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ITEM 1 – COVER PAGE
Mattson Financial Services, LLC
3226 28th Street SE
Kentwood, MI 49512
February 11th, 2026
Form ADV Part 2A Brochure
This brochure provides information about the qualifications and business practices of Mattson Financial Services,
LLC (“MFS”). If you have any questions about the contents of this brochure, please contact us at (800) 536-8907.
The information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Mattson Financial Services, LLC is a Registered Investment
Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority
does not imply a certain level of skill or training. Additional information about Mattson Financial Services, LLC is
available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying
number, known as an IARD number. The IARD number for Mattson Financial Services, LLC is CRD# 153067.
ITEM 2 – MATERIAL CHANGES
Summary of Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
This update is in accordance with the required annual update for Investment Advisors.
Since the last filing of this brochure on February 7, 2024, the following has been updated:
Updates made throughout the Brochure (Items 4, 5, and 13) describing the firm’s newly
offered retirement planning services
Item 10 has been updated describing the tax preparation services provided through the
Firm’s affiliated tax firm
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please contact
us by telephone at 800-536-8907 or by email at lsteward@mattsoncompanies.com.
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FEBRUARY 2026 | PAGE 1
ITEM 3 - TABLE OF CONTENTS
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ITEM 1 – COVER PAGE
ITEM 2 – MATERIAL CHANGES
ITEM 3 - TABLE OF CONTENTS
ITEM 4 – ADVISORY BUSINESS
ITEM 5 - FEES AND COMPENSATION
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
ITEM 7 - TYPES OF CLIENTS
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
ITEM 9 - DISCIPLINARY INFORMATION
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
ITEM 12 - BROKERAGE PRACTICES
ITEM 13 - REVIEW OF ACCOUNTS
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
ITEM 15 – CUSTODY
ITEM 16 – INVESTMENT DISCRETION
ITEM 17 – VOTING CLIENT SECURITIES
ITEM 18 – FINANCIAL INFORMATION
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FEBRUARY 2026 | PAGE 2
ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by Mattson Financial Services, LLC (“MFS” or “Firm”) about the
investment advisory services we provide. It discloses information about the services that we provide and the way
those services are made available to you, the client.
Mattson Financial Services, LLC became a SEC registered investment advisory firm in January 2021. The Firm is
owned by Gary Mattson, Laurel Steward, Taylor Steward, and Gerald Green. Laurel Steward is the Chief
Compliance Officer of the Firm.
Mattson Financial Services is a fee based financial planning and investment management firm. The Firm and
certain of its supervised persons are affiliated with other professionals and entities that may provide additional
financial services, such as tax preparation. Refer to Item 10 for Other Industry Affiliations.
We are committed to helping clients build, manage, and preserve their wealth. Our Firm provides services that
help clients to achieve their stated financial goals. We will offer initial complimentary meetings upon our
discretion; however, investment advisory services are initiated only after you and MFS execute an Investment
Management Agreement (“Agreement”).
Clients are free to select any independent CPA, attorney, or insurance professional of their choice, and the quality
or scope of the Firm’s advisory services is not contingent upon a client’s decision to use any affiliate.
Investment Management and Supervision Services
We manage advisory accounts on a discretionary basis. For discretionary accounts, once we have determined a
profile and investment plan with a client, we will execute the day-to-day transactions without seeking prior client
consent but within the expected investment guidelines. Account supervision is guided by the client’s written
profile and investment plan. We will accept accounts with certain trading restrictions if circumstances warrant.
We primarily allocate client assets among various equities, Exchanged Traded Funds (“ETFs”), fixed income, and
cash and cash equivalents.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition
and background. Based on client needs, we develop a client’s personal profile and investment plan. We then create
and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us
immediately if circumstances have changed with respect to their goals. Once we have determined the types of
investments to be included in a client’s portfolio and have allocated the assets, we provide ongoing investment
review and management services.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet client
financial objectives. We trade these portfolios based on the combination of our market views and client objectives,
using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure
that your portfolio is managed in a manner consistent with those needs and objectives. Clients have the ability to
leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts
of securities.
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Clients may engage us to advise on certain investment products that are not maintained at our Firm’s
recommended custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored
retirement plans. Where appropriate, we provide advice about any type of held away account that is part of a client
portfolio.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital
losses in your account.
strategists
Use of Model Managers and Platform Providers
The determination to use a particular model or models is based on each client’s individual investment goals,
objectives and mandates. Our Firm has entered into an agreement with a platform provider that offers asset
management services that include:
• model money managers
• portfolio managers
•
• marketing services
• billing/administrative services
retirement planning services
•
As part of the platform provider program, Clients provide our Firm and the platform provider discretion to select
third party, non-affiliated investment managers (“Model Managers”) to design and manage model portfolios.
The Firm has access to the platform provider’s reporting systems, client relationship management systems and
workflow systems to assist clients to establish an advisory account. Due to this arrangement, the platform
provider will have access to client information, but the platform provider will not serve as an investment advisor
to our clients. The Firm and the platform providers are non-affiliated companies. The platform providers charge
our Firm an annual fee for each account administered by them. The annual fee is paid from the portion of the
management fee retained by us. Clients receive continuous investment advice based on investment objective, risk
profile and time-horizon. While investment strategies and recommendations are tailored to the individual needs
of each client, they consist of an asset allocation consistent as outlined in Item 8 of this Brochure.
