MADRID WEALTH MANAGEMENT, LLC

Item 1: Cover Page Madrid Wealth Management, LLC 9400 Holly Ave NE Bldg 4 Albuquerque, NM 87122 505-633-5332 Form ADV Part 2A – Firm Brochure Dated: August 1, 2025 This Brochure provides information about the qualifications and business practices of Madrid Wealth Management, LLC. If you have any questions about the contents of this Brochure, please contact us at 505-633-5332 and/or paul@madridwm.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. Madrid Wealth Management, LLC is a registered investment adviser. Registration does not imply a certain level of skill or training. Additional information about Madrid Wealth Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s identification number, CRD 333331. 1  Item 2: Material Changes No material changs since last update in January 2025. 2  Item 3: Table of Contents Item 1: Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 9 Item 6: Performance-Based Fees and Side-By-Side Management 13 Item 7: Types of Clients 13 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss 14 Item 9: Disciplinary Information 18 Item 10: Other Financial Industry Activities and Affiliations 19 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 19 Item 12: Brokerage Practices 20 Item 13: Review of Accounts 23 Item 14: Client Referrals and Other Compensation 23 Item 15: Custody 23 Item 16: Investment Discretion 24 Item 17: Voting Client Securities 24 Item 18: Financial Information 25 3  Item 4: Advisory Business Description of Advisory Firm Madrid Wealth Management, LLC is an Investment Adviser principally located in the state of New Mexico. We are a Limited Liability Company founded in September 2024. Madrid Wealth Management, LLC became registered in 2024. Paul Madrid is the principal owner and Chief Compliance Officer (“CCO”). As used in this brochure, the words “MWM”, "we", "our firm", “Advisor” and "us" refer to Madrid Wealth Management, LLC and the words "you", "your" and "Client" refer to you as either a client or prospective client of our firm. Types of Advisory Services MWM is a fee-only firm, meaning the only compensation we receive is from our Clients for our services. We offer wealth management, investment management services, financial planning, retirement plan consulting, retirement plan management, and education services. From time to time, MWM recommends third-party professionals such as attorneys, accountants, tax advisors, insurance agents, or other financial professionals. Clients are never obligated to utilize any third-party professional we recommend. MWM is not affiliated with nor does MWM receive any compensation from third-party professionals we may recommend. Wealth Management Services Wealth Management encompasses investment management services and financial planning. Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s personal and financial background. Account supervision is guided by the stated objectives of the Client (e.g., capital appreciation, growth, growth and income, income, and capital preservation), as well as risk tolerance and tax considerations. We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government and municipal securities, certificates of deposit, corporate debt securities, separately managed accounts, options contracts, Real Estate Investment Trusts, and cash and cash equivalents. We may also provide advice regarding investments held in Client’s portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the Client’s request. When we provide investment management services, Clients grant us limited authority to buy and sell securities on a discretionary basis and non-discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. At no additional fee and at Client’s election, MWM also provides the Client with a financial plan. A Client will be taken through establishing their goals and values around money. Clients will be required to provide pertinent information to help complete the following areas of analysis: net worth, cash flow, employee benefits, retirement planning, insurance, investments, college planning, and estate planning. Once the Client's information is reviewed, their plan will be built and analyzed, and then the findings, analysis and potential changes to their current situation will be reviewed with the Client. Clients will receive a detailed financial plan designed to help achieve Client’s 4  stated financial goals and objectives. The plan and the Client's financial situation and goals will be monitored throughout the year. Investment Management Services Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s personal and financial background. Account supervision is guided by the stated objectives of the Client (e.g., capital appreciation, growth, growth and income, income, and capital preservation), as well as risk tolerance and tax considerations. We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government and municipal securities, certificates of deposit, corporate debt securities, separately managed accounts, options contracts, Real Estate Investment Trusts, and cash and cash equivalents. We may also provide advice regarding investments held in Client’s portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the Client’s request. When we provide investment management services, Clients grant us limited authority to buy and sell securities on a discretionary basis and non-discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. When appropriate, we utilize the services of third-party investment managers (“Outside Managers”) to assist with the management of Client accounts. We assist Clients in providing due diligence of the Outside Managers, selecting an appropriate investment strategy, interacting with the Outside Managers and conducting an ongoing review of the Outside Managers’ quantitative and qualitative metrics, including performance. Our review process and analysis of Outside Managers is further discussed in Item 8 of this Brochure. Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. Blackrock Investment Management We may recommend that certain Clients implement some of their investment portfolio through Blackrock Investment Management. Clients have access to sets of equity and fixed income strategies managed by Blackrock Investment Management. Each strategy can be customized to the client’s preferences. Betterment for Advisors We may recommend that certain Clients implement their investment portfolios through our web-based portfolio manager, Betterment for Advisors, a division of Betterment LLC (herein “Betterment”). Clients have access to MWM constructed custom portfolio strategies. Each portfolio is comprised of exchange- traded funds or mutual funds and are customized to the risk-level for each Client’s investment goal. Financial Planning Services Financial planning involves an evaluation of a Client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service 5  will receive a written report, providing the Client with a detailed financial plan designed to help achieve his or her stated financial goals and objectives. In general, the financial plan will address some or all of the following areas of concern. The Client and MWM will work together to select specific areas to cover. These areas may include, but are not limited to, the following: ● Business Planning: We provide consulting services for Clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. ● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. ● College Savings: Includes projecting the amount that will be needed to achieve college or other post- secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to children and grandchildren (if appropriate). ● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. We will participate in meetings or phone calls between you and your attorney with your approval or request. ● Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. ● Insurance and Annuities: Review of existing policies to ensure proper coverage for life, disability, long- term care, and liability. Annuity reviews will consist of suitability, fees and cash flow needs. ● Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. 6  ● Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. ● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We may also provide tax projections with different scenarios to assist in tax planning for current and future years. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Financial Planning Services are offered on a Project-Based and/or via an Ongoing engagement. Project-Based Financial Planning. We provide project-based financial planning services on a limited scope one- time engagement. Project-Based Financial Planning is available for Clients looking to address specific questions or issues. The Client may choose from one or more of the above topics to cover or other areas as requested and agreed to by MWM. For Project-Based Financial Planning, the Client will be ultimately responsible for the implementation of the financial plan. Ongoing Financial Planning. This service involves working one-on-one with a financial planner (“planner”) over an extended period of time. Through this ongoing arrangement, Clients are expected to collaborate with the planner to develop and assist in the implementation of specific segments of their financial plan (the “plan”). The planner will monitor the plan, recommend any appropriate changes and ensure the plan is up-to-date as the Client’s situation, goals, and objectives evolve. Upon engaging the firm for financial planning, MWM is responsible for obtaining and analyzing the necessary qualitative and quantitative information from the Client that is essential to understanding the Client’s personal and financial circumstances; helping the Client identify, select, and prioritize certain financial goals while understanding the effect that pursuing one goal may have on other potential goals; assessing the Client’s current course of action and alternative courses of action to identify required changes that provide the best opportunity for the client to meet their financial goals; developing & presenting financial planning recommendations based on the aforementioned actions; and ongoing monitoring of the Client’s progress toward the goals and objectives that the recommendations are based around. These components all require in-depth communication with the Client in order for the planner to establish a financial plan and implementation strategy that provides the Client with the most appropriate options in pursuing their established goals and objectives. Consulting 7  MWM provides hourly and fixed fee consulting services for clients on a limited scope basis. These consulting services include fiduciary assessments, request for proposal (RFP) assistance, investment consulting, investment policy consulting, asset allocation modeling/design, financial consulting, and review/oversight of investment providers. Retirement Plan Consulting Our firm provides retirement plan services to employer plan sponsors on an ongoing basis. Generally, such services consist of assisting employer plan sponsors or plan named fiduciaries in establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: design of investment policy statement, investment review and recommendations, fee analysis, participant education, and vendor searches & analysis. Depending on the complexity of the client’s situation, our firm may team up with another service provider to service the client and meet the their needs. In providing retirement plan services, 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”). Certain plans and/or clients that we may provide services to are regulated under the Employee Retirement Income Securities Act of 1974 (“ERISA”). We will provide employee benefit plan services to the plan sponsor and/or fiduciaries as described above for the fees set forth in Item 5 of this brochure. The services we provide are advisory in nature. We are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as a