MAIA WEALTH, LLC

ITEM 1 – COVER PAGE Maia Wealth, LLC www.maiawealth.com Main Office Maia Wealth, LLC 1401 17th Street, Suite 850 Denver, CO 80202 Phone: (720) 644-8803 | Fax: (720) 368-5294 Other Offices Colorado 7887 E. Belleview Avenue Suite 1100 Denver, CO 80111 (720) 644-8803 Colorado 5025 Boardwalk Drive Colorado Springs, CO 80910 (719) 260-1184 Indiana 9365 Counselors Row Suite 215 Indianapolis, IN 46240 (463) 274-4630 Texas 14101 US-290 Bldg. 1100, Suite 219 Austin, TX 78737 (720) 640-6455 Illinois 2020 Calamos Ct. Naperville, IL 60563 (630) 703-0533 Illinois 1 Mid America Plaza 3rd Floor Oakbrook Terrace, IL 60181 (708) 722-2165 Part 2A Brochure September 15, 2025 This brochure provides information about the qualifications and business practices of Maia Wealth, LLC (“Maia Wealth”) If you have any questions about the contents of this brochure, please contact us at (720) 644-8803. 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. Maia Wealth is a Registered Investment Adviser. Registration as an Investment Adviser with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about Maia Wealth, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a IARD number. The IARD number for Maia Wealth, LLC is 292817. Maia Wealth, LLC FORM ADV 2A Brochure 1  ITEM 2 – MATERIAL CHANGES Summary of Material Changes This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.adviserinfo.sec.gov. The following are changes that have been made since the last Annual Amendment filing made on March 18, 2025: In certain markets, Maia Wealth does business as Hofkin Capital Management The Texas office moved to 14101 US-290 Bldg. 1100, Suite 219, Austin, TX 78737 Item 4 was updated to reflect the following items: o o Maia Wealth provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s consulting services. Brokerage Customers have entered into a written advisory agreement with Maia Wealth. Item 5 was updated to reflect: o Maia Wealth receives a consulting fee based on the Assets Under Management from Brokerage Customers who have provided written consent to a broker/dealer to receive the investment consulting service from Maia Wealth and have entered into a written advisory contract with Maia Wealth. The consulting fee is calculated from the Assets Under Management as of the end of a calendar quarter period multiplied by the annualized rate of from 0.50% to 0.85% basis points. The initial fee is paid only after the completion of one full calendar quarter period following the date of the executed agreement with broker/dealers. - Item 10 was updated to reflect: o Financial Institution Consulting Services Maia Wealth has agreement(s) with a broker/dealer to provide investment consulting services to Brokerage Customers. The broker/dealer does not pay compensation to Maia Wealth for providing investment consulting services to Customers. If you would like another copy of this Brochure, please download it from the SEC Website as indicated above or you may contact our Chief Compliance Officer, Chandler te Velde at (720) 644-8803. We encourage you to read this document in its entirety. Maia Wealth, LLC FORM ADV 2A Brochure 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 13 ITEM 9 - DISCIPLINARY INFORMATION 16 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 17 ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 18 ITEM 12 - BROKERAGE PRACTICES 19 ITEM 13 - REVIEW OF ACCOUNTS 22 ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION 23 ITEM 15 - CUSTODY 24 ITEM 16 - INVESTMENT DISCRETION 24 ITEM 17 - VOTING YOUR SECURITIES 25 ITEM 18 - FINANCIAL INFORMATION 25 Maia Wealth, LLC FORM ADV 2A Brochure 3  ITEM 4 – ADVISORY BUSINESS This Disclosure document is being offered to you by Maia Wealth, LLC (“Maia Wealth”) about the investment advisory services we provide. It discloses information about the services that we provide and the way those services are made available to you, the client. Maia Wealth, LLC (“Maia Wealth” or the “Advisor”) is a registered investment with the SEC located in the State of Colorado. Maia Wealth is organized as a Limited Liability Company (LLC) under the laws of Colorado. Maia Wealth became a registered entity in December 2017 and became licensed as a registered investment advisor in April 2018. In certain markets, Maia Wealth does business as Phyxius Financial Group, Integrated Financial Architects, Mana Financial Group, White Bison Wealth Management, Pathway Advisors Group, Cookie Wealth, SilverOak, and Hofkin Capital Management. The Advisor is owned directly by Marek Financial LLC, Dimond Ventures LLC, CTV Holdings LLC, and Bud & Thorne, LLC, and indirectly owned and operated by Scott Marek, Desmond Dimond, Chandler te Velde. Chandler te Velde is Chief Compliance Officer. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Maia Wealth. More information regarding affiliated entities under common ownership can be found in Item 10 of this document. We are committed to helping clients build, manage, and preserve their wealth, and to provide assistance that helps clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and Maia Wealth execute an engagement letter or client agreement. Investment and Wealth Management and Supervision Services We offer discretionary and non-discretionary investment management and investment supervisory services for a fee based on a percentage of your assets under management. These services include investment analysis, allocation of investments, quarterly portfolio reports, financial commentaries, and ongoing monitoring of client portfolios. We primarily allocate client assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt (bonds) and equity securities in accordance with their stated investment objectives. In some cases, our firm does utilize pre-built portfolios for clients based on their risk tolerance and time horizon. Clients have the ability to place reasonable restrictions on the types of investments that may be purchased in an account, however our Firm retains the right to decline to enter into a management agreement with any clients whose investment are contrary to the firm’s investment strategies. (Please see Item 16, Investment Discretion for additional information concerning discretionary authority.) If a non-discretionary relationship is in place, calls will be placed to the client presenting the recommendation made including a rebalancing recommendation and only upon your authorization will any action be taken on your behalf. Our clients should note that being in a discretionary or non-discretionary account does not affect the management of the accounts. It is the decision of the client on what type account they elect to open with our Firm: a discretionary account without prior notification of investment trades or a non- discretionary account as described above. Maia Wealth, LLC FORM ADV 2A Brochure 4  We will work with you to obtain necessary information regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. This information enables us to determine the portfolio or model best suited for your investment objective and needs. In performing our services, we shall not be required to verify any information received from you or from other