MAR WEALTH MANAGEMENT SERVICES, LLC

MAR Wealth Management Services, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of MAR Wealth Management Services, LLC. If you have any questions about the contents of this brochure, please contact us at (800) 708-6285 or by email at: mramos@marwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about MAR Wealth Management Services, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. MAR Wealth Management Services, LLC’s CRD number is: 167335 MAR Wealth Management Services, LLC 500 Australian Avenue South, Suite 600 West Palm Beach, FL 33401 Main: (800) 708-6285 Fax: (305) 390-2536 admin@marwealth.com www.marwealth.com www.marwealthmanagement.com Registration does not imply a certain level of skill or training. Version Date: 03/23/2026  Item 2: Material Changes There are no material changes in this brochure from the last annual updating amendment on 03/31/2025 of MAR Wealth Management Services, LLC. Material changes relate to MAR Wealth Management Services, LLC’s policies, practices or conflicts of interests. i  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................................................................................... i Item 3: Table of Contents .......................................................................................................................................................................................... ii Item 4: Advisory Business ......................................................................................................................................................................................... 1 A. Description of the Advisory Firm................................................................................................................................................................... 1 B. Types of Advisory Services.............................................................................................................................................................................. 1 Investment Supervisory Services ................................................................................................................................................................... 1 Selection of Other Advisers ............................................................................................................................................................................. 1 Financial Planning ............................................................................................................................................................................................ 1 Selection of Other Advisers ............................................................................................................................................................................. 2 Services Limited to Specific Types of Investments ...................................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions .......................................................................................................................... 2 D. Wrap Fee Programs .......................................................................................................................................................................................... 2 E. Amounts Under Management ......................................................................................................................................................................... 2 Item 5: Fees and Compensation ................................................................................................................................................................................ 3 A. Fee Schedule ...................................................................................................................................................................................................... 3 Investment Supervisory Services Fees ........................................................................................................................................................... 3 Selection of Other Advisers Fees .................................................................................................................................................................... 3 Financial Planning Fees ................................................................................................................................................................................... 3 Fixed Fees .......................................................................................................................................................................................................... 3 Hourly Fees ....................................................................................................................................................................................................... 4 B. Payment of Fees................................................................................................................................................................................................. 4 Payment of Investment Supervisory Fees ..................................................................................................................................................... 4 Payment of Selection of Other Advisers Fees ............................................................................................................................................... 4 Payment of Financial Planning Fees .............................................................................................................................................................. 4 C. Clients Are Responsible For Third Party Fees .............................................................................................................................................. 5 D. Prepayment of Fees .......................................................................................................................................................................................... 5 E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................................ 5 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................ 5 Item 7: Types of Clients ............................................................................................................................................................................................. 5 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ........................................................................................... 6 A. Methods of Analysis and Investment Strategies .................................................................................................................................. 6 Methods of Analysis ........................................................................................................................................................................................ 6 Charting analysis .............................................................................................................................................................................................. 6 Fundamental analysis ...................................................................................................................................................................................... 