fiduciary of the plan as defined in Section 3(21)(A)(ii) under ERISA. Retirement Plan Management Our firm provides retirement plan services to employer plan sponsors on an ongoing basis. Such services consist of assisting employer plan sponsors or plan named fiduciaries in buying and selling securities within the Plan on a discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. As the needs of the plan sponsor dictate, areas of advising could also include: design of investment policy statement, investment review and recommendations, fee analysis, participant education, and vendor searches & analysis. In providing retirement plan services, 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”). Certain plans and/or clients that we may provide services to are regulated under the Employee Retirement Income Securities Act of 1974 (“ERISA”). We will provide employee benefit plan services to the plan sponsor and/or fiduciaries as described above for the fees set forth in Item 5 of this brochure. We are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as an “investment manager” as defined in section 3(38) of ERISA pursuant to section 402(c)(3) of ERISA. Educational Seminars / Speaking Engagements We may provide seminars for groups seeking general advice on investments and other areas of personal finance. These seminars are purely educational in nature and do not involve the sale of any investment products. Information presented will not be based on any individual’s need, nor does MWM provide individualized investment advice to 8  attendees during these seminars. Topics covered during educational seminars will be determined by the Client and MWM. IRA Rollovers Clients have options with their employer sponsored retirement plans, which include leaving the assets in the plan, rolling over to another employer plan, rolling over to an individual retirement account (IRA), or cashing out the plan assets (could result in adverse tax consequences). We may recommend clients rollover assets to an IRA under our management and subject to our fee. This practice presents a conflict of interest because our fees will likely increase as a result of the rollover. Clients are under no obligation to complete the rollover and/or to have the IRA rollover assets managed by our firm. Client Tailored Services and Client Imposed Restrictions We tailor the delivery of our services to meet the individual needs of our Clients. We consult with Clients initially and on an ongoing basis, through the duration of their engagement with us, to determine risk tolerance, time horizon and other factors that may impact the Clients’ investment and/or planning needs. Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual securities and/or sectors that will be traded in their account, advised on or recommended. All such requests must be provided to MWM in writing. MWM will notify Clients if they are unable to accommodate any requests. Wrap Fee Programs We do not participate in wrap fee programs. Assets Under Management As of December 31, 2024 MWM has $123,973,547 in discretionary and $3,368,518 in non-discretionary assets under management. Item 5: Fees and Compensation MWM bases its fees on a percentage of assets under management and fixed fees. Hourly fees may be assessed for some consulting and planning agreements. Please note, unless a Client has received this brochure at least 48 hours prior to signing an Advisory Contract, the Advisory Contract may be terminated by the Client within five (5) business days of signing the Advisory Contract without penalty. How we are paid depends on the type of advisory services we perform. Below is a brief description of our fees, however, you should review your executed Advisory Contract for more detailed information regarding the exact fees you will be paying. No increase to the agreed-upon advisory fees outlined in the Advisory Contract shall occur without prior Client consent. Please note, lower fees for comparable services may be available from other sources. Clients with services performed and delivered in New Mexico receive a passthrough tax from MWM to pay gross receipts tax on the advisory fee. MWM will collect this tax when fees are assessed and send to the state of New Mexico’s tax and revenue department. Please visit tax.newmexico.gov for current rates based in Albuquerque. 9  Wealth Management Services and Investment Management Services The fee is based on a percentage of assets under management and is negotiable. The annualized fees for wealth management services are based on the following fee schedule: Assets Under Management Annual Advisory Fee $0 - $1,000,000 1.00% $1,000,001 - $2,000,000 0.85% $2,000,001 - $5,000,000 0.60% $5,000,000 - $10,000,000 0.45% $10,000,000 and Above 0.30% A minimum annual fee of $5,000 will apply but is waived if using MWM’s investment management through Betterment. Betterment charges an additional fee of 0.15%. The annual advisory fee is paid quarterly in arrears based on the value of Client’s account(s) as of the last day of the billing period. The advisory fee is a blended tier. For example, for assets under management of $2,000,000, a Client would pay 1.00% on the first $1,000,000 and 0.85% on the next $1,000,000. The quarterly fee is determined by the following calculation: (($1,000,000 x 1.00%) + ($1,000,000 x 0.85%) ÷ 4 = $4,625.00. In determining the advisory fee, we may allow accounts of members of the same household to be aggregated. MWM relies on the valuation as provided by Client’s custodian in determining assets under management. Our advisory fee is prorated for flows and partial billing periods occurring during the engagement, including the initial and terminating billing periods. Fee schedules may be negotiated up or down depending on the complexity of accounts, the inclusion of other services, and the amount service time the client desires. Similarly, a flat fee or custom fee schedule can be negotiated based on client needs. If MWM utilizes an Outside Manager, the