MARATHON WEALTH MANAGEMENT, INC.

Marathon Wealth Management, Inc. Form ADV Part 2A – Disclosure Brochure Effective: February 19, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Marathon Wealth Management, Inc. (“Marathon” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (631) 760-8385 or at info@marathonwealth.net. Marathon is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Marathon to assist you in determining whether to retain the Advisor. Additional information about Marathon and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or IARD# 289119 Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about Advisory Persons of Marathon. For convenience, the Advisor has combined these documents into a single disclosure document. Marathon believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Marathon encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 21, 2025: • The Advisor’s new primary office is 105 Maxess Road, Suite 124 Melville, NY 11747. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or IARD# 289119. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (631) 760-8385 or at info@marathonwealth.net. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 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 Services..................................................................................................................................... 4 A. Firm Information ..............................................................................................................................................................4 B. Advisory Services Offered ...............................................................................................................................................4 C. Client Account Management ...........................................................................................................................................6 D. Wrap Fee Programs ........................................................................................................................................................6 E. Assets Under Management .............................................................................................................................................6 Item 5 – Fees and Compensation .......................................................................................................................... 6 A. Fees for Advisory Services ..............................................................................................................................................7 B. Fee Billing ........................................................................................................................................................................7 C. Other Fees and Expenses...............................................................................................................................................8 D. Advance Payment of Fees and Termination ...................................................................................................................8 E. Compensation for Sales of Securities .............................................................................................................................9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ........................................................................................................................................ 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 9 A. Methods of Analysis ........................................................................................................................................................9 B. Risk of Loss ...................................................................................................................................................................10 Item 9 – Disciplinary Information ........................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 11 A. Code of Ethics ...............................................................................................................................................................11 B. Personal Trading with Material Interest .........................................................................................................................11 C. Personal Trading in Same Securities as Clients ...........................................................................................................12 D. Personal Trading at Same Time as Client.....................................................................................................................12 Item 12 – Brokerage Practices ............................................................................................................................. 12 A. Recommendation of Custodian[s] .................................................................................................................................12 B. Aggregating and Allocating Trades ...............................................................................................................................13 Item 13 – Review of Accounts.............................................................................................................................. 13 A. Frequency of Reviews ...................................................................................................................................................13 B. Causes for Reviews.......................................................................................................................................................13 C. Review Reports .............................................................................................................................................................13 Item 14 – Client Referrals and Other Compensation ......................................................................................... 13 A. Compensation Received by Marathon ..........................................................................................................................13 B. Compensation for Client Referrals ................................................................................................................................14 Item 15 – Custody.................................................................................................................................................. 14 Item 16 – Investment Discretion .......................................................................................................................... 14 Item 17 – Voting Client Securities ....................................................................................................................... 14 Item 18 – Financial Information ........................................................................................................................... 15 Form ADV Part 2B – Brochure Supplement ....................................................................................................... 16 Privacy Policy ........................................................................................................................................................ 20 Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 3  Item 4 – Advisory Services A. Firm Information Marathon Wealth Management, Inc. (“Marathon” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Corporation under the laws of the State of New York. Marathon was founded in June 2015 and became a registered investment advisor in September 2017. Marathon is owned and operated by Aaron Lieberman (Managing Director and President). