-1 Financial's advisory professionals receive commission-based compensation for the sale of insurance products. Please see Item 10 for detailed information and conflicts of interest. Item 6 Performance-Based Fees and Side-By-Side Management Mach-1 Financial does not charge performance-based fees. Item 7 Types of Clients Mach-1 Financial offers the estate planning referral services described in this brochure primarily to individuals and families seeking estate planning solutions through Wealth's platform. 5  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss This Item is not applicable to the estate planning services described in this brochure. Investment strategies, methodologies, and risks are disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure, where applicable. Item 9 Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item. Item 10 Other Financial Industry Activities and Affiliations Wealth.com Mach-1 Financial has purchased access to Wealth.com through an annual license, which allows our advisors to provide estate planning services through Wealth's technology platform. Mach-1 Financial charges clients a fee for estate planning services provided through Wealth, subject to a maximum fee as disclosed under Item 5 of this brochure. Clients can also incur separate legal fees if they choose to engage unaffiliated attorneys made available through Wealth's platform. This arrangement creates a potential conflict of interest because Mach-1 Financial receives compensation in connection with clients' use of the Wealth platform. Clients are under no obligation to use Wealth and may obtain estate planning services from providers of their choosing. Insurance Sales We are affiliated with David A Lee, Inc., a licensed insurance agency, through common control and ownership. Therefore, certain persons providing investment advice on behalf of our firm are licensed as insurance agents. These persons, and/or David A Lee, Inc., will earn commission-based compensation for selling insurance products, including insurance products they sell to you, and thus a conflict of interest exists. Insurance commissions earned by these persons are separate from our advisory fees. See the Fees and Compensation section in this brochure for more information on the compensation received by insurance agents who are affiliated with our firm. Mach-1 Financial strives to put its clients' interests first and foremost, and clients may utilize any insurance carrier or insurance agency they desire. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Mach-1 Financial has adopted a Code of Ethics governing the conduct of its advisory personnel. The estate planning services described in this brochure do not involve securities transactions or personal trading activity. A copy of the Code of Ethics is available upon request. Item 12 Brokerage Practices This Item is not applicable to the estate planning services described in this brochure. 6  Brokerage practices related to investment advisory services are disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure. Item 13 Review of Accounts Mach-1 Financial does not provide ongoing account monitoring or periodic reviews in connection with the estate planning services described in this brochure. Any review of investment accounts is disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure. Item 14 Client Referrals and Other Compensation Other than the estate planning fee described in Item 5, Mach-1 Financial does not receive compensation from third parties in connection with the estate planning services described in this brochure. Referral and compensation arrangements related to investment advisory services are disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure. Item 15 Custody Mach-1 Financial does not have custody of client funds or securities in connection with the estate planning services described in this brochure. Custody disclosures related to investment advisory services are contained in Appendix 1 – the Wrap Fee Program Brochure. Item 16 Investment Discretion Mach-1 Financial does not exercise investment discretion in connection with the estate planning services described in this brochure. Investment discretion related to advisory services is disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure. Item 17 Voting Client Securities Mach-1 Financial does not vote client securities in connection with the estate planning services described in this brochure. Proxy voting practices related to investment advisory services are disclosed exclusively in Appendix 1 – the Wrap Fee Program Brochure. Item 18 Financial Information Mach-1 Financial does not require prepayment of estate planning fees more than six months in advance and does not have a financial condition reasonably likely to impair its ability to meet commitments to clients. 7  Item 19 Requirements for State-Registered Advisers Mach-1 Financial is a federally registered investment adviser; therefore, this Item is not applicable. 8 

Mach-1 Financial Group, LLC CRD No. 298195 1001 S. 52nd Street, Suite 100 Rogers, AR 72758 Telephone: 479-876-2100 https://mach-1financial.com/ Email: info@mach-1financial.com March 30, 2026 PART 2A - APPENDIX 1 WRAP FEE PROGRAM BROCHURE This wrap fee program brochure provides information about the qualifications and business practices of Mach-1 Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at 479-876-2100. 