above fee schedule does not include the Outside Manager’s fee. The Outside Manager will debit the Client's account for its fee. The Outside Manager’s wrap fees, advisory fees, billing schedule, and payment procedures are set forth in their separate written disclosure documents, advisory agreements, and/or the account opening documents of your account Custodian. Ongoing Financial Planning We charge an initial fee of $2,500 for initial construction of the plan and a recurring fixed fee for Ongoing Financial Planning. Recurring fees are paid quarterly in arrears, ranging from $1,250 to $15,000 per quarter. The fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. Fees are negotiable and the final agreed upon fee will be outlined in your Advisory Contract. Project-Based Financial Planning & Consulting 10  MWM charges either a fixed or hourly fee for Project-Based Financial Planning and Consulting. Fixed fee rates start at $2,500. Our hourly rate is $250. The fee is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. Fees are negotiable and the final agreed upon fee will be outlined in your Advisory Contract. MWM may request a portion of the fee be collected in advance with the remainder due upon completion of the services. MWM will not bill an amount above $500 more than 6 months or more in advance of rendering the services. Retirement Plan Management and Consulting The fee is based on a percentage of assets under management and is negotiable. The annualized fees for retirement plan investment management services are based on the following fee schedule: Assets under Management Retirement Plan Consulting Retirement Plan Management Annual Advisory Fee Annual Advisory Fee $0 - $1,000,000 $3,500 $5,000 $1,000,001 - $2,500,000 $5,000 $7,500 $2,500,001 - $5,000,000 $7,500 $10,000 $5,000,001 - $10,000,000 $10,000 $15,000 $10,000,000 - $20,000,000 $15,000 $20,000 $20,000,000 and above Negotiated Negotiated The annual advisory fee is paid quarterly in arrears based on the value of Client’s account(s) as of the last day of the billing period. The advisory fee is a straight tier. For example, for assets under management of $2,000,000, a Client using the Retirement Plan Management service would pay $7,500. The quarterly fee is determined by the following calculation: $7,500 ÷ 4 = $1,875. Additional fees include a one-time setup fee of $1,500 which includes the one participant enrollment and education meeting. Additional participant and enrollment meetings are $1,000 per visit. Advisor offers its services in a virtual or in-person setting. Should the meeting require travel arrangements, both parties must agree to the terms of travel (i.e. cost, distance, hotel arrangements) at the start of the engagement. Fee schedules may be negotiated up or down depending on the complexity of accounts, the inclusion of other services, and the amount service time the client desires. Similarly, a flat fee or custom fee schedule can be negotiated based on client needs. These fees do not include fees to other parties, such as record keepers, custodians, or third-party administrators. MWM relies on the valuation as provided by Client’s custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. 11  Educational Seminars / Speaking Engagements Seminars and speaking engagements are offered to organizations and the public on a variety of financial topics. Fees range from $0 to $5,000 per seminar. The fee range is based on the content, amount of research conducted, the number of hours of preparation needed, and the number of attendees. MWM may collect a portion of the fee in advance with the remainder due at the conclusion of the Seminar. Advisor offers its services in a virtual or in-person setting. Should the event require travel arrangements, both parties must agree to the terms of travel (i.e. cost, distance, hotel arrangements) at the start of the engagement. Fee Payment For Wealth and Investment Management services, we deduct our advisory fee plus any gross receipts tax required by states from one or more account(s) held at an unaffiliated third-party custodian, as directed by the Client. Please refer to Item 15 of this Brochure regarding our policy on direct fee deduction. When an Outside Manager is used, the Outside Manager will debit the Client’s account for its fee. For Financial Planning services and Educational Seminars / Speaking Engagements, fees are paid by electronic funds transfer (EFT) or check. We use an independent third-party payment processor in which the Client can securely input their banking information and pay their fee. We do not have access to the Client’s banking information at any time. The Client will be provided with their own secure portal in order to make payments. For Retirement Plan services, fees are either paid directly by the plan sponsor or deducted directly from the plan assets by the custodian. Please refer to Item 15 of this Brochure regarding our policy on direct fee deduction. Clients may also pay by electronic funds transfer (EFT) or check. We use an independent third-party payment processor in which the Client can securely input their banking information and pay their fee. We do not have access to the Client’s banking information at any time. The Client will be provided with their own secure portal in order to make payments. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Clients subject to New Mexico gross receipts tax will have the tax added to the MWM fee. MWM will collect this tax when fees are assessed and send to the state of New Mexico’s tax and revenue department. Please visit tax.newmexico.gov for current rates based in Albuquerque. Item 12 further describes the factors that we consider in selecting or recommending custodians for Client’s transactions and determining the reasonableness of their compensation (e.g., commissions). Clients may incur fees from third-party professionals such as accountants and attorneys that MWM may recommend, upon Client request. Such fees are separate and distinct from MWM’s advisory fees. Depending on the complexities of the relationship, clients with MWM advisory fees in excess of $20,000 per year may negotiate with MWM to pay third-party tax professionals for tax preparation services. 