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Marathon. B. Advisory Services Offered Marathon offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Marathon’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Marathon may provide Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with the discretionary management of a Client’s investment portfolio. These services are described below. Investment Management Services: Marathon provides customized investment advisory solutions for its Clients, both as part of its wealth management services, but also as a stand-alone service. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Marathon works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Marathon will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Marathon’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Marathon will construct, implement and monitor the Client’s portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Marathon evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Marathon may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Marathon may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Marathon may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 4  Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will Marathon accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Comprehensive Financial Life Planning and Consulting Services Marathon provides comprehensive financial life planning and consulting services to its Clients, both as part of its wealth management services, but also as a stand-alone service, pursuant to either a subscription or on a one- time basis. Clients who desire comprehensive financial planning services provided on an annual basis will enter into a Comprehensive Financial Planning Agreement. For one-time services, Clients will be required to enter into a separate financial life planning services agreement. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. Planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Marathon may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Marathon provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company/sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Oversight Services (ERISA 3(21)) • Vendor Analysis • Employee Enrollment and Education Tracking • • Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 5  • Performance Reporting • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance These services are provided by Marathon serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Marathon’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Use of Independent Managers Marathon may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Manager[s]”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and 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. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor 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. Prior to entering into an agreement with the Independent Manager[s] the Client will be provided with the Independent Manager's Form ADV 2A – Disclosure Brochure (or a brochure that makes the appropriate disclosures). C. Client Account Management Prior to engaging Marathon to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Marathon, in connection with the Client, will develop an investment strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Marathon 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 – Marathon will develop an investment portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Marathon will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Marathon does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Marathon. E. Assets Under Management As of December 31, 2025 Marathon manages approximately $150,540,000 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one of more written agreements with the Advisor. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 6  A. Fees for Advisory Services Wealth Management Services Wealth management fees include both investment management and financial planning services. Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are fixed and based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and/or the overall relationship with the Advisor. The Advisor will also take into consideration the following, which is not intended to be an exhaustive list: amount of financial planning required, number and type of accounts, net worth, life transitions, number of household members, business interests, real estate ownership, and trust arrangements. Clients that established Wealth Management Agreements prior to September 4, 2019 will be grandfathered under their previously executed Client Agreement. The fixed fee will generally range from $9,000 annually or $2,250 quarterly to $50,000 annually or $12,500 quarterly. All securities held in accounts managed by Marathon will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor also offers wealth management services on the following tiered schedule: Annual Rate (%) Assets Under Management ($) First $1,000,000 Next $3,000,000 (up to $4,000,000) Over $4,000,000 1.25% 0.75% 0.50% Comprehensive Financial Life Planning and Consulting Services Marathon offers stand-alone comprehensive financial life planning and consulting services on either a fixed fee subscription basis or a one-time project basis. Subscription engagements start at $500 monthly and require an annual commitment. One-time project engagements are at an hourly rate of up to $350 per hour. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or overall costs will be provided to the Client prior to engaging for these services. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.50%, billed quarterly, pursuant to the terms of the agreement. Retirement plan fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. Use of Independent Managers For Clients referred by the Advisor to an Independent Manager, the Client’s fee will be deducted from the Client’s account[s] with the respective Independent Manager and a portion of the fee may be provided to Marathon based on Marathon’s agreement with the Client or billed separately by Marathon. Marathon is responsible for negotiating the fees with the Independent Manager on behalf of the Client. Marathon may charge a fee of up to 2.25% for relationships utilizing a third-party money manager. B. Fee Billing Wealth Management Services Clients have the choice to select how wealth management fees will be paid to the Advisor. These options include the authorized deduction of fees from Client account[s] held at their selected Custodian; by check; and utilizing a third-party vendor (AdvicePay) to process their payment. When fees are deducted through the Client’s selected Custodian, the Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of each quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Marathon directly Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 7  from their account[s] held by the Custodian as part of the management agreement and separate account forms required by the Custodian. Comprehensive Financial Life Planning and Consulting Services For subscription engagements, an initial deposit of $500 is due at the start of the engagement and monthly installments of $500 are due at the end of each month thereafter until completion of the engagement deliverables. For one-time financial life planning and consulting engagements, Marathon is paid in advance of the engagement deliverables. At the Advisors discretion it may allow Clients to pay for one-time engagements by depositing 50% of the fee in advance with the remaining 50% due upon completion of the engagement. Retirement Plan Advisory Services Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Use of Independent Managers For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or deducted from the Client’s account[s] with the respective manager and a portion of the investment advisory fee may be provided to Marathon. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Marathon, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Marathon are separate and distinct from these custody and execution fees. In addition, fees paid to Marathon for wealth management and investment management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Marathon, but would not receive the services provided by Marathon which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Marathon to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Marathon is compensated for its wealth management services at the beginning of the quarter prior to services being rendered. Either party may terminate the agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the agreement within five (5) business days of signing the agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement is non-transferable without the Client’s prior consent. Comprehensive Financial Life Planning and Consulting Services For subscription engagements, Marathon is partially compensated for its services upon entering the initial Client engagement and monthly thereafter until completion of the financial planning engagement. For one time financial life planning and consulting engagements, Marathon is paid in advance of the engagement deliverables. Either Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 8  party may terminate the financial life planning agreement[s], at any time, by providing advance written notice to the other party. The Client may also terminate the financial life planning agreement[s] within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Either party may request to terminate their services with Marathon in whole or in part, by providing advance written notice to the other party. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and that Independent Manager. Marathon will assist the Client with the termination and transition as appropriate. E. Compensation for Sales of Securities Marathon does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Marathon does not charge performance-based fees for its investment advisory services. The fees charged by Marathon are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Marathon does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Marathon offers wealth management and investment advisory services to individuals, high net worth individuals, trusts, estates, businesses and retirement plans. The amount of each type of Client is available on Marathon’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Marathon generally does not impose a minimum size for establishing a relationship. However there is a minimum fee of $2,250 per quarter. Fees may be negotiable, and the Advisor reserves the right to decline situations in which we consider not complicated enough to warrant our minimum fee. Alternately, we may agree to negotiate a lower fee for simpler situations. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Marathon primarily employs fundamental, technical, cyclical and charting analysis methods in developing investment strategies for its Clients. Research and analysis from Marathon are 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 Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 9  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 patterns 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 Marathon 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 Marathon is recommending. The risks with cyclical analysis are similar to those of technical analysis. Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally pricing trends that may indicate movement in the markets. 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 technical and charting analysis may lose value and may have negative investment performance. The Advisor monitors these market indicators to determine if adjustments to strategic allocations are appropriate. As noted above, Marathon generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Marathon 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, Marathon 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. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Marathon will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help 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 these methods of 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. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 10  Following are some of the risks associated with the Advisor’s investment approach: ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Marathon or any of its Supervised Persons. Marathon and its Advisory Persons value the trust you place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or IARD# 289119. Item 10 – Other Financial Industry Activities and Affiliations Optimal Divorce Outcomes, LLC Mr. Lieberman is also the Principal of Optimal Divorce Outcomes, LLC, a consultancy focused on assisting married couples with the financial aspects of divorce. This service is not offered to Clients of Marathon. Mr. Lieberman spends 15% of his time in this position during trading hours. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. In such arrangements, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Marathon has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Marathon (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to Marathon Clients. Marathon and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Marathon’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of Marathon’s Code, please contact the Advisor at (631) 760-8385 or at info@marathonwealth.net. B. Personal Trading with Material Interest Marathon allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Marathon does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Marathon does not have a material interest in any securities traded in Client accounts. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 11  C. Personal Trading in Same Securities as Clients Marathon allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons has a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Marathon requiring reporting of personal securities trades by its employees for review by the Chief Compliance Officer (“CCO”). We have also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Marathon allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Marathon, or any Supervised Person of Marathon, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Marathon does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Marathon to direct trades to the Custodian as agreed upon in the investment management agreement. Further, Marathon does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Marathon does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Marathon. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Marathon may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation and/or the location of the Custodian's offices. The Advisor will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits. Please see Item 14 – Client Referrals and Other Compensation below. The following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with the broker-dealer/custodian in exchange for research and other services. Marathon does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – Marathon does not receive any compensation from any third party in connection with the recommendation for establishing an account. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 12  3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis”, where Marathon will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Marathon will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Marathon may aggregate orders in a block trade or trades when securities are purchased or sold through the same Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Aaron Lieberman, Managing Director, President and Chief Compliance Officer of Marathon. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Marathon if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Marathon Marathon is a fee-based advisory firm that is compensated solely by its Clients and not from any investment product. Marathon does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Marathon may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Marathon may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like The Advisor. As a registered investment advisor participating on the Schwab Advisor Services platform, The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 13  at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits can influence the Advisor’s recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Marathon that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Marathon believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion Marathon generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Marathon. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management or investment management agreement containing all applicable limitations to such authority. All discretionary trades made by Marathon will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Marathon does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 14  Item 18 – Financial Information Neither Marathon, nor its Supervised Persons have any adverse financial situations that would reasonably impair the ability of Marathon to meet all obligations to its Clients. Neither Marathon, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Marathon is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 15  Form ADV Part 2B – Brochure Supplement for Aaron D. Lieberman, CFP®, CDFATM Managing Director, President and Chief Compliance Officer Effective: February 19, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Aaron D. Lieberman (CRD# 3258650) in addition to the information contained in the Marathon Wealth Management, Inc. (“Marathon” or the “Advisor”, IARD# 289119) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Marathon Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (631) 760-8385 or at info@marathonwealth.net. Additional information about Mr. Lieberman is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3258650. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 16  Item 2 – Educational Background and Business Experience Aaron D. Lieberman, CFP® born in 1964, is dedicated to advising Clients of Marathon as the Managing Director, President and Chief Compliance Officer. Mr. Lieberman earned a Bachelor of Arts in Psychology from Hobart and William Smith Colleges in 1986. Mr. Lieberman received his CFP® certification in 2010. Additional information regarding Mr. Lieberman’s employment history is included below. Employment History: Managing Director / President, Marathon Wealth Management, Inc. Principal, Optimal Divorce Outcomes, LLC Managing Principal, Wells Fargo Advisors Financial Network Senior Vice President, Wells Fargo Advisors LLC 10/2017 to Present 02/2021 to Present 08/2015 to 10/2017 01/1999 to 08/2015 Certified Financial Planner “(CFP®”) The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. About the CDFA™ Certification The Certified Divorce Financial Analyst™, (CDFA™) is a professional certification granted in the United States Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 17  and Canada by the Institute for Divorce Financial Analysts™ (IDFA™). To attain the right to use the CDFA™(Certified Divorce Financial Analyst™) certification, an individual must satisfactorily fulfill the following requirements: • Education – Professionals must develop their theoretical understanding and knowledge of the financial aspects of divorce by completing a comprehensive course of study approved by the IDFA™; • Examination – Practitioners must pass a four-part (in the USA) or three-part (in Canada) Certification Examination that tests their understanding and knowledge of the financial aspects of divorce. In addition, the practitioner must demonstrate the practical application of this knowledge in the divorce process; • Experience – Individuals must have a minimum of three years’ experience in a financial or legal capacity prior to earning the right to use the CDFA™ certification mark; and • Ethics – Practitioners agree to abide by a strict code of professional conduct known as the “Code of Ethics and Professional Responsibility,” which sets forth their ethical responsibilities to the public, clients, employers and other professionals. The IDFA™ may perform a background check during this process, and each candidate for CDFA™ certification must disclose any investigations or legal proceedings relating to his or her professional or business conduct. Individuals who become certified must complete the following ongoing education requirements in order to maintain the right to continue to use the CDFA™ designation: • Continuing Education – Complete a minimum of fifteen (15) hours of continuing education every two years, that are specifically related to the field of divorce, and • Ethics – Practitioners must voluntarily disclose any public, civil, criminal, or disciplinary actions that may have been taken against them during the past two years as part of the renewal process. If a complaint has been brought against a CDFA™ by another professional or member of the general public, the CDFA™ must be examined and cleared by IDFA’s Ethics Committee to maintain their designation. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Lieberman. Mr. Lieberman has never been involved in any regulatory, civil or criminal action. There have been no Client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Lieberman. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Lieberman. However, we do encourage you to independently view the background of Mr. Lieberman on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3258650. Item 4 – Other Business Activities Optimal Divorce Outcomes, LLC Mr. Lieberman is also the Principal of Optimal Divorce Outcomes, LLC, a consultancy focused on assisting married couples with the financial aspects of divorce. This service is not offered to Clients of Marathon. Mr. Lieberman spends 15% of his time in this position during trading hours. Item 5 – Additional Compensation Mr. Lieberman has an additional business activity detailed in Item 4 above. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 18  Item 6 – Supervision Mr. Lieberman serves as the Managing Director, President and Chief Compliance Officer of Marathon. Mr. Lieberman can be reached at (631) 760-8385. Marathon has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Marathon. Further, Marathon is subject to regulatory oversight by various agencies. These agencies require registration by Marathon and its Supervised Persons. As a registered entity, Marathon is subject to examinations by regulators, which may be announced or unannounced. Marathon is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 19  Privacy Policy Effective: February 19, 2026 Our Commitment to You Marathon Wealth Management, Inc. (“Marathon” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Marathon (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Marathon does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 20  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Marketing Purposes Marathon does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Marathon or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Marathon does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (631) 760-8385 or at info@marathonwealth.net. Marathon Wealth Management, Inc. 105 Maxess Road, Suite 124, Melville, NY 11747 Phone: (631) 760-8385 * Fax: (631) 760-8391 https://marathonwealth.net/ Page 21