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. Registration with the SEC or State Regulatory Authority does not imply a certain level of skill or expertise. Additional information about Mach-1 Financial Group, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated, March 22, 2025, we have the following material changes to report: • This Appendix 1 reflects a comprehensive update to the Firm's Disclosure Brochure. All sections of the brochure have been materially revised to update, clarify, and enhance disclosures regarding the Firm's business practices, services, fees and compensation arrangements, conflicts of interest, affiliated relationships, and compliance practices. These changes were made to ensure the brochure accurately reflects the Firm's current operations and regulatory disclosure obligations. Because the updates affect each section of the brochure, clients are encouraged to review the Disclosure Brochure in its entirety. For a current copy of our Appendix 1 brochure, please contact the Chief Compliance Officer at the telephone number listed on the Cover Page. 2  Item 3 Table of Contents Item 1 Cover Page Item 2 Summary of Material Changes Item 3 Table of Contents Item 4 Services, Fees, and Compensation Item 5 Account Requirements and Types of Clients Item 6 Portfolio Manager Selection and Evaluation Item 7 Client Information Provided to Portfolio Managers Item 8 Client Contact with Portfolio Managers Item 9 Additional Information Item 10 Requirements for State-Registered Advisers Page 1 Page 2 Page 3 Page 4 Page 10 Page 10 Page 13 Page 13 Page 14 Page 20 3  Item 4 Services, Fees, and Compensation Mach-1 Financial Group Mach-1 Financial Group, LLC ("Mach-1 Financial," and/or "the firm") is an Arkansas limited liability corporation owned by Mach-1 Holdings, Inc., Matthew Walters, CEO, and James Mackey, President and COO, and indirectly owned by David A. Lee as Trustee of The Lee Family Trust. The firm was first registered as an investment adviser in February 2020 and provides asset management services to high net-worth individuals, individuals, trusts, corporations, partnerships, and other legal entities. As used in this brochure, the words "we," "our," and "us" refer to Mach-1 Financial Group, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person in this brochure. Our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. We offer asset management services through a wrap-fee program ("Program") as described in this wrap fee program brochure to prospective and existing clients. We are the sponsor and investment adviser for the Program. A wrap-fee program is a type of investment program that provides clients with asset management and brokerage services for one all-inclusive fee. If you participate in our wrap fee program, you will pay our firm a single fee, which includes money management fees, certain transaction costs, and custodial and administrative costs. You are not charged separate fees for the respective components of the total services. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the Program. Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. Advisory Services Offered We offer discretionary asset management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary asset management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. This Program allows you to choose an investment option that employs a model portfolio developed by our firm that is diversified among investment styles and/or asset classes. We will use the information we gather to develop a strategy that enables our firm to customize an investment portfolio for you in accordance with your risk tolerance and investment objectives. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance and re- balance your investments as required by changes in market conditions and in your financial circumstances. 4  Assets for program accounts are held at Charles Schwab & Co., Inc. ("Schwab"), Fidelity Brokerage Services, LLC ("Fidelity"), LPL Financial LLC ("LPL"), and MTG LLC, dba Betterment Securities ("Betterment Securities"), all members FINRA/SIPC, (together the "Custodian") as custodian. The Custodian for the Program also acts as the executing broker/dealer for transactions placed in Program accounts and provides other administrative services as described throughout this Brochure. To compare the cost of the wrap fee program with non-wrap fee asset management services, you should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by the Custodian for the Program and the advisory fees charged by investment advisers. Ascent - Automated Advisory Services Ascent is Mach-1 Financial Group's automated online service built on Betterment's technology platform that guides clients through the entire investment management process and provides management services. Clients subscribing to the Ascent service authorize Mach-1 Financial Group to select money managers to implement our proprietary portfolio models. As part of the Ascent investment management service, clients complete an online personal risk tolerance assessment and provide additional information about their financial goals. Clients can also submit or modify risk preferences, investment objectives, investment size, and any other restrictions for their accounts directly through the online platform. Based on the information provided and their choices, the appropriate model portfolio is selected for the client. We generally create diversified model portfolios of investments consisting of low-cost exchange traded funds ("ETFs"), mutual funds, and other similar equity-related index funds, stocks, or investment products tailored to the client's specific needs. Information about the client's model portfolio is available on the online platform, which includes their investment style, objectives, and a list of ETFs and other investments with shares that are included in and traded through them. The money managers will periodically rebalance client model portfolios based upon the client's individual needs, stated goals, and objectives. Before selecting money managers, we make sure that they are properly licensed or registered. Clients who subscribe to this service will enter into a dual contract with us and the money manager. Financial Planning Services As part of the Program, we offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. We will meet with you to gather information about your financial circumstances and objectives. We also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. Tax Planning Services Mach-1 Financial also provides