Overview

Assets Under Management: $106 million
High-Net-Worth Clients: 33
Average Client Assets: $2.9 million

Frequently Asked Questions

MARKIZ WEALTH MANAGEMENT charges 2.00% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #127371), MARKIZ WEALTH MANAGEMENT is subject to fiduciary duty under federal law.

MARKIZ WEALTH MANAGEMENT serves 33 high-net-worth clients according to their SEC filing dated April 01, 2026. View client details ↓

According to their SEC Form ADV, MARKIZ WEALTH MANAGEMENT offers financial planning and portfolio management for individuals. View all service details ↓

MARKIZ WEALTH MANAGEMENT manages $106 million in client assets according to their SEC filing dated April 01, 2026.

According to their SEC Form ADV, MARKIZ WEALTH MANAGEMENT serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (MARKIZ WEALTH MANAGEMENT ADV PART 2A)

MinMaxMarginal Fee Rate
$0 and above 2.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

Number of High-Net-Worth Clients: 33
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 90.58%
Average Client Assets: $2.9 million
Total Client Accounts: 169
Discretionary Accounts: 169
Minimum Account Size: $500,000
Note on Minimum Client Size: $500,000

Regulatory Filings

CRD Number: 127371
Filing ID: 2090764
Last Filing Date: 2026-04-01 12:56:44

Form ADV Documents

Primary Brochure: MARKIZ WEALTH MANAGEMENT ADV PART 2A (2026-04-01)