12  Terminations and Refunds For Wealth/Investment Management services and Retirement Plan Services, the Advisory Contract may be terminated with written notice at least 5 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the Advisory Contract. Clients will be responsible for payment of fees up to the date of termination. For Ongoing Financial Planning services, the Advisory Contract may be terminated with written notice at least 5 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the Advisory Contract. Clients will be responsible for payment of fees up to the date of termination, based on the percentage of work completed by the Advisor. For Project-Based Financial Planning services, this service is not an ongoing engagement, thus upon receipt of the final fees, the Advisory Contract will automatically be terminated. Clients may terminate at any time provided written notice at least 5 calendar days in advance. If fees are paid in advance, a prorated refund will be given, if applicable, upon termination of the Advisory Contract for any unearned fee. For fees paid in arrears, Client shall be charged a pro-rata fee based upon the percentage of the work done up to the date of termination. For Educational Seminars and Speaking Engagements, Advisor or Clients may cancel the event provided written notice at least 10 calendar days in advance. Should the Client cancel the event within 10 days of the event (with the exception of weather or similar unforeseen causes), the Client will be responsible for reimbursement of any non- refundable travel expenses already incurred and a prorated fee for any work conducted in preparation of the event, based on the percentage of work done and the flat fee agreed upon by both parties. Should any fees collected in advance exceed the amount of work conducted, Advisor will provide a prorated refund within 30 days from the notice of termination. Sale of Securities or Other Investment Products Advisor and its supervised persons do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees and do not engage in side-by-side management. Item 7: Types of Clients We provide services to individuals, high net-worth individuals, banking or thrift institutions, investment companies, pension and profit sharing plans, charitable organizations, corporations or other businesses, state or municipal government entities, tribal governments and commercial enterprises, and other investment advisers. We do not have a minimum account size requirement, but we have a minimum annual fee of $5,000 to open or maintain an account under our management. MWM may reduce or waive the minimum fee requirement on a case- by-case basis. 13  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Below is a brief description of our methods of analysis and primary investment strategies when we provide securities recommendations. Methods of Analysis Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. 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, then it changes the very cycles these investors are trying to exploit. Modern Portfolio Theory (MPT) The underlying principles of MPT are: ● Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. ● Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. ● ● ● The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Investing for the long-term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. 14  Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at qualitative aspects such as expertise and investment philosophy. In addition, we monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. Lastly, we compare fees to peers to determine if the fee is reasonable relative to the benefit we expect. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the Client’s portfolio. Use of Outside Managers: We may refer Clients to Third Party Investment Advisers (“Outside Managers”). Our analysis of Outside Managers involves the examination of the experience, expertise, investment philosophies, and past performance of the Outside Managers in an attempt to determine if that Outside Manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the Outside Manager's strategies, and concentrations as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the Outside Manager's compliance and business enterprise risks. A risk of investing with an Outside Manager who has been successful in the past is that they may not be able to replicate that success in the future. In addition, we do not control the underlying investments in an Outside Manager's portfolio. There is also a risk that an Outside Manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our Clients. Moreover, as we do not control the Outside Manager's daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Investment Strategies Asset Allocation In implementing our Clients’ investment strategy, we begin by attempting to identify an appropriate ratio of equities, fixed income, and cash (i.e. “asset allocation”) suitable to the Client’s investment goals and risk tolerance. A risk of asset allocation is that the Client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of equities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the Client’s goals. We attempt to closely monitor our asset allocation models and make changes periodically to keep in line with the target risk tolerance model. Passive and Active Investment Management We may choose investment vehicles that are considered passive, active, or a combination of both styles. Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. Active investing involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Actively managed funds are also designed to reduce volatility and risk. 15  We may engage in both passive and active investing in Client’s portfolio. However, we strive to construct portfolios of funds and individual securities that we believe will have the greatest probability for achieving our Clients’ personal financial goals with the least amount of volatility and risk rather than attempt to outperform an arbitrary index or benchmark. Specific investment selections are based on a number of factors that we evaluate in order to select, what we believe to be, the highest quality funds or individual securities for our Clients. These factors include but are not limited to underlying holdings of funds, percentage weighting of holdings within funds, liquidity, tax efficiency, and other smart/strategic beta factors. These factors may or may not result in the lowest cost ETFs and mutual funds available when utilizing funds in a Client’s portfolio, but we strive to keep internal fund expenses as low as possible. Socially Responsible Investing We may utilize various socially conscious investment approaches if a Client desires. MWM may construct portfolios that utilize mutual funds, ETFs, or individual securities with the purpose of incorporating socially conscious principles into a Client’s portfolio. These portfolios may sometimes also be customized to reflect the personal values of each individual, family, or organization. This allows our Clients to invest in a way that aligns with their values. MWM may rely on mutual funds and ETFs that incorporate Environmental, Social and Governance (“ESG”) research as well as positive and negative screens related to specific business practices to determine the quality of an investment on values-based merits. If you request your portfolio to be invested according to socially conscious principles, you should note that returns on investments of this type may be limited and because of this limitation you may not be able to be as well diversified among various asset classes. The number of publicly traded companies that meet socially conscious investment parameters is also limited, and due to this limitation, there is a probability of similarity or overlap of holdings, especially among socially conscious mutual funds or ETFs. Therefore, there could be a more pronounced positive or negative impact on a socially conscious portfolio, which could be more volatile than a fully diversified portfolio. Long-term/Short-term purchases We purchase securities and generally hold them in the Client's account for a year or longer. Short-term purchases may be employed as appropriate when: ● We believe the securities to be currently undervalued, and/or ● We want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. 16  Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio. Turnover Risk: Actively managed mutual funds tend to have a higher turnover rate than passive funds. A high portfolio turnover would result in higher transaction costs and in higher taxes when shares are held in a taxable account. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Currency Risk: Investments outside of the United States generally hold currencies of other countries. These currencies fluctuate in value relative to the U.S. dollar and may impact the value of the investments. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Cryptocurrencies are alternative currencies that are very volatile. They have a number of risks including regulatory challenges, uncertainty on adoption rates, and are in the infancy stage of development. Prices may go up and down quite dramatically, and suddenly. There is a risk that all the value of the cryptocurrency could be lost. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. 17  Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above (premium) or below (discount) their net asset value and an ETF purchased at a premium may ultimately be sold at a discount; (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are delisted from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Annuities: Annuities are an investment vehicle for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future, generally in retirement. Annuities are contracts issued by a life insurance company designed to meet requirement or other long- term goals. An annuity is not a life insurance policy. Item 9: Disciplinary Information Criminal or Civil Actions MWM and its management persons have not been involved in any criminal or civil action. Administrative Enforcement Proceedings MWM and its management persons have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings MWM and its management persons have not been involved in legal or disciplinary events that are material to a its management. Client’s or prospective Client’s evaluation of MWM or the integrity of 18  Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Neither MWM or its management persons is registered, or have an application pending to register, as a broker- dealer or a registered representative of a broker-dealer. Other Affiliations Neither MWM or its management persons is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Related Persons Neither MWM or its management persons have any relationship or arrangement with any related parties. Contractors MWM may use contractors for tax services, financial planning services, and investment advisory services. MWM pays these contractors directly for any services they provide. Clients may contract directly with these contractors. No Clients are required to use any contractor services. Recommendations or Selections of Other Investment Advisers As referenced in Item 4 of this brochure, MWM may recommend Clients to Outside Managers to manage their accounts. In the event that we recommend an Outside Manager, we do not share in their advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5 of this brochure). In addition, you will be provided a copy of the Outside Manager’s Form ADV 2A, Firm Brochure, which also describes the Outside Manager’s fee. You are not obligated, contractually or otherwise, to use the services of any Outside Manager we recommend. Moreover, MWM will only recommend an Outside Manager who is properly licensed or registered as an investment adviser. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Additionally, MWM requires adherence to its Insider Trading Policy, and the CFA Institute's Asset Manager Code of Professional Conduct and Code of Ethics and Standards of Professional Conduct. Code of Ethics Description This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its specific provisions will not shield our firm or its access persons from liability for misconduct that violates a fiduciary duty to our Clients. A summary of the Code of Ethics' Principles is outlined below. 19  Integrity - Access persons shall offer and provide professional services with integrity. ● ● Objectivity - Access persons shall be objective in providing professional services to Clients. ● Competence - Access persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. ● Fairness - Access persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. ● Confidentiality - Access persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. ● Professionalism - Access persons conduct in all matters shall reflect the credit of the profession. ● Diligence - Access persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither our firm, its access persons, or any related person is authorized to recommend to a Client or effect a transaction for a Client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm, its access persons, and its related persons may buy or sell securities similar to, or different from, those we recommend to Clients. In an effort to reduce or eliminate certain conflicts of interest, our Code of Ethics may require that we restrict or prohibit access persons’ transactions in specific reportable securities. Any exceptions or trading pre-clearance must be approved by MWM’s Chief Compliance Officer in advance of the transaction in an account. MWM maintains a copy of access persons’ personal securities transactions as required. Trading Securities At/Around the Same Time as Client’s Securities From time to time our firm, its access persons, or its related persons may buy or sell securities for themselves at or around the same time as they buy or sell securities for Clients’ account(s). To address this conflict, it is our policy that neither our firm or access persons shall have priority over Clients’ accounts in the purchase or sale of securities. Item 12: Brokerage Practices Factors Used to Select Custodians MWM does not have any affiliation with any custodian we recommend. Specific custodian recommendations are made to the Client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the custodian’s services. The factors we consider when evaluating a custodian for best execution include, without limitation, the custodian’s: ● Combination of transaction execution services and asset custody services (generally without a separate fee for custody); 20  ● Capability to execute, clear, and settle trades (buy and sell securities for your account); ● Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); ● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.); ● Availability of investment research and tools that assist us in making investment decisions ● Quality of services; ● Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; ● Reputation, financial strength, security and stability; ● Prior service to us and our clients. With this in consideration, our firm recommends Charles Schwab, an independent and unaffiliated SEC registered broker-dealer firm and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Although Clients may request us to use a custodian of their choosing, we generally recommend that Clients open brokerage accounts with Charles Schwab. We are not affiliated with Charles Schwab. The Client will ultimately make the final decision of the custodian to be used to hold the Client’s investments by signing the selected custodian’s account opening documentation. Another custodian our firm recommends is Betterment Securities. We are not affiliated with Betterment and the Client will ultimately make the final decision of the custodian to be used to hold the Client’s investments by signing the selected custodian’s account opening documentation. Betterment charges a wrap fee that bundles custody and trading services for a fee of 0.15% annually. Research and Other Soft-Dollar Benefits We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase products and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result of being on their institutional platform, Charles Schwab may provide us with certain services that may benefit us. Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor’s choice of Schwab for custody and brokerage services. This conflict of interest is mitigated as Advisor regularly reviews the factors used to select custodians to ensure our recommendation is appropriate. Following is a more detailed description of Schwab’s support services: 1. Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our Clients. Schwab’s services described in this paragraph generally benefit you and your account. 21  2. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our Clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our Clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: ● provide access to Client account data (such as duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple Client accounts facilitate payment of our fees from our Clients’ accounts ● ● provide pricing and other market data ● ● assist with back-office functions, recordkeeping, and Client reporting 3. Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: ● Educational conferences and events ● Consulting on technology, compliance, legal, and business needs ● Publications and conferences on practice management and business succession 4. Your brokerage and custody costs. For our Clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Betterment for Advisors offers its investment sub-advisory services for securities portfolios through a wrap fee program that includes custody and trading services provided by its affiliate, MTG LLC, dba Betterment Securities (“Betterment Securities”). Betterment Securities is a registered broker-dealer and member of FINRA and SIPC. Betterment Securities is responsible for execution of securities transactions and maintains custody of customer assets. Betterment places aggregated orders involving multiple Betterment accounts trading in the same securities. Orders for the purchase or sale of securities are routed by Betterment Securities to Apex Clearing Corporation (“Apex”), the clearing broker used by Betterment Securities, for managed execution. Betterment Securities does not provide research or other products and services to MWM in connection with Client securities transactions. Brokerage for Client Referrals We receive no referrals from a custodian, broker-dealer or third party in exchange for using that custodian, broker- dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use We do not permit Clients to direct brokerage (direct us to a broker-dealer of your choosing) when providing investment management services. Aggregating (Block) Trading for Multiple Client Accounts Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we 22  combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or access persons may participate in block trading with your accounts; however, they will not be given preferential treatment. Outside Managers used by MWM may block Client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12. Item 13: Review of Accounts Periodic Reviews Clients who engage us for wealth/investment management services will have their account(s) reviewed at least annually by Paul Madrid, CEO and CCO. Account(s) are reviewed more frequently when client needs arise, or when market conditions warrant changes. Conversely, there may be periods of inactivity because we may determine that changes to the Client’s portfolio are neither necessary nor prudent. The account(s) are reviewed with regards to the Client’s investment policies and risk tolerance levels. Triggers of Reviews Events that may trigger a special review would be unusual performance, addition or deletions of Client-imposed restrictions, excessive draw-down, volatility, Client changes, or buy and sell decisions from the firm or per Client's needs. Review Reports Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. MWM will provide written performance and/or holdings reports to Wealth and Investment Management Clients on a quarterly basis. We urge Clients to compare these reports against the account statements they receive from their custodian. Item 14: Client Referrals and Other Compensation Compensation Received by Madrid Wealth Management, LLC MWM is a fee-only firm that is compensated solely by its Clients. MWM does not receive commissions or other sales-related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Client Referrals from Solicitors MWM does not, directly or indirectly, compensate any person who is not advisory personnel for Client referrals. Item 15: Custody MWM does not hold, directly or indirectly, Client funds or securities, or have any authority to obtain possession of them. All Client assets are held at a qualified custodian. If MWM deducts its advisory fee from Client’s account(s), the following safeguards will be applied: 23  i. ii. The Client will provide written authorization to MWM, permitting us to be paid directly from Client’s accounts held by the custodian. The custodian will send at least quarterly statements to the Client showing all disbursements from the accounts, including the amount of the advisory fee. We urge you to carefully review custodial statements and compare them to the account invoices or reports that we may provide to you and notify us of any discrepancies. Clients are responsible for verifying the accuracy of these fees as listed on the custodian’s brokerage statement as the custodian does not assume this responsibility. Our invoices or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. MWM can establish a Standing Letter of Authorization or other similar asset transfer authorization arrangements (“SLOA”) with qualified custodians in order for us to disburse funds to accounts as specifically designated by the Client. With a SLOA a Client can typically authorize first-party and/or third-party transfers. If transfers are third- party, MWM complies with each of the requirements and conditions enumerated below: 1. 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. 2. The Client authorizes MWM, 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. 3. 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. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. MWM 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. 6. MWM maintains records showing that the third party is not a related party of MWM or located at the same address as MWM. 7. 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 Client accounts where we provide Wealth/Investment Management Services, MWM has discretionary authority and limited power of attorney to determine the securities and the amount of securities to be bought or sold for a Client’s account without having to obtain prior Client approval for each transaction. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally, the discretionary relationship will be outlined in the Advisory Contract and signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments. However, approval of such requests are at the firm’s sole discretion. If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17: Voting Client Securities 24  We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. The Outside Managers mentioned in Item 4 will vote proxies on the Client’s behalf. Item 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our Clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client funds or securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $500 in fees six months or more in advance. 25