access to a tax planning professional. The tax planning and coordination services are limited in scope and include discussions on general tax planning concepts and the potential tax implications of investment strategies. We do not provide tax or legal advice, do not prepare tax returns, and do not represent clients before taxing authorities. Mach-1 can coordinate 5  with third-party CPA firms, and in certain circumstances, Mach-1 will cover the cost of the third-party CPA firm. Clients are encouraged to consult their independent tax professionals regarding their specific tax circumstances. Changes in Your Financial Circumstances In providing the contracted services, we are not required to verify any information we receive from you or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume that there are no restrictions on our services, other than to manage your account in accordance with your designated investment objectives, risk tolerance, and time horizon (collectively, "investment parameters"). It is your responsibility to promptly notify us if there are ever any changes in your financial situation or investment parameters for the purpose of reviewing, evaluating, and/or revising our previous recommendations and services. The Program Fee We charge an annual "wrap-fee" for participation in the Program depending upon the market value of your assets under our management. You are not charged separate fees for the different components of the services provided by the Program. Our firm pays all trade expenses of trades placed on your behalf. Our Program fee includes the fee we pay to any portfolio manager for their management of your account and the Custodian's transaction or execution costs. Assets in each of your account(s) are included in the fee assessment unless specifically identified in writing for exclusion. In special circumstances, and in our sole discretion, we may negotiate a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention, etc.). Mach-1 Financial will charge a fee for its advisory services based on the value of the account not to exceed the annual percentages below. Fees are negotiable. The maximum total fee charged for the Mach-1 Financial Group's Wrap Fee Program will not exceed 1.85% of assets under management. Annual Program Fee 1.85% Max. The maximum total fee charged for our Ascent service will not exceed 0.75% of assets under management. This fee is divided between our firm and Betterment Securities. Annual Program Fee 0.75% Max. Asset-based fees are subject to the investment advisory agreement between the client and Mach-1 Financial. Such fees are typically payable monthly in arrears or quarterly in advance (for LPL accounts). The specific billing methodology will be disclosed in the Investment Advisory Agreement signed by the client. The fees are based on the market value of the assets in the account(s) on the last day of the immediately preceding month or the average daily balance, subject to the custodian having this capability. If the applicable custodian does not offer average daily pricing, then we will bill in arrears based upon the closing month's portfolio value. For LPL accounts, fees are billed quarterly in advance based on the market value of the assets in the account(s) on the last day of the immediately preceding quarter. No adjustments for significant contributions or withdrawals will be made. The fees 6  will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar month. The foregoing fees will be in effect until 30 days after Mach-1 has provided a notice to the Client about a change in the Mach-1 Fees As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than those charged by others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower (or higher) rates. A client may be able to obtain some or all of the types of services available through our firm's wrap fee program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown above. Additional Fees And Expenses Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. These fees include charges for all transaction costs such as commissions on purchase and sales of stocks, bonds, exchange-traded funds and options, trade-away fees on bonds and mutual fund transactions fees. Except as otherwise provided below, client will incur no charges other than Mach-1 Financial's fee described above in connection with the maintenance of and activity in client's account. The Program fee does not include annual account fees, technology fees, or other administrative fees, such as wire fees, charged by Managers or brokerage firms; certain odd-lot differentials, transfer taxes, transaction fees mandated by the Securities Act of 1934, postage and handling fees, and charges imposed by law with regard to transactions in the Client's account; and advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds), closed-end investment companies or other managed investments, if any, held in Client's account. The Program fee also does not cover certain costs associated with securities transactions in the over-the-counter market, such as fixed income securities where Manager must approach a dealer or market maker to purchase or sell a security. Such costs include the dealer's mark-up, mark-down or spread and odd-lot differentials or transfer taxes imposed by law. Mach-1 Financial's advisory professionals are compensated primarily through a salary and bonus structure and through asset-based fees generated from client accounts. Certain Mach-1 Financial's advisory professionals receive commission-based compensation for the sale of insurance products. Please see Item 9 for detailed information and conflicts of interest. Certain persons providing investment advice on behalf of our firm are registered representatives with LPL Financial, LLC a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. In their capacity as registered representatives, these persons receive compensation in connection with the purchase and sale of securities or other investment products, including asset-based sales charges, service fees or 12b-1 fees, for the sale or holding, of mutual funds. Please see Item 9 for detailed information and conflicts of interest. Payment of Fees We will deduct our fee directly from your account through the qualified Custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified Custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. 