View Document Text
Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Item 1: Cover Page Main Address: Oregon Office Address: 159 Harbor View Drive, Port Washington, NY 11050 4949 Meadows Road, Suite 600, Lake Oswego, OR 97035 Main Phone: (503) 805-3485 Fax Number: (516) 467-4044 Web Site Address: http://www.markizwealth.com E-mail address: info@markizwealth.com March 30, 2026 This Brochure provides information about the qualifications and business practices of Markiz Wealth Management. If you have any questions about the contents of this Brochure, please contact us using the information listed above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Markiz Wealth Management (CRD# 127371) is a registered investment advisor with the SEC. Registration of an investment advisor does not imply any certain level of skill or training. Additional information about Markiz Wealth Management is also available on the SEC’s website at www.adviserinfo.sec.gov. Firm CRD Number 127371 1 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Item 2: Summary of Material Changes Markiz Wealth Management (“MWM”) is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. This Brochure updates and replaces the brochure dated March 24th, 2025. The following material changes are reflected in this version: • Item 4: Updated to reflect our Assets Under Management (AUM) as of December 31st, 2025 You may request a copy of our current Brochure at any time, without charge, by calling us at (503) 805- 3485 or e-mailing us at info@markizwealth.com. MWM has made additional non-material updates to other sections in this Brochure, so we encourage each client to review the complete Brochure carefully and to call us with any questions you may have. Pursuant to SEC Rules, MWM will ensure that clients receive a summary of any material changes to this Brochure within 120 days of the close of our fiscal year, along with a copy of this Brochure or an offer to provide the full Brochure. Additionally, as MWM experiences material changes in the future, we will send you a summary of our “Material Changes” under separate cover. Additional information about MWM and our investment adviser representatives is available on the SEC’s website at https://adviserinfo.sec.gov/. Firm CRD Number 127371 2 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Item 3: Table of Contents Item 1: Cover Page ....................................................................................................................................................... 1 Item 2: Summary of Material Changes ......................................................................................................................... 2 Item 3: Table of Contents ............................................................................................................................................. 3 Item 4: Advisory Business ............................................................................................................................................ 4 Item 5: Fees and Compensation ................................................................................................................................... 6 Item 6: Performance-Based Fees and Side-by-Side Management ............................................................................... 8 Item 7: Types of Clients ............................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................ 8 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 ............................... 12 Item 12: Brokerage Practices ...................................................................................................................................... 13 Item 13: Review of Accounts ..................................................................................................................................... 15 Item 14: Client Referrals and Other Compensation ................................................................................................... 15 Item 15: Custody ........................................................................................................................................................ 16 Item 16: Investment Discretion .................................................................................................................................. 17 Item 17: Voting Client Securities ............................................................................................................................... 17 Item 18: Financial Information ................................................................................................................................... 17 Firm CRD Number 127371 3 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Item 4: Advisory Business The Firm’s History Portland Financial Advisors Inc, dba Markiz Wealth Management (“MWM,” or “the firm”) was formed in October 2007 by Gabriel J. Markiz, MSFP, CPA/PFS, CFP®. MWM currently operates offices in both Port Washington, NY, and Lake Oswego, OR. MWM maintains the same principle upon which it was founded: to provide clients with truly objective financial advice. MWM’s goal is to construct a world-class financial planning and investment advisory firm, dedicated to the fiduciary principle that the client’s best interest should remain paramount at all times. Randi Alberts-Markiz owns 10% and Gabriel J. Markiz owns 90% of MWM and together they make all major decisions of a strategic and administrative nature for the firm. Types of Advisory Services Offered MWM offers two programs - MWM Wealth Management Services and MWM Financial Planning Services MWM – Wealth Management Services MWM’s Wealth Management Services are available to all clients. The program combines ongoing investment advisory services and additional wealth management services to clients based upon their unique circumstances and needs. Such wealth management services may include risk management counsel, financial planning, tax planning, estate planning, cash flow planning, retirement capital needs analysis, retirement planning, college planning, business planning, and establishment of and counsel with regard to retirement plans. Wealth Management Services to be provided are outlined in the Client Agreement. Generally, MWM’s Wealth Management Services include the following: • The benefits of MWM’s ongoing research and analysis regarding the taxation of investments, review of specific investment products, and other matters affecting clients’ investments and financial planning in general. • Development and implementation of an Investment Plan. This Investment Plan includes an Investment Policy Statement, which may be amended if and when the Clients’ circumstances change. • Quarterly reports from MWM of the Clients’ investment portfolio. • Portfolio reviews and rebalancing of the portfolio, for the assets held under