professionals. If you request, we will recommend you engage the services of other professionals for implementation purposes. You have the right to decide whether or not to engage the services of any such recommended professional. Once we have determined the types of investments to be included in your portfolio and allocated them, we will provide ongoing portfolio review and management services. This approach requires us to review your portfolio at least quarterly. We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios and rebalance them based on the combination of our market views and your objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate written authorization from you. Where appropriate, we provide advice about any type of legacy position or other investment held in client portfolios. Clients will engage us to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks may exist that adversely affect an account’s performance. This could result in capital losses in your account. Use of Independent Managers Maia Wealth may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portfolio of a Client’s investment portfolio. In such instances, the Client will then enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. Maia Wealth may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. Maia Wealth will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated money manager[s] or investment advisor[s], will be provided with the advisor's Form ADV 2A (or a brochure that makes the appropriate disclosures). Maia Wealth, LLC FORM ADV 2A Brochure 5  Financial Planning Financial planning is available for a separate agreement and a separate fee. Through our Financial Planning process, we strive to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each family in mind, we offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer and family legacy objectives. Our team partners with our client’s other advisors (CPA, Estate Attorney, Insurance broker, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets and periodic updates. Our specific services in preparing your plan may include: • Review and clarification of your financial goals. • Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management and estate planning. • Creation of a unique plan for each goal you have including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession and other personal goals. • Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans, taxable and trust accounts that require special attention. • Design of a risk management plan including risk tolerance, risk avoidance, mitigation and transfer, including liquidity as well as various insurance and possible company benefits. • Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death. A written evaluation of each client's initial situation or Financial Plan is provided to the client. An annual review will be provided by the Adviser, if indicated by the Client and Advisor per the Financial Planning Agreement. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Estate Planning Services Maia Wealth uses Wealth.com to provide a holistic estate planning solution that allows clients to create, manage and administrate estate plans through a technology platform. Wealth.com facilitates an optional hybrid model where clients can start the process digitally, but still receive a human experience by consulting live with one of the local Trust and Estate attorneys. Maia Wealth purchases an annual license and access to the Wealth.com platform. Wealth.com allows clients to create estate planning documents to action the legacy objectives that our firm will design together. Once referred to Wealth.com, client enters the Wealth.com platform and is guided through the document creation process by Wealth.com, not by Maia Wealth. Though advisors can refer clients to the Wealth.com platform, Maia Wealth and its advisors are not involved with the drafting of the legal documents and do not have the ability to make selections for the client. With Advisor only access to Wealth.com, Maia Wealth and its advisor representatives can receive read-only visibility of the client account. This allows our advisors to assist clients in completing the process of creating and monitoring for optimization opportunities. Maia Wealth, LLC FORM ADV 2A Brochure 6  Retirement Plan Advisory Services- Guideline Platform Maia Wealth also offers Retirement Plan Services through the Guideline Platform. While the primary clients for these services will be sponsors of pension, profit sharing and 401(k) plans, Maia Wealth can also provide these services, where appropriate, to individuals and trusts, estates and charitable organizations. Maia Wealth will work closely with the client, the plan administrator and/or other third parties, to determine if Maia Wealth 's investment approach is consistent with the client's investment strategy. The Guideline Platform will offer Plan investment options and will be monitored according to the procedures and timing intervals determined by the client. Maia Wealth will not be involved in executing transactions within the relevant plan in providing these monitoring services. For pension, profit sharing and 401(k) plan clients where there are individual accounts with participants exercising control over assets in their own account ('self-directed plans''), Maia Wealth can provide educational support and investment workshops designed for the qualified plan participants. The nature of the topics to be covered will be determined by Maia Wealth and the client under the guidelines established in Section 404(c) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA"). The educational support and investment workshops will not provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations outside the scope of the retirement plan. As part of its Qualified Plan Service, limited to participant-directed plans, Maia Wealth also offers the sponsors of tax-qualified retirement plans managed model portfolios that the sponsor can then offer to its plan participants. Qualified plan sponsors engaging Maia Wealth to provide this service will have daily access to the performance of their plan participant accounts via a website serviced by the plan's record-keeper. Investment Platform Providers Maia Wealth may recommend that certain Clients implement their investment portfolios through Betterment Institutional, a division of Betterment LLC or ZOE Financial ZoeFin (herein “Investment Platform Providers”). These Investment Platform Providers offer what is often termed as “robo-advisor services”. Robo-advisor services offer an online wealth management service providing automated, algorithm-based portfolio management advice. Robo-advisors use technology to deliver similar services as traditional advisors, but generally only offer portfolio management and do not get involved in a Client’s personal situation, such as taxes and retirement or estate planning. Maia Wealth chose to affiliate with certain Investment Platform Providers due to the Investment Platform’s customized portfolio allocations, automated rebalancing, and competitive fees. Maia Wealth utilizes Investment Platform Providers as a complement to its comprehensive