7  Termination of Advisory Relationship You may terminate the wrap fee program agreement upon 30 days' written notice to our firm. You will incur a pro-rata charge for services rendered prior to the termination of the investment advisory agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. After the investment advisory agreement has been terminated, transactions are processed at the prevailing brokerage rates/fees. You become responsible for monitoring your own assets and our firm has no further obligation to act upon or to provide advice with respect to those assets. Wrap Fee Program Disclosures • The benefits under a wrap fee program depend, in part, upon the size of the account, the • management fee charged, and the number of transactions likely to be generated in the account. For example, a wrap fee program may not be suitable for accounts with little trading activity. In order to evaluate whether a wrap fee program is suitable for you, you should compare the Program Fee and any other costs of the Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and other execution costs, and custodial services comparable to those provided under the Program. In considering the investment programs described in this brochure, you should be aware that participating in a wrap fee program may cost more or less than the cost of purchasing advisory, brokerage, and custodial services separately from other advisers or broker-dealers. • Our firm and Associated Persons receive compensation as a result of your participation in the Program. This compensation may be more than the amount our firm or the Associated Persons would receive if you paid separately for investment advice, brokerage, and other services. Accordingly, a conflict of interest exists because our firm and our Associated Persons have a financial incentive to recommend the Program. • Similar advisory services may be available from other registered investment advisers for lower fees. Brokerage Practices If you participate in the Program, you will be required to establish an account with our Wrap Program Custodian. If you do not direct our firm to execute transactions through our Wrap Program Custodian, we will not be able to accept your account. Not all advisers require their clients to direct brokerage. We believe our Wrap Program Custodian provides quality execution services based on several factors, including, but not limited to, the ability to provide professional services, reputation, experience and financial stability. Our selection of Custodian is based on many factors, including the level of services provided, the Custodian's financial stability, and the cost of services provided by the Custodian to our clients, which includes the yield on cash sweep choices, commissions, custody fees and other fees or expenses. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements. Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account Custodian. As such, we will also have access to research products and services from your account Custodian and/or other brokerage firm. These products include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision- making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with 8  soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Additional Disclosure Concerning Wrap Programs Current business practices of the broker-dealer/custodian(s) we use has led to the reduction or elimination of many transaction charges (commissions). Therefore, our commission costs for trading in certain types of securities within the wrap fee program have been reduced or eliminated which means we retain a larger portion of the advisory fee we charge you, depending on the types of securities transacted in your account. This presents a conflict of interest as we have not reduced our fees to you in conjunction with these savings. We have no way of predicting how the custodian will assess transaction costs in the future, and trading costs may be higher or lower. As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than those charged by others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower (or higher) rates. A client may be able to obtain some or all of the types of services available through our firm's wrap fee program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown above. We believe our wrap fee is fair and reasonable based on the services we provide and the advice we deliver. Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. 9  Client Assets Under Management As of December 31, 2025, we provide continuous management services for $546,345,461 in client assets on a discretionary basis. Item 5 Account Requirements and Types of Clients Mach-1 Financial is an independent investment management firm providing asset management services to various types of clients including individuals, including high net worth individuals, trusts, corporations, partnerships, and other legal entities. In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your account if it falls below a minimum size and we determine, in our sole opinion, is too small to manage effectively. Item 6 Portfolio Manager Selection and Evaluation The Firm Acts as Both a Wrap Fee Sponsor and Portfolio Manager Mach-1 Financial Group is the sponsor and sole portfolio manager for the Program. Refer to Services, Fees, and Compensation for additional disclosures on costs associated with your participation in the Program. Performance-Based Fees and Side-by-Side Management Mach-1 Financial does not charge performance-based fees. Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. There is no guarantee that any specific investment or strategy will be profitable for a particular client. Clients will have access to securities Portfolios consisting of stocks, bonds, mutual funds, exchange- traded funds, and other securities and/or contracts relating to the same that are developed, maintained, and modified by Mach-1 Financial Group. Mach-1 Financial utilizes additional independent third parties to assist it in recommending to clients and monitoring of the model portfolios and strategies as appropriate under the circumstances. Our investment strategies and advice can vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. 10  Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Other Risk Considerations When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all-inclusive, but should be considered carefully by a prospective client before retaining our services. Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell the investment at all. Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time when the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or are nearing retirement. Security-Specific Material Risks There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one Manager, one type of investment instrument (equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain, but also offer the potential for significant loss. Money Market Funds: A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, there is no guarantee that the share price will stay at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S. 11  Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than you expected to earn, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tends to be less than long term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its underlying index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their underlying Indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its underlying index, or its weighting of investment exposure to such securities may vary from that of the underlying index. Some ETFs may invest in securities or financial instruments that are not included in the underlying index, but which are expected to yield similar performance. Investment Discretion Clients grant a limited power of attorney to Mach-1 with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, Mach-1 will exercise full discretion as to the nature and type of securities to be purchased and sold, and the amount of securities for such transactions. Investment limitations may be designated by the client as outlined in the investment advisory agreement. In addition, subject to the terms of its investment advisory agreement, Mach-1 may be granted discretionary authority for the retention of independent third-party sub-advisers. Investment limitations may be designated by the client as outlined in the investment advisory agreement. Betterment uses algorithms to advise clients on our Ascent platform and manage their accounts. These algorithms are developed, overseen, and monitored by Betterment's investment advisory personnel. Betterment periodically rebalances Participant portfolios so that in the face of fluctuating 12  market prices each Participant's portfolio remains within a range of the target allocation. Betterment also offers optional automated asset location services for Participants who also open a Betterment Retail account. Proxy Voting Mach-1 Financial does not take discretion with respect to voting proxies on behalf of its clients. Mach-1 Financial will endeavor to make recommendations to clients on voting proxies regarding shareholder vote, consent, election or similar actions solicited by, or with respect to, issuers of securities beneficially held as part of Mach-1 Financial supervised and/or managed assets, but in no event will the firm take discretion with respect to voting proxies on behalf of its clients. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. For assets managed on the Ascent platform, Participants delegate to Betterment the authority to receive and vote all proxies and related materials. Betterment will only vote on proxies and respond to corporate actions associated with securities that Betterment recommends be purchased for client accounts. Except as required by applicable law, Mach-1 Financial will not be obligated to render advice or take any action on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Mach-1 Financial has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. Mach-1 Financial also has no duty to evaluate a client's eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Mach-1 Financial has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where Mach-1 Financial receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner. Item 7 Client Information Provided to Portfolio Managers In order to provide the Program services, we will share your private information with your account custodian. We may also provide your private information to mutual fund companies and/or private managers as needed. We will only share the information necessary in order to carry out our obligations to you in servicing your account. We share your personal account data in accordance with our privacy policy as described below. Item 8 Client Contact with Portfolio Managers The firm encourages communication with its clients and does not limit or condition the amount of time clients can spend with the firm's advisory professionals. You should contact your advisory representative with respect to changes in your investment objectives, risk tolerance, or requested restrictions placed on the management of your Program assets. 