6 ii  Technical analysis ............................................................................................................................................................................................. 6 Cyclical analysis ............................................................................................................................................................................................... 6 Investment Strategies ....................................................................................................................................................................................... 6 B. Material Risks Involved .......................................................................................................................................................................... 6 Methods of Analysis ........................................................................................................................................................................................ 6 Fundamental analysis ...................................................................................................................................................................................... 6 Technical analysis ............................................................................................................................................................................................. 6 Cyclical analysis ............................................................................................................................................................................................... 7 Investment Strategies ....................................................................................................................................................................................... 7 C. Risks of Specific Securities Utilized ....................................................................................................................................................... 7 Item 9: Disciplinary Information .............................................................................................................................................................................. 8 A. Criminal or Civil Actions ........................................................................................................................................................................ 8 B. Administrative Proceedings ................................................................................................................................................................... 8 C. Self-regulatory Organization (SRO) Proceedings ................................................................................................................................ 9 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................... 9 A. Registration as a Broker/Dealer or Broker/Dealer Representative .................................................................................................. 9 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ................... 9 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests .............................................. 9 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections .................................. 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................... 10 A. Code of Ethics ......................................................................................................................................................................................... 10 B. Recommendations Involving Material Financial Interests ............................................................................................................... 10 C. Investing Personal Money in the Same Securities as Clients ............................................................................................................ 10 D. Trading Securities At/Around the Same Time as Clients’ Securities ............................................................................................. 11 Item 12: Brokerage Practices.................................................................................................................................................................................... 11 A. Factors Used to Select Custodians and/or Broker/Dealers ............................................................................................................. 11 1. Research and Other Soft-Dollar Benefits ........................................................................................................................................ 11 2. Brokerage for Client Referrals ......................................................................................................................................................... 12 3. Clients Directing Which Broker/Dealer/Custodian to Use ........................................................................................................ 12 B. Aggregating (Block) Trading for Multiple Client Accounts ............................................................................................................. 12 Item 13: Reviews of Accounts ................................................................................................................................................................................. 12 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ............................................................................... 12 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................................................................ 12 C. Content and Frequency of Regular Reports Provided to Clients ..................................................................................................... 13 Item 14: Client Referrals and Other Compensation ............................................................................................................................................. 13 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ...... 13 B. Compensation to Non – Advisory Personnel for Client Referrals ................................................................................................... 14 Item 15: Custody ....................................................................................................................................................................................................... 14 iii  Item 16: Investment Discretion ............................................................................................................................................................................... 15 Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................................................. 15 Item 18: Financial Information ................................................................................................................................................................................ 15 A. Balance Sheet .......................................................................................................................................................................................... 15 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ............................... 15 C. Bankruptcy Petitions in Previous Ten Years ...................................................................................................................................... 