financial planning services to provide cost effective investing coupled with personalized financial planning. To establish accounts with Investment Platform Providers, the Client will also enter into one or more agreements with the chosen Investment Platform Provider that provides the authority for discretionary investment management by the Investment Platform. Maia Wealth remains the Client’s primary advisor and relationship contact and will select or construct a portfolio of ETFs and/or cash equivalents from the universe of investments included on the Investment Platform. Maia Wealth will have the discretionary authority to instruct Betterment Institutional with respect to portfolio construction, asset allocation and other investment decisions, subject to the limitations described herein. Betterment Institutional will implement the portfolio and be responsible for the discretionary trading of the ETFs in the Client’s portfolio, including the purchase and sale of investments and the automatic rebalancing back to targets. Maia Wealth, LLC FORM ADV 2A Brochure 7  Maia Wealth will work with each Client to construct a portfolio to meets the needs of the Client. The Client has limited ability to put restrictions on its accounts. The account[s] cannot contain investments that are not included in the Betterment Institutional universe of ETFs and cash equivalents. Betterment Institutional, under its discretionary authority, will automatically adjust and rebalance the Client’s accounts daily based on the drift tolerance established for the positions in the investment portfolio. The Advisor’s investment philosophy is long-term, but Maia Wealth may make such tactical overrides to take advantage of market pricing anomalies or strong market sectors. Maia Wealth does not actively trade in the Client’s account[s] and is also limited to a enter one allocation change per account per trading day through Betterment Institutional, the Client should be aware of these potential disadvantages. Prior to engaging Maia Wealth to provide investment advisory services, each Client is required to enter into an agreement with Maia Wealth that defines the terms, conditions, authority and responsibilities. These services may include: • Establishing an Investment Strategy – Maia Wealth in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Maia Wealth will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Maia Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Maia Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio. Financial Institution Consulting Services Maia Wealth provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s consulting services. Brokerage Customers have entered into a written advisory agreement with Maia Wealth. Disclosure Regarding Rollover Recommendations A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age Maia Wealth, LLC FORM ADV 2A Brochure 8  considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer and remains available to address any questions that a client or prospective client has regarding the oversight. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Participant Account Management (Discretionary) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Assets As of December 31, 2024, our Firm manages a total of $704,344,811 of regulatory assets under management. Our Firm manages $700,900,542 in discretionary assets and $3,444,269 in non-discretionary assets. ITEM 5 - FEES AND COMPENSATION Investment Management Fees and Compensation Maia Wealth charges a fee as compensation for providing Investment Management services on your account. These services include advisory services, trade entry, investment supervision, and other account-maintenance activities. Our recommended custodian charges may include transaction costs, custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for additional details. Investment advisory fees are paid monthly in arrears, at the end of each month, and are based on the market value of assets under management on the last day of the calendar month. The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. The maximum annual advisory fee for accounts paying a percentage of assets under management is 1.50%. The specific advisory fees are set forth in your Investment Advisory Agreement. Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account or other reasons agreed upon by us and you as the client. Maia Wealth, LLC FORM ADV 2A Brochure 9  The market value will be determined as reported by the Custodian. Maia Wealth will not have the authority or responsibility to value portfolio securities. Fees are assessed on all assets under management. Cash and money market balances will be included in billing. Margin balances are excluded from advisory fee billing. In certain circumstances, our fees and the timing of the fee payments may be negotiated. Our employees and their family- related accounts are charged a reduced fee for our services. Unless otherwise instructed by the client, we will aggregate asset amounts in accounts from your same household together to determine the advisory fee for all your accounts. We would do this, for example, where we also service accounts on behalf of your minor children, individual and joint accounts for a spouse, and/or other types of related accounts. This consolidation practice is designed to allow you the benefit of an increased asset total, which could potentially cause your account(s) to be assessed a lower advisory fee. The independent qualified custodian holding your funds and securities will debit your account directly for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be paid directly from your account held by the qualified custodian. Further, the qualified custodian agrees to deliver an account statement at least quarterly directly to you indicating all the amounts deducted from the account including our advisory fees. At our discretion, you may pay the advisory fees by check. You are encouraged to review your account statements for accuracy. The investment advisory Agreement may be terminated by the client without penalty. upon written notice to the other party. The management fee will be pro-rated to the date of termination, for the month in which the cancellation notice was given and the unearned fee refunded to you. Upon termination, you are responsible for monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those assets. In the event of client’s death or disability, Maia Wealth will continue management of the account until we are notified of client’s death or disability and given alternative instructions by an authorized party. Use of Independent Managers As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Financial Planning Fees Maia Wealth will negotiate the planning fees with you. Fees may vary based on the extent and complexity of your individual or family circumstances and the amount of your assets under our management. We will determine your fee for the designated financial advisory services based on a fixed fee arrangement described below. Financial Planning fees are fixed fees only and range from $1,000 to $25,000. Fees will be agreed in advance of services being performed. The fee will