management, on a periodic basis. • Evaluate risks for Long-Term Care, Disability, Life, Home, Liability, and Auto insurance. Firm CRD Number 127371 4 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management • Tax return planning and preparation (through affiliation with Gabriel J. Markiz, CPA, PC). • Education planning. • Estate planning review and facilitation of implementation of Wills, Trusts, Powers of Attorney, Advance Directives for Healthcare, Charitable Trusts, Donor Advised Funds. Clients’ Investment Advisory Accounts are managed on a Discretionary basis: Discretionary When the Client elects to use MWM on a discretionary basis, the Client will sign a limited trading authorization or equivalent allowing MWM to determine the securities to be bought or sold and the amount of the securities to be bought or sold. MWM will have the authority to execute transactions in the account without seeking Client consent on each transaction. MWM – Financial Planning Services MWM’s financial planning services range from comprehensive financial planning to more focused consultations, depending on the needs of each client. MWM evaluates the client’s financial, business and investment information and makes recommendations designed with the intention of achieving the client’s overall goals and objectives. Advice and recommendations may also be given on non-securities matters. Clients always have the right to accept or reject any or all recommendations made by MWM. Should clients act on such recommendations, they always have the right to decide with whom they choose to do so. If a conflict of interest exists between the interests of MWM and the interests of the Client, the Client is under no obligation to act upon MWM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through MWM. Client-Tailored Services and Client-Imposed Restrictions The Client’s financial needs, investment goals, tolerance for risk, and investment objectives are documented in MWM’s Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. These restrictions may, however, prohibit engagement with MWM. Non-Participation in Wrap Fee Programs MWM does not participate in a Wrap Program. Firm CRD Number 127371 5 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Amount of Assets Under Management As of December 31, 2025, the following represents the amount of client assets under management by the Firm on a discretionary and non-discretionary basis: Type of Account Assets Under Management Discretionary $ 105,846,846 Non-Discretionary $ 0 Total: $105,846,846 Item 5: Fees and Compensation Wealth Management Service Fees MWM charges an annual investment advisory fee for its Wealth Management Service, which is a combination of investment management and financial planning. The fee will either be a percentage of the Client’s assets under management, or a fixed advisory fee. When structured as a percentage of assets under management, the fee is directly tied to the value of the Client’s assets. When structured as a fixed fee, total assets under management are considered as one factor in determining the amount. The fee for each client is set forth in the Client’s Agreement, and is based upon the following factors: • Total assets managed (not including residence and personal property) • Client financial complexity • Anticipated or requested frequency of client interaction The standard fee as a percentage of managed assets will not exceed the safe harbor maximum of 2.00%. Fees are paid quarterly in advance. Fees in the initial quarter of service are prorated based on the number of days remaining in the current quarter. Financial Planning Fees Fees for financial planning services will be billed at the rate of $400 per hour plus out-of-pocket expenses, which will be pre-approved by the Client. Services will be billed monthly and will be due and payable within ten (10) days from the date of invoice. A late charge of 1½ percent per month will be charged upon any unpaid balance within one month of the invoice date. Clients may terminate their Agreement for financial planning services, without penalty, at any time upon written notice. At the time of termination, any prepaid fees will be prorated based on the amount of work completed by the Firm as of the date the notice of termination is received, and any unearned fees will be returned to the Client. It is possible that if the client seeks to terminate their Agreement with MWM, and Firm CRD Number 127371 6 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management substantial work has been done to provide services to the client, the client may not receive any return of the initial payment. If clients wish to engage MWM for wealth management services, within six months of completion of the financial plan, the fees paid for the financial plan will be credited toward the first year’s wealth management fee. How Wealth Management Fees are Paid Wealth Management Fees are generally deducted directly from the Client’s Account. Financial Planning Fees are generally invoiced directly to the Client but may also be deducted from another account held with MWM. MWM, in its sole discretion, may charge a lesser fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). For all services, Clients may terminate their engagement with MWM within five (5) business days of signing an Agreement with no obligation and without penalty. After the initial five (5) business days, the Agreement may be terminated by MWM with thirty (30) days written notice to Client and by the Client at any time with written notice to MWM. For advisory accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. In the case of hourly engagements, fees will be prorated based on the work completed at the stated hourly rate. All unpaid earned fees will be due to MWM, and all unearned fees will be refunded to the Client. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Additional Fees in Connection with Wealth Management Services Custodians may charge brokerage commissions, transaction fees, and other related costs on the purchases or sales of mutual funds, equities, bonds, and exchange-traded funds. Mutual funds, money market funds, and exchange-traded funds may also charge internal management fees, which are disclosed in the fund’s prospectus. Clients may also incur an account termination fee upon transfer from one custodian to another. MWM does not directly receive any compensation from these fees. All of these fees are in addition to the management fee you pay to MWM. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Fees Wealth Management fees are paid quarterly in advance. External Compensation for the Sale of Securities MWM does not receive any external compensation from the sale of securities. Firm CRD Number 127371 7 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Item 6: Performance-Based Fees and Side-by-Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities. MWM does not use a performance-based fee structure nor “side-by-side” management because of the conflict of interest. Performance based compensation may create an incentive for MWM to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients MWM’s Clients are generally individuals and their families, including high net worth individuals and trusts. MWM may also provide investment advice to plan participants, as well as foundations, other institutions and business entities. Client relationships vary in scope and length of service. MWM requires a minimum of $500,000 to open an advisory account. However, the firm reserves the right to accept or decline a potential client for any reason at its sole discretion. Clients are not required to have a certain amount of investment experience or sophistication. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analyses In developing investment recommendations, MWM relies primarily on information provided by the client regarding financial circumstances, investment objectives, time horizon, liquidity needs, tax considerations, and risk tolerance. This information forms the basis of each client’s overall asset allocation. Asset allocation decisions are informed by historical market data, publicly available academic research, and capital market assumptions from established financial institutions. MWM reviews economic data, market conditions, and fund-specific information in evaluating portfolio construction and security selection. Security and fund selection may consider factors such as expense ratios, portfolio composition, diversification characteristics, tax efficiency, historical volatility, and consistency with the client’s overall asset allocation. MWM utilizes publicly available financial publications, fund prospectuses, regulatory filings, and analytical tools in conducting its research. The firm periodically reviews client portfolios to assess alignment with the established investment strategy and may recommend adjustments when appropriate. Investment Strategy MWM generally employs a long-term investment approach centered on strategic asset allocation and diversification across multiple asset classes, including equities and fixed income securities. Portfolios are Firm CRD Number 127371 8 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management typically implemented using diversified mutual funds and exchange-traded funds (“ETFs”), with an emphasis on cost efficiency and tax awareness where appropriate. Client portfolios may follow internally developed allocation models designed to align with varying risk tolerances and investment objectives. In certain circumstances, asset allocations may be customized to reflect specific client needs, including assets held outside accounts managed by MWM. While MWM primarily follows a strategic allocation approach, it may make periodic adjustments to portfolio weightings based on changes in client circumstances, market conditions, or valuation considerations. Any such adjustments are made within the context of the client’s long-term investment objectives. Risk of Investments and Strategies Utilized MWM utilizes diversification across global equity and fixed income asset classes as part of its portfolio construction process; however, diversification does not ensure a profit or protect against loss. Portfolios may include exposure to small- and value-oriented securities. These investments may experience periods of underperformance relative to other market segments and may exhibit higher volatility. While MWM considers risk in developing portfolio recommendations, clients remain subject to market risk, including the potential for significant declines in portfolio value. MWM cannot provide any guarantee that clients’ goals and objectives will be achieved. Investing in securities involves risk of loss that Clients should be prepared to bear. MWM’s investment approach constantly keeps the risk of loss in mind. Investors may face the following investment risks: General Investment and Trading Risks: Clients may invest in securities and other financial instruments using strategies and investment techniques that have various degrees of risk characteristics. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. Political, economic, and social changes may trigger market events. Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. When interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Firm CRD Number 127371 9 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Fixed Income Securities Risk: Fixed income securities (bonds) are subject to interest rate risk, credit risk, inflation risk, call risk, and liquidity risk. Interest rate risk is the risk that bond prices will decline because of rising interest rates. Credit risk is the risk that a bond issuer will fail to make interest or principal payments when due. Inflation risk arises because the value of the income stream from a bond will decline due to inflation. Call risk occurs when an issuer redeems a bond before maturity. Liquidity risk refers to the risk that an investor may not be able to sell a bond quickly at an appropriate price. Exchange-Traded Funds Risk: ETFs are a type of index fund bought and sold on a securities exchange. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although lack of liquidity in an ETF could result in it being more volatile and ETFs have management fees that increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices may not correlate perfectly with changes in the underlying reference units; and (ii) the risk of possible trading halts due to market conditions or other reasons that, in the view of the exchange upon which an ETF trades, would make trading in the ETF inadvisable. Mutual Fund Risk: An investment in mutual funds could lose money over short or even long periods. A mutual fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations of the overall stock market. Dimensional Fund Advisors: Certain mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are generally only available through approved registered investment advisers. MWM is one such approved investment adviser and may use or recommend DFA mutual funds in providing its advisory services. Upon the termination of MWM’s advisory services, Client’s new adviser may maintain or sell out of DFA mutual fund positions but may be restricted in the ability to purchase additional DFA mutual fund shares. Common Stocks and Equity-Related Securities: Certain ETFs or mutual funds hold common stock. Prices of common stock react to the economic condition of the company that issued the security, industry and market conditions, and other factors which may fluctuate widely. Investments related to the value of stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-related securities, including preferred stock, warrants, and options may also vary widely. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Business Risk: These risks are associated with a particular industry or company within an industry. For example, oil-drilling companies depend on finding oil and refining it, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Firm CRD Number 127371 10 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Cybersecurity Risk: MWM and its service providers may be subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting MWM and its service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the release of private information about Clients, impede trading, subject MWM to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which Clients may invest in, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damages, and loss from damage or interruption of systems. Although MWM has established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that MWM does not directly control the cybersecurity measures and policies employed by third party service providers. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment with MWM. Item 9: Disciplinary Information MWM and its management have not been involved in any criminal or civil actions, administrative or self- regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of MWM or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Registration as a Broker-Dealer or Broker-Dealer Representative Neither MWM nor its management persons are registered as a broker-dealer or broker-dealer representative. Firm CRD Number 127371 11 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither MWM nor its management persons are registered as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Relationships Material to this Advisory Business and Possible Conflicts of Interest Gabriel J. Markiz is a principal of Gabriel J. Markiz, CPA, PC, an affiliated accounting firm providing accounting, tax preparation, and tax planning to select clients. MWM’s advisory clients may also be Gabriel J. Markiz, CPA, PC’s accounting clients. Mr. Markiz offers MWM clients the opportunity to utilize the services of Gabriel J. Markiz, CPA, PC for their tax and accounting needs. There are no direct fees paid to MWM or Mr. Markiz for such referrals. Should clients of MWM choose to engage Gabriel J. Markiz, CPA, PC, Mr. Markiz will receive normal compensation for his respective role as an accountant with Gabriel J. Markiz, CPA, PC. Additionally, as Mr. Markiz is the owner of Gabriel J. Markiz, CPA, PC, he shares in profits of Gabriel J. Markiz, CPA, PC. The additional receipt of compensation creates a conflict of interest in that Mr. Markiz has a financial incentive to recommend Gabriel J. Markiz, CPA, PC to MWM clients as opposed to other accounting firms. To mitigate these conflicts, they are disclosed to clients of MWM at the time of their engagement with the Firm - through the delivery of the Firm’s Disclosure Brochure and applicable Brochure Supplements. Further, MWM Clients are made aware that they are under no obligation to utilize Gabriel J. Markiz, CPA, PC for their accounting needs, and are free to select any accountant of their choosing. Selection of Other Advisors or Managers MWM does not utilize nor select other advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The supervised persons (supervised persons include employees and/or independent contractors) of MWM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of MWM supervised and addresses conflicts that may arise. The Code defines acceptable behavior for supervised persons of MWM. The Code reflects MWM and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when supervised persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any supervised persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. Firm CRD Number 127371 12 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management MWM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other supervised person, officer or director of MWM may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. MWM’s Code is based on the guiding principle that the interests of the Client are our top priority. MWM’s officers, directors, and advisors have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of our supervised persons or MWM. Certain parts of this Code apply to “access” persons. “Access” persons are supervised persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. MWM will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Recommendations Involving Material Financial Interests Neither MWM nor its related persons recommend to Clients, or buys or sells for Client accounts, securities in which MWM or a related person has a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest MWM and its supervised persons may invest in the same securities (or related securities, e.g., warrants, options or futures) that MWM or a supervised person recommends to Clients. In order to mitigate conflicts of interest, such as frontrunning, MWM’s Chief Compliance Officer, or their designee, will review firm and/or personal holdings of its supervised persons no less than quarterly. These reviews ensure that the personal trading of supervised persons does not disadvantage Clients of MWM. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest MWM and its supervised persons may recommend securities, or buy or sell securities for Clients accounts, at or about the same time, that they also buy or sell the same securities in their own account(s). In order to mitigate conflicts of interest, such as frontrunning, MWM’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm and/or personal holdings of its supervised persons. These reviews ensure that the personal trading of supervised persons does not disadvantage Clients of MWM. Item 12: Brokerage Practices Factors Used to Select or Recommend Broker-Dealers MWM encourages clients to use Charles Schwab & Co., Inc., however Clients may utilize a broker-dealer of their choice. MWM has selected Charles Schwab & Co., Inc based on a number of factors including but Firm CRD Number 127371 13 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management not limited to their transaction fees, quality of customer service, and reporting ability. MWM relies on the broker-dealer to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by MWM. Please note that not all Investment Advisors require their Clients direct brokerage. 1. Research and Other Soft Dollar Benefits MWM does not receive soft dollar benefits. 2. Brokerage for Client Referrals MWM does not receive Client referrals from any custodian or third party in exchange for using that broker-dealer or third party. 