15 Item 19: Requirements For State Registered Advisers ......................................................................................................................................... 16 A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background .......................... 16 B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) .................. 16 C. How Performance-based Fees are Calculated and Degree of Risk to Clients ................................................................................ 16 D. Material Disciplinary Disclosures for Management Persons of this Firm ...................................................................................... 16 E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) ..................................................... 16 iv  Item 4: Advisory Business A. Description of the Advisory Firm MAR Wealth Management Services, LLC is a Limited Liability Company organized in the state of Florida. The firm was formed in May of 2012 and the principal owners are Maricela A. Ramos and Christian M. Ramos. B. Types of Advisory Services MAR Wealth Management Services, LLC (hereinafter “MAR”) offers the following services to advisory clients: Investment Supervisory Services MAR offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. MAR creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring MAR evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. MAR will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Selection of Other Advisers MAR may direct clients to third-party investment advisers. Before selecting other advisers for clients, MAR will always ensure those other advisers are properly licensed or registered as investment adviser. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and 1  debt/credit planning. These services are based on fixed fees or hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. Selection of Other Advisers MAR may direct clients to third party money managers. The fee charged by the third party will be separate and distinct from the fee charged by MAR for this service. Before selecting other advisors for clients, MAR will always ensure those other advisors are properly licensed or registered as investment advisor. Services Limited to Specific Types of Investments MAR generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, hedge funds, REITs, and government securities. MAR may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions MAR offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent MAR from properly servicing the client account, or if the restrictions would require MAR to deviate from its standard suite of services, MAR reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. MAR does not participate in any wrap fee programs. E. Amounts Under Management MAR has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $75,726,133.00 $49,389,067.00 12/31/2025 2  Item 5: Fees and Compensation A. Fee Schedule Investment Supervisory Services Fees Total Assets Under Management Annual Fee All Assets Under Management 1.00% These fees are negotiable depending upon the needs of the client and complexity of the situation and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Fees are paid monthly in advance, and clients may terminate their contracts with thirty days’ written notice. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Refunds are given on a prorated basis, based on the number of days remaining in a month at the point of termination. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the month up to and including the day of termination. (*The daily rate is calculated by dividing the monthly AUM fee by the number of days in the termination month). Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Selection of Other Advisers Fees MAR may direct clients to third-party investment advisers. MAR will be compensated via a fee share from the advisers to which it directs those clients. This relationship will be memorialized in each contract between MAR and each third-party adviser. The fees shared will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. Financial Planning Fees Fixed Fees Depending upon the complexity of the situation and the needs of the client, the rate for creating client financial plans is between $1,000 and $10,000. Fees are paid in arrears upon completion. Because fees are charged in arrears, no refund is necessary. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Clients may terminate their contracts without penalty within five business days of signing the advisory contract. 3  Hourly Fees The hourly fee for these services is $250. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Fees are paid in arrears upon completion. Because fees are charged in arrears, no refund is necessary. Clients may terminate their contracts without penalty within five business days of signing the advisory contract. Extraordinary Financial Consulting Services or Complex Projects: In some cases, where the amount of time and/or resources required cannot be clearly determined at the commencement of the services, or if the client desires a specific financial planning services not included within the scope of engagement of the Investment Advisory Agreement, the client agrees to pay MAR’s basic rates, payable after consultation or services have been provided. Outside Investments: The advisory service provides for the inclusion and coordination of Client investment assets wherever held for pursuing the client’s goals and objectives. The fee schedule for investment advisory services for assets that are not held at Advisor’s primary custodians, such as but not limited to 401(k), annuity, executive compensation program, 403(b), 529 Plans, or direct illiquid investments held by a third party corporate trustee, will be determined in the contract between MAR and the client. B. Payment of Fees Payment of Investment Supervisory Fees Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid monthly in advance. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected and will be disclosed to the client prior to entering into a relationship with the third-party advisor. Payment of Financial Planning Fees Hourly Financial Planning fees are paid via check or as a debit to the client account in arrears upon completion. Because fees are charged in arrears, no refund is necessary. Fixed Financial Planning fees are paid via check or as a debit to the client account in arrears upon completion. Because fees are charged in arrears, no refund is necessary. 4  C. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by MAR. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees MAR collects fees in advance and in arrears. Fees collected in advance will be returned within thirty days to the client via check. For all asset-based fees paid in advance the fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the month up to and including the day of termination. (*The daily rate is calculated by dividing the monthly AUM fee by the number of days in the termination month). E. Outside Compensation For the Sale of Securities to Clients Neither MAR nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management MAR does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients MAR generally provides investment advice and/or management supervisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Charitable Organizations ❖ Businesses 5  Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis MAR’s methods of analysis include charting analysis, fundamental analysis, technical analysis, and cyclical analysis. Charting analysis involves the use of patterns in performance charts. MAR uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involved the analysis of business cycles to find favorable conditions for buying and/or selling a security. Investment Strategies MAR uses long term trading and short-term trading strategies. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in solely using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term. 6  Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns and 2) if too many investors begin to implement this strategy, it changes the very cycles they are trying to take advantage of. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short term trading generally holds greater risk and clients should be aware that there is a material risk of loss using any of those strategies. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized MAR generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above). Equity investment generally refers to buying shares of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the investment may incur a loss. Treasury Inflation Protected/Inflation Linked Bonds: The Risk of default on these bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Fixed Income is an investment that guarantees fixed periodic payments in the future that may involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of principal risk, etc. Debt securities carry risks such as the possibility of default on the principal, fluctuation in interest rates, and counterparties being unable to meet obligations. Stocks & Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). 7  Real Estate funds face several kinds of risk that are inherent in this sector of the market. Liquidity risk, market risk and interest rate risk are just some of the factors that can influence the gain or loss that is passed on to the investor. Liquidity and market risk tend to have a greater effect on funds that are more growth-oriented, as the sale of appreciated properties depends upon market demand. Conversely, interest rate risk impacts the amount of dividend income that is paid by income-oriented funds. Hedge Funds are not suitable for all investors and involve a high degree of risk due to several factors that may contribute to above average gains or significant losses. Such factors include leveraging or other speculative investment practices, commodity trading, complex tax structures, a lack of transparency in the underlying investments, and generally the absence of a secondary market. REITs have specific risks including valuation due to cash flows, dividends paid in stock rather than cash, and the payment of debt resulting in dilution of shares. Precious Metal ETFs (Gold, Silver, Palladium Bullion backed “electronic shares” not physical metal): Investing in precious metal ETFs carries the risk of capital loss. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability and inflation. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings On May 4, 2018 MAR signed a Stipulation and Consent Order with the State of Florida without admitting or denying the findings. MAR agrees to Cease and Desist from violating Chapter 517, Florida Statutes, and to pay an administrative fine of $7,000.00. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. 8  Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither MAR nor its representatives are registered as or have pending applications to become a broker/dealer or as representatives of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither MAR nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Maricela A. Ramos is co-trustee of four (4) trust accounts and co-trustee of two (2) inherited IRAs that are managed by MAR. Maricela A. Ramos is a co-owner of a joint tenants with rights of survivorship (JTWROS) account and a board member of four (4) charitable foundation whose accounts are managed by MAR. Maricela A. Ramos is sole trustee of one (1) trust account that is managed by MAR. Maricela A. Ramos’s IRA owns two (2) rental apartments. Maricela A. Ramos owns 50% of a property of which a portion is being rented. Maricela A. Ramos owns 33.33% of EXE Vending Services, LLC, a vending machine business. Maricela A. Ramos also owns one (1) unsecured loan to EXE Vending Services, LLC. Maricela A. Ramos spends an estimated ten (10) hours per month in assisting with the operations of EXE Vending Services, LLC. MAR owns a business investment account held at Charles Schwab & Co., Inc. and managed by MAR which is invested in MAR’s Moated Individual Stock Strategy. MAR and Coral Gables Trust Company have a fee share arrangement in which MAR is being compensated by Coral Gables Trust Company for having directed a prospective client to Coral Gables Trust Company for portfolio management services. Christian M. Ramos is a board member of one (1) charitable foundation, co-trustee of three (3) trust accounts, and co-trustee of one (1) inherited IRA that are managed by MAR. John Patten is co-trustee of one (1) trust account that is managed by MAR. John Patten is the Managing Member of Patten Fiduciary Services LLC, which provides fiduciary services such as trustee, personal representative, guardian, power of attorney, and trust protector. John Patten’s self-directed IRA owns Patvest, LLC of which he is the Managing Member, and it provides personal loans, auto loans, and real estate mortgage loans. John Patten is a member of the Professional Fiduciary Council of Florida. 9  From time to time, Maricela A. Ramos, Christian M. Ramos, and/or John Patten may offer clients advice or products from those activities, and clients should be aware that these services may involve a conflict of interest. MAR Wealth Management Services, LLC always acts in the best interest of the client, and clients are in no way required to use the services of any representative of MAR Wealth Management Services, LLC in connection with such individual’s activities outside of MAR Wealth Management Services, LLC. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections MAR may direct clients to third party money managers. This relationship will be disclosed in each contract between MAR and each third-party advisor. The fee charged by the third party will be separate and distinct from the fee charged by MAR for this service. MAR will always act in the best interests of the client, including when determining which third party manager to recommend to clients. MAR will ensure that all recommended advisors or managers are licensed or notice filed in the states in which MAR is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics MAR has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests MAR does not recommend that clients buy or sell any security in which a related person to MAR or MAR has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of MAR may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of 10  MAR to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. MAR will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of MAR may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of MAR to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, MAR will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on MAR’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a client on terms that are the most favorable to the client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and MAR may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of MAR. MAR will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. MAR uses Charles Schwab & Co., Inc. Advisor Services as custodian. 