13  Item 9 Additional Information Disciplinary and Other Financial Activities and Affiliations Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item. Other Financial Industry Activities and Affiliations Registrations With Broker-Dealers Certain persons providing investment advice on behalf of our firm are registered representatives with LPL Financial, LLC a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. In their capacity as registered representatives, these persons receive compensation in connection with the purchase and sale of securities or other investment products, including asset-based sales charges, service fees or 12b-1 fees, for the sale or holding, of mutual funds. Compensation earned by these persons in their capacities as registered representatives is separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice to advisory clients on behalf of our firm who are registered representatives have an incentive to recommend investment products based on the compensation received rather than solely based on your needs. Persons providing investment advice to advisory clients on behalf of our firm can, as registered representatives of LPL, select or recommend mutual fund investments in share classes that pay 12b-1 fees when clients are eligible to purchase share classes of the same funds that do not pay such fees and are less expensive. This presents a conflict of interest. You are under no obligation, contractually or otherwise, to purchase securities products through any person affiliated with our firm who receives compensation described above. We have a fiduciary duty to act in our client's best interest including the duty to seek best execution. Therefore, our mutual fund selection and recommendation process takes into consideration several factors in order to meet this requirement. See the Brokerage Practices section for additional information on our mutual fund share class selection process. Insurance Sales We are affiliated with David A Lee, Inc., a licensed insurance agency, through common control and ownership. Therefore, certain persons providing investment advice on behalf of our firm are licensed as insurance agents. These persons, and/or David A Lee, Inc., will earn commission-based compensation for selling insurance products, including insurance products they sell to you, Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. You are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with Mach-1 Financial. Mach-1 Financial strives to put its clients' interests first and foremost, and clients may utilize any insurance carrier or insurance agency they desire. Material Relationships Maintained by this Advisory Business and Conflicts of Interest AE Wealth Management, LLC AE Wealth Management, LLC provides certain back office support and may serve as a Sub-adviser for strategies selected or recommended by Mach-1 Financial. 14  Betterment At Work As part of Mach-1 Financial's relationship with the Betterment Entities, Betterment may offer Mach-1 services intended to help us manage and further develop our business enterprise, such as access to webinars and advice about using the Betterment at Work platform. Betterment may offer different or expanded services in the future. These services could create an incentive for Mach-1 to recommend that our Clients invest through the Betterment at Work platform. This is a potential conflict given that our interest in recommending Betterment could be influenced by your receipt of B4B's, Betterment's, and Betterment Securities' services to our business. Additionally, Betterment may offer discounted pricing to our Clients based on the total combined assets of all of our firm's Clients on the Betterment at Work platform. This is a potential conflict of interest, to the extent that our firm's compensation increases on account of this fee discounting structure. Other potential conflicts may exist regarding Mach-1 Financial's use of the Betterment at Work platform. Code of Ethics, Brokerage Trading Practices, Account Reviews, and Financial and Related Matters Code of Ethics Description In accordance with the Advisers Act, the firm has adopted policies and procedures designed to detect and prevent insider trading. In addition, the firm has adopted a Code of Ethics (the "Code"). Among other things, the Code includes written procedures governing the conduct of the firm's advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the Chief Compliance Officer of the firm. The firm will send clients a copy of its Code of Ethics upon written request. The firm has policies and procedures in place to ensure that the interests of its clients are given preference over those of the firm, its affiliates, and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest The firm does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm's inventory or buying stocks from advisory clients into a firm's inventory). In addition, the firm does not recommend any securities to advisory clients in which it has some proprietary or ownership interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest The firm, its affiliates, employees and their families, trusts, estates, charitable organizations and retirement plans established by it may purchase the same securities as are purchased for clients in their Portfolios in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: • owned by the client, or • considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which the firm specifically prohibits. The firm has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: require our advisory representatives and employees to act in the client's best interest, • • prohibit fraudulent conduct in connection with the trading of securities in a client account • prohibit employees from personally benefitting by causing a client to act, or fail to act in making investment decisions 15  • prohibit the firm or its employees from profiting or causing others to profit on knowledge of completed or contemplated client transactions • allocate investment opportunities in a fair and equitable manner • provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefiting at the expense of a client. Advisory representatives and employees must follow the firm's procedures when purchasing or selling the same securities purchased or sold for the client. Factors Used to Select Broker-Dealers for Client Transactions Custodian Recommendations Mach-1 Financial participates in the institutional customer program of Charles Schwab & Co. ("Schwab"), a division of The Charles Schwab Corporation, member FINRA/SIPC/NFA, Fidelity Brokerage Services, LLC ("Fidelity"), member FINRA/SIPC, and LPL Financial LLC ("LPL"), member FINRA/SIPC (together the "Custodians"). Schwab, Fidelity, and LPL are independent and unaffiliated SEC-registered broker-dealers. Schwab, Fidelity, and LPL offer to independent investment advisers services which include custody of securities, trade execution, clearance, and settlement of transactions. Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like ours. Mach-1 Financial receives some benefits from Schwab, Fidelity, and LPL through its participation in the programs. (Please see the disclosure under Item 4 of this Brochure.) Mach-1 Financial provides clients with access to an automated advisory services program, Ascent. Clients choosing to participate in the Ascent program enter into an agreement with MTG LLC, dba Betterment Securities, which is responsible for execution of securities transactions and maintains custody of client assets. Mach-1 Financial considers the financial strength, reputation, operational efficiency, cost, execution capability, level of customer service, and related factors in recommending broker-dealers or custodians to advisory clients. Aggregating Securities Transactions for Client Accounts In general, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. If you participate in our wrap fee program described above, you will not pay any portion of the transaction costs in addition to the program fee. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in proportion to the size of each client's order. Accounts owned by our firm or persons associated with our firm are permitted to participate in aggregated trading with your accounts; however, they will not be given preferential treatment. Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Accounts are reviewed by Mach-1 Financial's Manager. The frequency of reviews is determined based on the client's investment objectives, but reviews are conducted no less frequently than annually. More frequent reviews may also be triggered by a change in the client's investment objectives, tax considerations, large deposits or withdrawals, large purchases or sales, loss of confidence in the underlying investment, changes in macro-economic climate, or for any reason deemed appropriate by Mach-1 Financial or the client. 16  Review of Client Accounts on Non-Periodic Basis The firm may perform ad hoc reviews on an as-needed basis if there have been material changes in the client's investment objectives or risk tolerance, or a material change in how the firm formulates investment advice. Content of Client-Provided Reports and Frequency Mach-1 Financial does not provide any performance or other reports to third-party investment advisers or any subscribing sub-adviser firm. To the extent Mach-1 Financial may manage an individual client account, we will not provide the client with regular written reports: the client will receive no less frequently than quarterly a statement from the custodian indicating holdings, transactions, and cash balance. Betterment Securities maintains custody of your assets that are managed by Betterment. Account statements are available for review on the activity section of the Betterment at Work Advisor dashboard. The custodian is the official record of the client's account. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Schwab, Fidelity, and LPL As disclosed above, Mach-1 Financial participates in the institutional customer programs of Schwab, Fidelity, and LPL and may recommend Schwab, Fidelity, or LPL Financial to clients for custody and brokerage services. There is no direct link between Mach-1 Financial's participation in the program and the investment advice it gives to clients, although the firm receives economic benefits through its participation in the program that are typically not available to Schwab, Fidelity, or LPL retail investors. These benefits include the following products and services (provided either without cost or at a discount): • Receipt of duplicate client statements and confirmations • Research related products and tools • Consulting services • Access to a trading desk serving our clients' accounts • Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to our client's accounts) • The ability to have advisory fees deducted directly from our client's accounts • Access to an electronic communications network for client order entry and account information • Access to mutual funds with no transaction fees, and to certain institutional money managers As part of its fiduciary duties to clients, Mach-1 Financial endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Mach-1 Financial or its related persons in and of itself creates a potential conflict of interest and may indirectly influence Mach-1 Financial's choice of Schwab, Fidelity, or LPL for custody and brokerage services. AE Wealth Management, LLC Mach-1 Financial has entered into an agreement with AE Wealth Management, LLC ("AEWM") and its affiliates, whereby AEWM has provided bonus funding to our firm in the form of a forgivable loan representing an unvested advance on fees we will generate pursuant to a sub-advisory agreement with AEWM. As part of this agreement, our firm has agreed to use AEWM's sub-advisory services for at least a certain period of time. This arrangement creates a conflict of interest in that we have a financial incentive to recommend AEWM's sub-advisory services to our clients. Notwithstanding our agreement with AEWM, we have reasonable belief that AEWM provides quality services based on several factors, including, but not limited to, the ability to provide professional services, reputation, experience and financial stability. In addition, AEWM, their affiliate Advisors Excel, and