be determined based on factors including the complexity of your financial Maia Wealth, LLC FORM ADV 2A Brochure 10  situation, agreed upon deliverables, and whether or not you intend to implement any recommendations through Maia Wealth. Typically, we complete a plan within a month and will present it to you within 90 days of the contract date, provided that you have provided us all information needed to prepare the financial plan. Timing and payment of fees are negotiable and outlined in the financial planning agreement. You may terminate the financial planning agreement by providing us with written notice. Upon termination, fees will be prorated to the date of termination and any unearned portion of the fee will be refunded to you based on an hourly rate of $250.00. We will not require prepayment of more than $1,200 in fees per client, six (6) or more months in advance of providing any services. In no case are our fees based on, or related to, the performance of your funds or investments. When both investment management or plan implementation and financial planning services are offered, there is a conflict of interest since there is an incentive for us offering financial planning services to recommend products or services for which Maia Wealth receives compensation. However, Maia Wealth will make all recommendations independent of such considerations and based solely on our obligations to consider your objectives and needs. As a financial-planning client, you have the right not to act upon any of our recommendations and not affect the transaction(s) through us if you decide to follow the recommendations. Estate Planning Service Fees Maia Wealth offers estate planning services through wealth.com for a negotiable flat, fixed fee ranging between $500- $2500. These services are available to all Maia Wealth clients. Guideline Retirement Plan Advisory Service Fees For Retirement Plan Advisory Services compensation, we charge an annual fee as negotiated with the client and disclosed in the Investment Advisory Agreement. The compensation method is explained and agreed upon in advance before any services are rendered. Fees are 0.50% of assets under management. Investment Platform Provider Service Fees Investment Platform Providers will charge an asset-based fee that is generally included with the advisory fee listed above. Investment Platform Provider fees include the securities transaction fees for all trades. Maia Wealth will only receive its investment advisory fees as detailed above and does not share in any fees earned by the Investment Platform Providers. The Client, prior to entering into an agreement with the Investment Platform Provider, will be provided with the Investment Platform's Form ADV Part 2A (or a brochure that makes the appropriate disclosures). Fee and the billing methods may vary from the Platform Providers but are clearly disclosed in the client engagement. In the event that a client should wish to terminate their relationship with the Investment Platform Provider, the terms for the termination will be set forth in the respective agreements between the Client and that Independent Manager. Maia Wealth will assist the Client with the termination and transition as appropriate. Maia Wealth, LLC FORM ADV 2A Brochure 11  Financial Institutional Consulting Services Maia Wealth receives a consulting fee based on the Assets Under Management from Brokerage Customers who have provided written consent to a broker/dealer to receive the investment consulting service from Maia Wealth and have entered into a written advisory contract with Maia Wealth. The consulting fee is calculated from the Assets Under Management as of the end of a calendar quarter period multiplied by the annualized rate of from 0.50% to 0.85% basis points. The initial fee is paid only after the completion of one full calendar quarter period following the date of the executed agreement with broker/dealers. Held Away Discretionary Accounts Relationship with Pontera We charge an annual advisory fee for services provided to these held away accounts, which is deducted on a quarterly basis. Fees are based on the value of the assets within these held away accounts. All advisory fee calculations for the held away discretionary account services are facilitated through a third-party nonaffiliated service, Pontera. Maia Wealth is responsible for sending the final invoice to the Client and the Client sends advisory fee payment directly to Maia Wealth via check. ACH and Credit Card Payments Through Square Financial planning fees can be paid via check to our Firm from your personal bank account or can be invoiced and processed through a third-party nonaffiliated service, Square. Clients will be asked to set up their bank account or credit card at Square to enable credit card or ACH payments. While Square allows firms like Maia Wealth to receive payments directly from the client’s credit card or bank account, it does not give Maia Wealth access to the bank account itself, nor to any of the client’s credit card or bank account information. Maia Wealth is not able to initiate any additional payments via Square as agreed upon and outlined in the Agreement. Administrative Services Provided by Orion Investment Management LLC We have contracted with Orion to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance, quarterly performance evaluations, payable reports, web site administration, models, trading platforms, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Orion will have access to information on the client accounts, but Orion will not serve as an investment advisor to our clients. Maia Wealth and Orion are non-affiliated companies. Orion charges our Firm an annual fee for each account administered by Orion. Please note that the fee charged to the client will not increase due to the annual fee Maia Wealth pays to Orion, the annual fee is paid from the portion of the management fee retained by Maia Wealth. Additional Fees and Expenses In addition to the advisory fees paid to Maia Wealth, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges may include securities brokerage commissions, transaction fees, custodial fees, fees charged by the Independent Managers, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), 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. Maia Wealth’s brokerage practices are described at length in Item 12, below. Neither our Firm nor its supervised persons accept compensation for the Maia Wealth, LLC FORM ADV 2A Brochure 12  sale of securities or other investment products. Further, our firm does not share in any of these additional fees and expenses outlined above. ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client account (so-called performance-based fees) nor engage in side by side management. ITEM 7 - TYPES OF CLIENTS We provide investment advice to individuals, high net worth individuals, trusts, estates, corporations or businesses. We do not have a minimum initial account value. ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Investment Strategies Maia Wealth primarily employs fundamental, technical and cyclical analysis methods in developing investment strategies for its Clients. Technical, and cyclical methods of analysis may also be utilized when deemed appropriate to achieve a Client’s investment objective. Research and analysis from Maia Wealth is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market pattern and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Maia Wealth will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that Maia Wealth is recommending. The risks with cyclical analysis are similar to those of technical analysis. As noted above, Maia Wealth generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Maia Wealth will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Maia Wealth, LLC FORM ADV 2A Brochure 13  Maia Wealth may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Clients should be aware that buying and selling of positions that are more short-term in nature will result in additional securities transactions costs, which will reduce the amount of returns on the investments.. Risk of Loss Clients must understand that past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different types of investments there will be varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, Maia Wealth is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Investors should be aware that accounts are subject to the following risks: Market Risk Even a long-term investment approach cannot guarantee a profit. Economic, political and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon liquidation. Foreign Securities and Currency Risk Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. Capitalization Risk Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. Interest Rate Risk In a rising rate environment, the value of fixed-income securities generally declines and the value of equity securities may be adversely affected. Credit Risk Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may effect a security’s value and, thus, impact the fund’s performance. Exchange-Traded Funds Maia Wealth, LLC FORM ADV 2A Brochure 14  ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset value.” Performance of Underlying Managers We select the mutual funds and ETFs in the asset allocation models. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. Alternative Risk Investments classified as "alternative investments" may include a broad range of underlying assets including, but not limited to, hedge funds, private equity, venture capital, and registered, publicly traded securities. Alternative investments are speculative, not suitable for all clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with a single advisor; absence of information regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees than other investment options such as mutual funds. The SEC requires investors be accredited to invest in these more speculative alternative investments. Investing in a fund that concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Individual Stocks The performance of individual stocks is subject to market risk, including the possible loss of principal. The price of the individual stock will fluctuate through the trading day and vary from day to day. This means that a price that an individual stock is bought or sold at vary even if the transactions are processed during the same trading day, especially when trading is heavy. Leveraged ETF Risks Leveraged ETFs seek to deliver multiples of the performance of the index or benchmark they track. These ETFs attempt to deliver some multiple of an index's daily returns (positive or negative). Please consider the implications to both the upside and the downside of multipliers. While it may seem that a 2x multiplier is a benefit in an up- market cycle' it is important to remember that the same multiplier applies when the Maia Wealth, LLC FORM ADV 2A Brochure 15  ETF moves against the market. This could potentially result in significant losses, and highlights the additional risk associated with Leveraged ETFs. Structured Notes Risks Structured products are designed to facilitate highly customized risk-return objectives. While structured products come in many different forms, they typically consist of a debt security that is structured to make interest and principal payments based upon various assets, rates, or formulas. Many structured products include an embedded derivative component. Structured products may be structured in the form of a security, in which case these products may receive benefits provided under federal securities law, or they may be cast as derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation. Investment in structured products includes significant risks, including valuation, liquidity, price, credit, and market risks. One common risk associated with structured products is a relative lack of liquidity due to the highly customized nature of the investment. Moreover, the full extent of returns from the complex performance features is often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment decision rather than a means of getting in and out of a position with speed and efficiency. Another risk with structured products is the credit quality of the issuer. Although the cash flows are derived from other sources, the products themselves are legally considered to be the issuing financial institution’s liabilities. The vast majority of structured products are from high- investment-grade issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of alternative structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or commissions among broker- dealers. Cybersecurity Risks In addition to the Material Investment Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at our firm or one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information, and generally compromise our Firm’s ability to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk that cybersecurity breaches may not be detected. ITEM 9 - DISCIPLINARY INFORMATION Maia Wealth does not have any legal, financial or other “disciplinary” item to report. Maia Wealth, LLC FORM ADV 2A Brochure 16  ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Insurance Certain IARs of Maia Wealth, LLC carry active insurance licenses. IARs of Maia Wealth may act as agents appointed with various life, disability or other insurance companies, receive commissions, trails, or other compensation from the respective product sponsors and/or as a result of effecting insurance transactions for clients. Compensation from the sale of insurance products is run through Maia Insurance, LLC. Clients should note that they have the right to decide whether to act on the recommendation and the right to purchase any insurance products through Maia Wealth Insurance, LLC or its IAR or any licensed insurance agent not affiliated with Maia Wealth. This creates a conflict of interest. We recognize the fiduciary responsibility to act in the best interest of our clients and have established policies in this regard to mitigate any conflicts of interest. Marek Financial LLC Scott Marek is the owner of Marek Financial LLC (“Marek Financial”). Marek Financial is a holding company for the partial ownership of Maia Wealth. In certain markets this entity does business as Bullet