MACLEAN CAPITAL ADVISORS, LLC

MacLean Capital Advisors, LLC Client Brochure This brochure provides information about the qualifications and business practices of MacLean Capital Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at (760) 636-4593 or by email at: christian@macleancapital.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. Additional information about MacLean Capital Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. MacLean Capital Advisors, LLC’s CRD number is: 156978 74900 US Highway 111, Suite 224 Indian Wells, California, 92210 (760) 636-4593 christian@macleancapital.com Registration does not imply a certain level of skill or training. MacLean Capital Advisors, LLC and PKS are not affiliated companies. Version Date: 2/17/2026  Item 2: Material Changes MacLean Capital Advisors, LLC is required to report all material changes that have occurred since our last annual amendment filing. Since our last annual amendment filing, we have no material changes to report. i  Item 3: Table of Contents Table of Contents MacLean Capital Advisors, LLC ...........................................................................................................................1 Item 2: Material Changes ........................................................................................................................................ i Item 3: Table of Contents ....................................................................................................................................... ii Item 4: Advisory Business ......................................................................................................................................1 A. Description of the Advisory Firm ................................................................................................................1 B. Types of Advisory Services ...........................................................................................................................1 Investment Supervisory Services ..................................................................................................................1 Financial Planning ...........................................................................................................................................1 Services Limited to Specific Types of Investments .....................................................................................2 C. Client Tailored Services and Client Imposed Restrictions ........................................................................3 D. Wrap Fee Programs ........................................................................................................................................3 E. Amounts Under Management ......................................................................................................................3 Item 5: Fees and Compensation .............................................................................................................................3 A. Fee Schedule ....................................................................................................................................................3 Investment Supervisory Services Fees ..........................................................................................................3 Financial Planning ...........................................................................................................................................4 C. Clients Are Responsible For Third Party Fees ............................................................................................4 D. Prepayment of Fees ........................................................................................................................................4 E. Outside Compensation For the Sale of Securities to Clients .....................................................................5 1. This is a Conflict of Interest .................................................................................................................5 2. Clients Have the Option to Purchase Recommended Products From Other Brokers .................5 3. Advisory Fees in Addition to Commissions or Markups ................................................................5 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................5 Item 7: Types of Clients ..........................................................................................................................................5 Minimum Account Size ..................................................................................................................................6 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .......................................6 A. Methods of Analysis and Investment Strategies ..................................................................................6 Methods of Analysis ........................................................................................................................................6 ii  Fundamental analysis .....................................................................................................................................6 Technical analysis ............................................................................................................................................6 Cyclical analysis ...............................................................................................................................................6 Investment Strategies ......................................................................................................................................6 B. Material Risks Involved ...........................................................................................................................6 Methods of Analysis ........................................................................................................................................6 Fundamental analysis .....................................................................................................................................6 Technical analysis ............................................................................................................................................6 Cyclical analysis ...............................................................................................................................................7 Investment Strategies ......................................................................................................................................7 C. Risks of Specific Securities Utilized ........................................................................................................7 Item 9: Disciplinary Information ...........................................................................................................................8 Item 10: Other Financial Industry Activities and Affiliations ...........................................................................8 A. Registration as a Broker/Dealer or Broker/Dealer Representative ..................................................8 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor ..................................................................................................................................................8 Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests .................................................................................................................................................................8 D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ..............................................................................................................................................................8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................9 A. Code of Ethics ............................................................................................................................................9 B. Recommendations Involving