1. Research and Other Soft-Dollar Benefits While MAR does have access to research from Charles Schwab & Co., Inc. Advisor Services, MAR’s investment decisions are mainly and primarily made from research MAR pays for from Morningstar. This soft dollar benefit does not result in higher transaction fees. MAR’s clients pay the same transaction fees for stock, bond, ETF, and Mutual Fund trades as do Charles Schwab & Co., Inc’s retail clients, and Charles Schwab & Co., Inc. Advisor Services’ transaction fees are among the lowest in the industry. 11  There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. MAR benefits by not having to produce or pay for the research, products or services, and MAR will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that MAR’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals MAR receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use MAR allows clients to direct brokerage. However, MAR may recommend custodians. MAR may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients money because without the ability to direct brokerage, MAR may not be able to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts MAR does have the ability to place block trades. This is used solely for efficiency purposes. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least monthly by Maricela A. Ramos, Managing Member and Christian M. Ramos, Managing Member. Maricela A. Ramos and Christian M. Ramos review clients’ accounts with regard to clients’ respective investment policies and risk tolerance levels. All accounts at MAR are assigned to these reviewers. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Maricela A. Ramos, Managing Member and Christian M. Ramos, Managing Member. There is only one level of review and that is the total review conducted to create the financial plan. 12  B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least monthly from the custodian, a written report that details the client’s account including assets held and asset value which will come directly from the custodian. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services did provide MAR in 2013 with $3,000 toward technology related expenses in which they paid Morningstar directly. Currently, Charles Schwab & Co., Inc. Advisor Services does not offer at no charge to MAR marketing, legal and business consulting, conferences on practice management, and/or human capital consultants. Aside from the $3000 paid to Morningstar in 2013, currently Charles Schwab & Co., Inc. Advisor Services does not arrange or pay third parties for any aforementioned services that will benefit MAR. Furthermore, currently Charles Schwab & Co., Inc. Advisor Services does not waive or discount fees that would otherwise be charged for the aforementioned services. Charles Schwab & Co., Inc. Advisor Services provides MAR with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For MAR clients’ accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. 13  Charles Schwab & Co., Inc. Advisor Services also makes available to MAR other products and services that benefit MAR but may not benefit its clients’ accounts. These benefits may include products and services to assist MAR in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of MAR’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of MAR’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to MAR other services intended to help MAR manage and further develop its business enterprise. These services may include publications on practice management, information technology, regulatory compliance, and employee benefits providers. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to MAR by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to MAR. MAR is independently owned & operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals MAR may enter into a written arrangement with a third party to act as solicitor for MAR’s investment management services. All compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. Item 15: Custody MAR, with client written authority, has limited custody of client’s assets through direct fee deduction of MAR’s fees only. If the client chooses to be billed directly by Charles Schwab & Co., Inc. Advisor Services, MAR would have constructive custody over that account and must have written authorization from the client to do so. MAR may also be deemed to have custody over the funds and securities of trust accounts for which it or its related persons serve as trustee and/or accounts for which bill pay services are offered and utilized. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion For those client accounts where MAR will have investment discretion, the client has given MAR written discretionary authority over the client’s accounts with respect to securities to be bought 14  or sold and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides MAR discretionary authority via a discretionary investment management clause in the Investment Advisory Contract and/or a limited power of attorney clause in the contract between the client and the custodian. Item 17: Voting Client Securities (Proxy Voting) MAR will accept voting authority for client securities in certain cases. When MAR does accept voting authority for client securities, it will always seek to vote in the best interests of its clients. MAR does not maintain preapproved voting guidelines but relies on the investment committee to determine the appropriate course of action in voting client securities that is in the best interest of the client. Clients may direct MAR on how to vote client securities by communicating their wishes in writing or electronically to MAR. When voting client proxies, the investment committee will always hold the interests of the clients above its own interests. Clients of MAR may obtain the voting record of MAR on client securities by contacting MAR at the phone number or e-mail address listed on the cover page of this brochure. Clients may obtain a copy of MAR’s proxy voting policies and procedures upon request. Item 18: Financial Information A. Balance Sheet MAR does not require nor solicit prepayment of more than $500 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither MAR nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years MAR has not been the subject of a bankruptcy petition in the last ten years. 15  Item 19: Requirements For State Registered Advisers A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background MAR currently has two management persons/executive officers: Maricela A. Ramos and Christian M. Ramos. Both, Maricela A. Ramos’s and Christian M. Ramos’s education and business background can be found on the Supplemental ADV Part 2B form. B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) Other business activities for each relevant individual can be found on the individual’s Form ADV Part 2B brochure supplement. C. How Performance-based Fees are Calculated and Degree of Risk to Clients MAR does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. D. Material Disciplinary Disclosures for Management Persons of this Firm MAR does not have any disciplinary events for management persons that are material to a client’s or prospective client’s evaluation of this advisory business. E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) Neither MAR, nor its management persons, has any relationship or arrangement with issuers of securities. 16