Wealth. Dimond Ventures LLC Desmond Dimond is the owner of Dimond Ventures LLC (“Dimond Ventures”). Dimond Ventures is a holding company for the partial ownership of Maia Wealth. CTV Holdings LLC Chandler te Velde is the owner of CTV Holdings LLC (“CTV Holdings”). CTV Holdings is a holding company for the partial ownership of Maia Wealth. Chandler te Velde is also managing member of the following entities that she uses for personal bookkeeping and investment purposes: Saturns Inheritance, LLC, and Chan Machine I, LLC. Bud & Thorne LLC Andrew Horton and Benjamin Horton are the owners of Bud & Thorne LLC (“Bud & Thorne”). Bud & Thorne is a holding company for the partial ownership of Maia Wealth. Financial Institution Consulting Services Maia Wealth has agreement(s) with a broker/dealer to provide investment consulting services to Brokerage Customers. The broker/dealer does not pay compensation to Maia Wealth for providing investment consulting services to Customers. This consulting arrangement does not include assuming discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of securities. These consulting services offered to Brokerage Customers may include a general review of Brokerage Customers’ investment holdings, which may or may not result in Destiny Capital’s Investment Adviser Representative making specific securities recommendations or offering general investment advice. Brokerage Customers that are advisory clients will execute a written advisory agreement directly with Destiny Capital. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive investment consulting services from Destiny Capital; by Maia Wealth not accepting or billing for additional compensation on broker/dealers’ Assets Under Management beyond the consulting fees disclosed in Item 5 in connection with the investment consulting services; and by Maia Wealth not engaging as, or holding itself out to the public as, a securities broker/dealer. Maia Wealth is not affiliated with any broker/dealer. Maia Wealth, LLC FORM ADV 2A Brochure 17  Clients should be aware that the ability to receive additional compensation by our Firm and its management persons or employees creates conflicts of interest that impair the objectivity of the Firm and these individuals when making advisory recommendations. Our Firm endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps, among others to address this conflict: • we disclose to clients the existence of all material conflicts of interest, including the potential for the Firm and our employees to earn compensation from advisory clients in addition to the Firm's advisory fees; • we disclose to clients that they have the right to decide to purchase recommended investment products from our employees; • we collect, maintain and document accurate, complete and relevant client background information, • including the client’s financial goals, objectives, and liquidity needs; the Firm conducts regular reviews of each client advisory account to verify that all recommendations made to a client are in the best interest of the client’s needs and circumstances; • we require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; • we periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by the Firm; and • we educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. Our Firm does not have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. Our firm nor any of its management persons are registered or have an application pending to register as a broker- dealer or a registered representative of a broker-dealer. ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Maia Wealth and persons associated with us are allowed to invest for their own accounts or to invest in the same securities or other investments that we recommend or acquire for your account, and may engage in transactions that are the same as or different than transactions recommended to or made for your account. This creates a conflict of interest. We recognize the fiduciary duty to place your interests first and have established policies to act in your best interest and to mitigate conflicts of interest. We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, the prohibition against the use of inside information. The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel regarding the firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and must act with complete propriety at all times, protect the reputation of Maia Wealth, guard against violation of the securities laws, and establish procedures for personnel to follow so that we may determine whether their personnel are complying with the firm’s ethical principles. We have established the following restrictions to ensure our firm’s fiduciary responsibilities: Maia Wealth, LLC FORM ADV 2A Brochure 18  1. No director, officer or supervised employee of Maia Wealth shall prefer his or her own interest to that of the advisory client. Trades for supervised employees are traded alongside client accounts. 2. We maintain a list of all securities holdings of anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of Maia Wealth. 3. We emphasize the unrestricted right of the client to decline to implement any advice rendered, except in situations where we are granted discretionary authority of the client’s account. 4. We emphasize the unrestricted right of the client to select and choose any custodian the client wishes (except in non-ERISA Plan accounts where we are granted discretionary authority). 5. We require that all supervised individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 6. Any supervised individual not in observance of the above may be subject to termination. You may request a complete copy of our Code by contacting us at the address, telephone or email on the cover page of this Part 2; Attn: Chief Compliance Officer. ITEM 12 - BROKERAGE PRACTICES The Custodian and Brokers We Use Investment Management Services Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. Advisor Services (“Schwab”), a registered broker- dealer, member SIPC, as the qualified custodian. We are independently owned and operated, and unaffiliated with Schwab. Schwab will hold client assets in a brokerage account, and buy and sell securities when we instruct them to. While we recommend that clients use Schwab as custodian/broker, client must decide whether to do so and open accounts with Schwab by entering into account agreements directly with them. The Client opens the accounts with Schwab. The accounts will always be held in the name of the client and never in Maia Wealth's name. How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: 1. Combination of transaction execution services and asset custody services (generally without a separate fee for custody) Maia Wealth, LLC FORM ADV 2A Brochure 19  2. Capability to execute, clear, and settle trades (buy and sell securities for client accounts) 3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) 4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) 5. Availability of investment research and tools that assist us in making investment decisions 6. Quality of services 7. Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices 8. Reputation, financial strength, and stability 9. Prior service to Maia Wealth and our other clients 10. Availability of other products and services that benefit us, as discussed below (see Products and Services Available to Us from Schwab) Client Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge separately for custody services. However, Schwab receives compensation by charging ticket charges or other fees on trades that it executes or that settle into clients’ Schwab accounts. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see How We Select Brokers/Custodians). Products and Services Available to Us from Schwab Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like us. They provide Maia Wealth and our clients with access to its institutional brokerage, 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; others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis (we do not have to request them) and at no charge to us. These are considered soft dollar benefits because there is an incentive to do business with Schwab. This creates a conflict of interest. We recognize the fiduciary responsibility to act in your best interest and have established policies in this regard to mitigate any conflicts of interest. Following is a more detailed description of Schwab’s support services: Services That Benefit Our Clients 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 our clients and their accounts. Services That May Not Directly Benefit Our Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit our clients or their accounts. These products and services assist us in managing and administering our clients’ Maia Wealth, LLC FORM ADV 2A Brochure 20  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: 1. Provide access to client account data (such as duplicate trade confirmations and account statements) 2. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts 3. Provide pricing and other market data 4. Facilitate payment of our fees from our clients’ accounts 5. Assist with back-office functions, recordkeeping, and client reporting 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: 1. Educational conferences and events 2. Consulting on technology, compliance, legal, and business needs 3. Publications and conferences on practice management and business succession 4. Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions. We believe that our selection of Schwab as custodian and broker is in the best interests of our clients. Some of the products, services and other benefits provided by Schwab benefit Maia Wealth and may not benefit our client accounts. Our recommendation or requirement that you place assets in Schwab's custody may be based in part on benefits Schwab provides to us, or our agreement to maintain certain Assets Under Management at Schwab, and not solely on the nature, cost or quality of custody and execution services provided by Schwab. This is a conflict of interest. We believe this arrangement is in the clients best interest and have developed polices to mitigate this conflict. We place trades for our clients' accounts subject to its duty to seek best execution and its other fiduciary duties. Schwab's execution quality may be different than other custodians. Brokerage for Client Referrals Maia Wealth does not receive client referrals from any custodian or third party in exchange for using that custodian or third party. Aggregation and Allocation of Transactions Maia Wealth, LLC FORM ADV 2A Brochure 21  Maia Wealth may aggregate transactions if we believe that aggregation is consistent with the duty to seek best execution for our clients and is consistent with the disclosures made to clients and terms defined in the client investment advisory agreement. No advisory client will be favored over any other client, and each account that participates in an aggregated order will participate at the average share price (per custodian) for all transactions in that security on a given business day. Maia Wealth aggregates trades of our personnel with those of client accounts. If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis. If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we will base the allocation on other relevant factors, which may include: 1. When only a small percentage of the order is executed, with respect to purchase allocations, allocations may be given to accounts high in cash; 2. With respect to sale allocations, allocations may be given to accounts low in cash; 3. We may allocate shares to the account with the smallest order, or to the smallest position, or to an account that is out of line with respect to security or sector weightings, relative to other portfolios with similar mandates; 4. We may allocate to one account when that account has limitations in its investment guidelines prohibiting it from purchasing other securities that we expect to produce similar investment results and that can be purchased by other accounts in the block; 5. If an account reaches an investment guideline limit and cannot participate in an allocation, we may reallocate shares to other accounts. For example, this may be due to unforeseen changes in an account’s assets after an order is placed; 6. If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, we may exclude the account(s) from the allocation and disgorge any profits. Generally, de minimis allocations do not exceed 5% of the total allocation. Additionally, we may execute the transactions on a pro-rata basis. 7. We will document the reasons for any deviation from a pro-rata allocation. Trade Errors We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and we will absorb any loss resulting from the trade error if the error was caused by the firm. If the error is caused by the custodian, the custodian will be responsible for covering all trade error costs. If an investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit or profit from trade errors. We do not routinely recommend, request or require that you direct us to execute transaction through a specified custodian. Additionally, we typically do not permit you to direct brokerage. We place trades for your account subject to our duty to seek best execution and other fiduciary duties. ITEM 13 - REVIEW OF ACCOUNTS Maia Wealth, LLC FORM ADV 2A Brochure 22  Account Reviews and Reviewers – Investment Supervisory Services The underlying securities within the investment supervisory services are monitored on at least a monthly basis. These reviews will be made by the firm’s investment advisor representatives. An annual review with the client is usually conducted in person or by telephone. The purpose of all these reviews is to ensure that the investment plan continues to be implemented in a manner which matches your objectives and risk tolerances. More-frequent reviews may be triggered by material changes in variables such as your individual circumstances, or the market, political or economic environment. You are urged to notify us of any changes in your personal circumstances. Statements and Reports Maia Wealth will provide clients with Performance/Position summary reports at least annually. Reports may also be provided at every client meeting. Communication to clients will be done on an as needed basis with a minimum of 1 contact per year. The custodian for the individual client’s account will also provide clients with an account statement at least quarterly. You are urged to compare the reports provided by Maia Wealth against the account statements you receive directly from your account custodian. Financial Planning clients (i.e. those who have no assets under management with us in our advisory program) will receive no regular reports from the Firm. ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION From time to time, our Firm and our financial advisors receive referrals or leads of potential clients from unaffiliated third parties in exchange for cash compensation (each a “third-party promoter arrangement”). Any third-party promoter arrangement entered into by our Firm and a promoter is operated pursuant to a written agreement in accordance with Rule 206(4)-3 of the Advisers Act. Our Firm and our financial advisors may pay cash compensation to the solicitor in the form of a flat fee or as a percentage of asset-based advisory fees received from a referred client. The details of the particular promoter arrangement and compensation paid to the promoter by us or our financial advisors will be disclosed to each referred client through a separate written disclosure. The advisory fees paid by any referred client are neither increased nor reduced because of the compensation paid to a promoter by our Firm or our financial advisors. The client must acknowledge receipt of the Promoters Disclosure describing the arrangements and nature of the relationship between professional partner and the Firm prior to any such payments being made. Our Firm may be asked to recommend a financial professional, such as an attorney, accountant, or mortgage broker. In such cases, our Firm may receive direct compensation in return for any referrals made to individuals or firms in our professional network. Clients must independently evaluate these firms or individuals before engaging in business with them and clients have the right to choose any financial professional to conduct business. Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm does not pay any direct compensation in return for any referrals made to our Firm. Our Firm does recognize the fiduciary responsibility to place client interests first and have established policies in this regard to mitigate any conflicts of interest. Maia Wealth, LLC FORM ADV 2A Brochure 23  We receive an economic benefit from Schwab in the form of the support products and services it makes available to us. These products and services, how they benefit us, and the related conflicts of interest are described above under Item 12 Brokerage Practices. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. ITEM 15 - CUSTODY Custody has been defined by regulators as having access or control over client funds and/or securities. Our firm does not have physical custody of funds or securities, as it applies to investment advisors. Deduction of Advisory Fees Our firm has custody of the funds and securities solely as a consequence of its authority to make withdrawals from client accounts to pay its advisory fee. For all accounts, our firm has the authority to have fees deducted directly from client accounts. Our firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from our Firm. When you have questions about your account statements, you should contact our Firm or the qualified custodian preparing the statement. Please refer to Item 5 for more information about the deduction of adviser fees. Standing Letters of Authorization Our firm is also deemed to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. We do not have a beneficial interest on any of the accounts we are deemed to have Custody where SLOAs are on file. In addition, account statements reflecting all activity on the account(s), are delivered directly from the qualified custodian to each client or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from us. When you have questions about your account statements, you should contact us, your Advisor or the qualified custodian preparing the statement. Please refer to Item 5 for more information about the deduction of advisor fees. ITEM 16 - INVESTMENT DISCRETION For all discretionary accounts, prior to engaging Maia Wealth to provide investment advisory services, you will enter a written Agreement with us granting the firm the authority to supervise and direct, on an on-going basis, investments in accordance with the client’s investment objective and guidelines. In addition, you will need to execute additional documents required by the Custodian to authorize and enable Maia Wealth, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell or exchange securities in and for your accounts. We are authorized, in our discretion and without prior consultation with you to: (1) buy, sell, exchange and trade any stocks, bonds or other securities or assets and (2) determine the amount of securities to Maia Wealth, LLC FORM ADV 2A Brochure 24  be bought or sold and (3) place orders with the custodian. Any limitations to such authority will be communicated by you to us in writing. The limitations on investment and brokerage discretion held by Maia Wealth for you are: 1. For discretionary clients, we require that we be provided with authority to determine which securities and the amounts of securities to be bought or sold. 2. Any limitations on this discretionary authority shall be in writing as indicated on the Investment Advisory Agreement. You may change/amend these limitations as required. In some instance, we may not have discretion. We will discuss all transactions with you prior to execution or you will be required to make the trades if in an employer sponsored account. ITEM 17 - VOTING CLIENT SECURITIES Maia Wealth will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent third-party at your own discretion. You designate proxy voting authority in the custodial account documents. You must ensure that proxy materials are sent directly to you or your assigned third party. We do not take action with respect to any securities or other investments that become the subject of any legal proceedings, including bankruptcies. Clients are able to contact our office with questions about a particular proxy solicitation by phone at (720) 644-8803. Class Action Suits - A class action is a procedural device used in litigation to determine the rights of and remedies, if any, for large numbers of people whose cases involve common questions of law and/or fact. Class action suits frequently arise against companies that publicly issue securities, including securities recommended by investment advisors to clients. With respect to class action suits and claims, you will have the responsibility for class actions or bankruptcies, involving securities purchased for or held in your account. We do not provide such services and are not obligated to forward copies of class action notices we may receive to you. ITEM 18 - FINANCIAL INFORMATION This item is not applicable to this brochure. We do receive prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. Maia Wealth, LLC FORM ADV 2A Brochure 25