3. Directed Brokerage MWM does not generally accept directed brokerage arrangements (when a Client requires that account transactions be effected through a specific broker-dealer). However, MWM does allow for Client directed brokerage in certain situations. Such situations may affect MWM’s ability to negotiate commissions with the resulting inability to obtain volume discounts or best execution for Client directed accounts in some transactions. Therefore, a Client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case should the Client elect to trade through the broker-dealer MWM recommends. Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker-dealer involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker-dealer and the financial strength and stability of the broker-dealer. MWM does not receive any portion of the trading fees. Aggregating Trading for Multiple Client Accounts MWM has chosen not to aggregate (combine) the trades of its clients. This is because all trade decisions are reviewed for near-term and long-term tax efficiency, which requires individual analysis of most trading decisions. This individual analysis of trades does not lend itself to computer software programs which could aggregate trades. Most trades are mutual funds where trade aggregation does not garner any client benefit. MWM’s clients do not receive the benefits of reduced transaction fees that may be available by aggregating trades. Firm CRD Number 127371 14 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management Item 13: Review of Accounts Frequency and Nature of Periodic Review and Who Makes Those Reviews Account reviews are performed at least annually by Gabriel Markiz of MWM. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Factors That Will Trigger a Non-Periodic Review of Client Accounts Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Content and Frequency of Regular Reports Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by the Client’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. MWM may also send periodic or other event-inspired reports based on market or portfolio activity. Reports will generally be provided in electronic format. In addition, in January or February of each calendar year, the client may be provided with a realized gains and loss report for any taxable accounts which are under management to aid the clients’ CPA/accountant/tax preparer in income tax preparation. While MWM hopes that our clients trust our firm and advisor, and MWM has never had an instance of theft of client funds, MWM believes it is nevertheless important for clients to verify their investment holdings and to ensure that all account transactions, including deductions to pay advisory fees remain proper, and to contact us with any questions. Item 14: Client Referrals and Other Compensation MWM does not provide or accept compensation from any person for client referrals. Referrals to other professionals may be undertaken where appropriate to meet the clients’ needs. These situations include: • Referral to Gabriel J. Markiz, CPA, PC for accounting and preparation of the clients’ tax returns. While MWM may assist Gabriel J. Markiz, CPA, PC by providing information for purposes of accounting and tax preparation, Gabriel J. Markiz, CPA, PC will provide these services directly to the client. Gabriel J. Markiz, CPA, PC then bills MWM for such services. While MWM employs a Certified Public Accountant (CPA) as a financial planner and investment advisor, this CPA does not provide tax preparation and accounting services as an employee of MWM. However, he does provide these services as an employee of Gabriel J. Markiz, CPA, PC Firm CRD Number 127371 15 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management • Referrals to attorneys for legal advice and document preparation may be undertaken for preparation of any recommended estate planning documents, the implementation of various strategies relating to asset protection planning, legal document preparation relating to transactions involving closely held businesses and/or professional firms, and other similar services. MWM is not a law firm and does not provide legal services. • Referrals to insurance agents for risk analysis, review, and purchase of insurance products may be undertaken for the implementation of various insurance strategies relating to investment, asset protection, and estate planning. MWM’s advisor representatives are not licensed insurance agents or consultants. Item 15: Custody All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by MWM. MWM is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of MWM. MWM will obtain written authorization from Client to allow for such deductions. To the extent MWM allows clients to direct third-party payments per a standard letter of authorization (“SLOA”), MWM will meet the following seven conditions to be exempt from custody and the annual audit requirement: 1. The Client provides instructions to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer will be directed. 2. The Client authorizes the investment advisor, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization, and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. The investment advisor has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. The investment advisor maintains records showing that the third party is not a related party of the investment advisor or located at the same address as the investment advisor. Firm CRD Number 127371 16 Form ADV Part 2A (Firm Brochure) Portland Financial Advisors Inc, dba Markiz Wealth Management 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. MWM is not affiliated with the custodian. The custodian does not supervise MWM, its employees or activities. Item 16: Investment Discretion Client will authorize MWM discretionary authority, via the Investment Advisory Agreement, to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize MWM discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. MWM allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to MWM in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. MWM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Clients will receive proxy voting information directly from the issuer and/or custodian of the security. Clients will not receive any such proxy voting material from MWM. When assistance on voting proxies is requested by the Client, MWM will provide recommendations to the Client. However, MWM will not have authority to vote proxies on behalf of the Client. If in the future MWM obtains authority to vote proxies, this Brochure will be appropriately amended. Clients may contact MWM at (503) 805-3485 or email info@markizwealth.com. Item 18: Financial Information Balance Sheet MWM does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in advance. Financial Condition At this time, neither MWM nor its management persons have any financial conditions that are likely to reasonably impair its ability to meet contractual commitments to Clients. Bankruptcy Petitions in Previous Years MWM has not been the subject of a bankruptcy petition in the last ten years. Firm CRD Number 127371 17