Material Financial Interests .................................................................9 C. Investing Personal Money in the Same Securities as Clients ..............................................................9 D. Trading Securities At/Around the Same Time as Clients’ Securities ...............................................9 Item 12: Brokerage Practices ................................................................................................................................10 A. Factors Used to Select Custodians and/or Broker/Dealers..............................................................10 1. Research and Other Soft-Dollar Benefits ..........................................................................................10 2. Brokerage for Client Referrals ...........................................................................................................10 3. Clients Directing Which Broker/Dealer/Custodian to Use ..........................................................10 B. Aggregating (Block) Trading for Multiple Client Accounts .............................................................10 Item 13: Reviews of Accounts ..............................................................................................................................11 iii  A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ..............................11 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................11 C. Content and Frequency of Regular Reports Provided to Clients .....................................................11 Item 14: Client Referrals and Other Compensation ..........................................................................................11 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales A. Awards or Other Prizes) ...................................................................................................................................11 B. Compensation to Non – Advisory Personnel for Client Referrals ...................................................11 Item 15: Custody ....................................................................................................................................................12 Item 16: Investment Discretion ............................................................................................................................12 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................13 Item 18: Financial Information .............................................................................................................................13 A. Balance Sheet ...........................................................................................................................................13 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ..................................................................................................................................................................13 C. Bankruptcy Petitions in Previous Ten Years .......................................................................................13 iv  Item 4: Advisory Business A. Description of the Advisory Firm MacLean Capital Advisors, LLC is a Limited Liability Company organized in the state of California in March 2011, and the principal owners are Christian A. MacLean and Brette H. MacLean. B. Types of Advisory Services MacLean Capital Advisors, LLC (hereinafter “MCA”) offers the following services to advisory clients: Investment Supervisory Services MCA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. MCA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring MCA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. MCA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services are based on hourly fees or fixed fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. Form ADV 2A Version: 02/17/2026 1  Retirement Plan Consulting Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: Investment Options – Our firm will work with the Plan Sponsor to evaluate Establishing an Investment Policy Statement – Our firm will assist in the • development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. • existing investment options and make recommendations for appropriate changes. • Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk. • Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. Participant Education – Our firm will provide opportunities to educate plan • participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non- publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Services Limited to Specific Types of Investments MCA limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, insurance products including annuities, and government securities. MCA may use other securities as well to help diversify a portfolio when applicable. Form ADV 2A Version: 02/17/2026 2  C. Client Tailored Services and Client Imposed Restrictions MCA offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent MCA from properly servicing the client account, or if the restrictions would require MCA to deviate from its standard suite of services, MCA reserves the right to end the relationship. D. Wrap Fee Programs MCA does not participate in any wrap fee programs. E. Amounts Under Management MCA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $222,096,364 $0.00 December 2025 Item 5: Fees and Compensation A. Fee Schedule Investment Supervisory Services Fees These maximum fee for this service will not exceed 1% of assets under management. Fees are negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Fees are paid quarterly in advance based upon the final day of the previous period, and clients may terminate their contracts with five days’ written notice. Unless otherwise provided in writing, our firm bills on cash. Refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Lower fees for comparable services may be available from other sources. Fees will typically be directly Form ADV 2A Version: 02/17/2026 3  debited from client managed accounts. As part of this process you understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Financial Planning Our firm charges on a flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Flat fees will not exceed $5,000. Our firm requires a retainer of 50% of the ultimate financial planning or consulting fee at the time of signing. The remainder of the fee will be directly billed to the client and due within 30 days of a financial plan being delivered or consultation rendered. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months. Retirement Plan Consulting Our Retirement Plan Consulting services are billed on an hourly or flat fee basis or a fee based on the percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Fees based on a percentage of managed Plan assets will not exceed 0.50%. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. C. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by MCA. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees MCA collects fees in advance and in arrears. Fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination and the total days during the billing period. Fees will be returned within fourteen days to the client via check or return to credit card. Form ADV 2A Version: 02/17/2026 4  E. Outside Compensation For the Sale of Securities to Clients Christian A. MacLean and Brette H. MacLean in their role as registered representatives accept compensation for the sale of securities to MCA clients. 1. This is a Conflict of Interest the compensation received rather than on MCA and its supervised persons will accept compensation for the sale of securities or other investment products, including asset based sales charges or services fees from the sale of mutual funds to its clients. This presents a conflict of interest and gives the supervised person and MCA an incentive to recommend products based on the client’s needs. When recommending the sale of securities or investment products for which MCA receives compensation, MCA will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase MCA recommended products through other brokers or agents that are not affiliated with MCA. 3. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management MCA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients MCA generally provides investment advice and/or management supervisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit Sharing Plans ❖ Charitable Organizations Form ADV 2A Version: 02/17/2026 5  Minimum Account Size There is an account minimum, $500,000, which may be waived by the investment advisor, based on the needs of the client and the complexity of the situation. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis MCA’s methods of analysis include fundamental analysis, technical analysis, and cyclical analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involved the analysis of business cycles to find favorable conditions for buying and/or selling a security. Investment Strategies MCA uses long term trading, short term trading, margin transactions, bonds, options writing (including covered options, uncovered options, or spreading strategies), cash & cash equivalents. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these Form ADV 2A Version: 02/17/2026 6  patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns and 2) if too many investors begin to implement this strategy, it changes the very cycles they are trying to take advantage of. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). Our firm does this in an attempt to take advantage of conditions that our firm believes will soon result in a price swing in the securities our firm purchase. This approach will result in added trading costs, and tax liabilities as short term capital gains are taxed at a higher rate than long term gains. Margin Transactions: Our firm may purchase securities for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase securities without selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate for every client. It should be noted that our firm bills advisory fees on securities purchased on margin which creates a financial incentive for us to utilize margin in client accounts. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on margin balances which will reduce your returns over time. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized MCA generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, it will utilize margin transactions and options writing. Short sales, margin transactions, and options writing generally hold greater risk of capital loss and clients should be aware that there is a material risk of loss using any of those strategies. Form ADV 2A Version: 02/17/2026 7  Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business or the integrity of our management. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Christian A. MacLean and Brette MacLean are registered representatives of PKS Investments. From time to time, they will offer clients advice or products from those activities. Clients should be aware that the registered representative services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. MCA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of MCA in their capacity as a registered representative. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither MCA nor its representatives are registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Christian A. MacLean and Brette MacLean are licensed insurance agents. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. MCA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of MCA in their capacity as an insurance agent. D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections Form ADV 2A Version: 02/17/2026 8  MCA does not utilize nor select other advisors or third party managers. All assets are managed by MCA management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Clients may request a copy of our Code of Ethics from management. B. Recommendations Involving Material Financial Interests MCA does not recommend that clients buy or sell any security in which a related person to MCA has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of MCA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of MCA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. MCA will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of MCA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of MCA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Form ADV 2A Version: 02/17/2026 9  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers The Custodian will be chosen based on their relatively low transaction fees and access to mutual funds and ETFs. MCA will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian. 1. Research and Other Soft-Dollar Benefits MCA receives research, products, or services other from its broker-dealer or another third-party in connection with client securities transactions (“soft dollar benefits”). There is no minimum client number or dollar number that MCA must meet in order to receive free research from the custodian or broker/dealer. There is no incentive for MCA to direct clients to this particular broker-dealer over other broker-dealers who offer the same services. The first consideration when recommending broker/dealers to clients is best execution. 2. Brokerage for Client Referrals MCA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use MCA will not allow clients to direct MCA to use a specific broker-dealer to execute transactions. Clients must use MCA recommended custodian (broker-dealer). By requiring clients to use our specific custodian, MCA may be unable to achieve most favorable execution of client transactions and this may cost clients money over using a lower-cost custodian. B. Aggregating (Block) Trading for Multiple Client Accounts MCA maintains the ability to block trade purchases across accounts. While block trading may benefit clients by purchasing larger blocks in groups, we do not feel that the clients are at a disadvantage due to the best execution practices of our custodian. Form ADV 2A Version: 02/17/2026 10  Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least quarterly by Christian A. MacLean and Brette MacLean. They are the chief advisors and are instructed to review clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at MCA are assigned to these reviewers. All financial planning accounts are reviewed upon financial plan creation and plan delivery. There is only one level of review and that is the total review conducted to create the financial plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least quarterly a written report that details the client’s account which may come from the custodian. Clients are offered a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) MCA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to MCA clients. B. Compensation to Non – Advisory Personnel for Client Referrals Form ADV 2A Version: 02/17/2026 11  MCA does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody MCA, with Client’s written authority, has limited custody of client’s assets through direct fee deduction of MCA’s Fees only. Constructive custody of all client’s assets and holdings is maintained primarily at the Custodian. Clients will receive all required account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser 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 contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion For those clients’ accounts where MCA provides ongoing supervision, the client has given MCA written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides Form ADV 2A Version: 02/17/2026 12  MCA discretionary authority via a limited power of attorney in the Investment Advisory Contract and in the contract between the client and the custodian. Item 17: Voting Client Securities (Proxy Voting) MCA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet MCA does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither MCA nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years MCA has not been the subject of a bankruptcy petition in the last ten years. Form ADV 2A Version: 02/17/2026 13