their brokered partners (or 17  insurance companies) may also provide bonus compensation or awards for business we place with them. This includes insurance product sales. This is a conflict of interest in that we have an economic incentive to refer insurance business to AEWM's affiliated entities. Advisory Firm Payments for Client Referrals Mach-1 Financial does not compensate any third-parties for client referrals. Ascent Platform Mach-1 Financial has entered into an agreement with three Betterment entities as part of the Ascent offering: • Betterment for Business LLC ("B4B") provides certain recordkeeping services to tax-qualified 401(k) plans (a "Plan" or "Plans"), including Plans that are our clients; • Betterment LLC ("Betterment"), an SEC-registered investment adviser, provides certain investment advisory services to Plans and their participants ("Participants") and; • MTG LLC, dba Betterment Securities ("Betterment Securities"), an SEC-registered broker- dealer and member of FINRA and the SIPC, serves as broker-dealer and custodian. We receive a non-economic benefit from Betterment in the form of the support products and services it makes available to us and, to the extent we place Clients on the Betterment at Work platform, we may be deemed to give Betterment an indirect benefit in the form of the asset-based fees it receives from our Clients. Flourish Financial LLC Flourish Cash is an online cash management solution that seeks to provide Clients with competitive APY and elevated FDIC coverage for their deposits placed at program banks. Flourish Cash is offered by Flourish Financial LLC, a registered broker-dealer and FINRA member. Mach-1 Financial Group, LLC is not affiliated with Flourish or any of the program's banks. Mach-1 Financial is not acting as an investment advisor representative or in a discretionary manner when inviting Clients to use Flourish and only does so with Client consent. We receive no economic benefit from Flourish but, to the extent we offer Clients access to the Flourish Cash platform, we may be deemed to give Flourish an indirect benefit in the form of the asset-based fees it receives from our Clients. Advisory Firm Payments for Client Referrals Mach-1 Financial does not compensate any third-parties for client referrals. Custody Mach-1 Financial is considered to have custody of client assets for purposes of the Advisers Act for the following reasons: • The client authorizes us to instruct their custodian to deduct our Mach-1 Fees directly from the client's Managed Accounts. The custodian maintains actual custody of clients' assets. • Mach-1 Financial, or persons associated with our firm, may effect asset transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third party asset transfers has access to the client's assets, and therefore has limited custody of the client's assets in any related accounts. 18  Based on an SEC no-action letter, Mach-1 Financial is not required to obtain a surprise annual audit as would otherwise be required by reason of having custody, as long as we meet the following criteria: 1. Client provides a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. Client authorizes Mach-1 Financial in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Client's qualified custodian verifies client's authorization (e.g., signature review) and provides a transfer of funds notice to client promptly after each transfer; 4. Client can terminate or change the instruction; 5. Mach-1 Financial has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. Mach-1 Financial maintains records showing that the third party is not a related party to us nor located at the same address as us; and 7. Client's qualified custodian sends client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Mach-1 Financial hereby confirms that it meets the above criteria. Individual advisory clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances, and portfolio holdings in their accounts. Clients are urged to compare the Managed Account balance(s) shown on their account statements to the quarter-end balance(s) on their custodian's monthly statement. The custodian's statement is the official record of the account: you should carefully review your account statements for accuracy. Private fund investors will receive fund level statements of all activity, cash balances, and portfolio holdings on a quarterly basis from their qualified custodian. Trustee Services Persons associated with our firm serve as trustees to certain accounts for which we also provide investment advisory services. In all cases, the persons associated with our firm have been appointed trustee as a result of a family or personal relationship with the trust grantor and/or beneficiary and not as a result of employment with our firm. Therefore, we are not deemed to have custody over the advisory accounts for which persons associated with our firm serve as trustee. Additionally, as part of Mach-1 Financial's 401(k) plan offering via Betterment At Work, Betterment Securities maintains custody of your assets that are managed by Betterment. Account statements are available for review on the activity section of the Betterment at Work Advisor dashboard. Clients receive periodic emails from Betterment with information about your accounts as well as links to account statements. Mach-1 Financial encourages you to carefully review those statements promptly. Financial Information Balance Sheet Mach-1 Financial does not require the prepayment of fees of $1200 or more, six months or more in advance, and as such is not required to file a balance sheet. Financial Conditions Reasonably Likely to Impair Advisory Firm's Ability to Meet Commitments to Clients The firm does not have any financial issues that would impair its ability to provide services to clients. Bankruptcy Petitions During the Past Ten Years There is nothing to report for this item. 19  Item 10 Requirements for State-Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. 20