We will not enter into an investment adviser relationship with a prospective client whose investment objectives
are considered incompatible with our investment philosophy or strategies or where the prospective client seeks
to impose unduly restrictive investment guidelines. However, Clients have the ability to impose reasonable
restrictions on the management of their accounts, including the ability to instruct the firm not to purchase certain
securities.
We do have limited authority to direct the Custodians to deduct our investment advisory fees from accounts, but
only with the appropriate written authorization from clients.
Financial Planning Services
We include financial planning services as part of our investment management engagement. However, if requested,
we offer standalone financial planning services. Through the financial planning process, our team strives to engage
MATTSON FINANCIAL SERVICES, LLC
FEBRUARY 2026 | PAGE 4
our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near
term as well as for future generations. With the unique goals and circumstances of each family in mind, our team
will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate,
income tax (our Firm is not a tax services Firm and you should always consult a tax professional), charitable, cash
flow, wealth transfer, and family legacy objectives. Our team partners with our client’s other advisors (CPAs,
Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the
client’s stated goals. Such services include various reports on specific goals and objectives or general investment
and/or planning recommendations, guidance to outside assets, and periodic updates.
Our specific services in preparing your plan may include:
PERSONAL: We can review family records, budgeting, personal liability, estate information and
financial goals.
TAX: The Firm is not a tax services Firm, however the Firm is affiliated with Mattson Tax Solutions,
which provides tax preparation services.). Refer to Item 10 for Other Industry Affiliations.
INVESTMENTS: We can analyze investment alternatives and their effect on the client's portfolio.
INSURANCE: We can review existing policies to ensure proper coverage for life, health, disability,
long-term care, and liability.
RETIREMENT: We can analyze current strategies and investment plans to help the client achieve his
or her retirement goals.
DEATH & DISABILITY: We can review the client's cash needs at death, income needs of surviving
dependents, estate planning and disability income.
ESTATE PLANNING: We help update accounts, review beneficiaries for retirement accounts and life
insurance, provide a second look at your current estate planning documents, and prompt you to
update your plan when the legal environment changes or you have major life events such as a
marriage, death, or births.
The scope of work and fee for an Advisory Service Agreement is provided to the Client in writing prior to the start
of the relationship.. Our financial planning and consulting services do not involve implementing any transaction
on your behalf or the active and ongoing monitoring or management of your investments or accounts. Clients
have the sole responsibility for determining whether to implement our financial planning and consulting
recommendations. A written financial plan is generally presented to the client during their second meeting with
the advisor and prior to the execution of a formal agreement,
, provided that all information needed to prepare the written financial plan has been accurately and promptly
provided by the client.
We will not require prepayment of more than $1,200 in fees per client, six (6) or more months in advance of
providing any services. In no case are our fees based on, or related to, the performance of your funds or
investments.
MATTSON FINANCIAL SERVICES, LLC
FEBRUARY 2026 | PAGE 5
Wrap Fee Program
MFS does not participate in wrap fee programs.
Consulting Services
We also provide clients investment advice on a more-limited basis on one or more isolated areas of concern such
as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide advice on
non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice or any
other business advisory / consulting services for equity or debt investments in privately held businesses. In these
cases, clients will be required to select their own investment managers, custodian, and/or insurance companies for
the implementation of consulting recommendations. If client needs include brokerage and/or other financial
services, we will recommend the use of one of several investment managers, brokers, banks, custodians, insurance
companies, or other financial professionals ("Firms"). Consulting clients must independently evaluate these Firms
before opening an account or transacting business and have the right to effect business through any firm they
choose. Clients have the right to choose whether or not to follow the consulting advice provided. Consulting
services will continue from year to year unless cancelled in writing by either party. Client may terminate the
Agreement within five (5) days without obligation.
Seminars and Workshops
MFS holds seminars and workshops to educate the public on different types of investments and the different
services they offer. The seminars are educational in nature and no specific investment or tax advice is given.
Retirement Plan Services
Our Firm offers Retirement Plan Consulting Services to employer-sponsored retirement plans and their
participants.
Retirement Plan Consulting Services are designed to allow our IARs to assist the Plan Sponsor in meeting his/her
fiduciary duties to administer the Plan in the best interests of Plan participants and their beneficiaries. Retirement
Plan Consulting Services are performed so that they would not be considered “investment advice” under ERISA.
Our consulting services to employer-sponsored retirement plans may include assisting the plan sponsor in
reviewing plan objectives and design options; reviewing plan committee structures, policies, and procedures;
recommending participant education and communication approaches intended to help comply with ERISA 404(c);
and helping develop and maintain fiduciary audit files and document-retention practices. We may also assist
fiduciaries with selecting, monitoring, benchmarking, and, when appropriate, replacing service providers, as well
as coordinating recordkeeper or provider changes. Our investment-related support can include periodic review of
the investment policy in light of plan objectives, helping the plan committee monitor investment performance, and
educating committee members regarding designated investment alternatives (DIAs) and qualified default
MATTSON FINANCIAL SERVICES, LLC
FEBRUARY 2026 | PAGE 6
investment alternatives (QDIAs). In addition, we may facilitate group enrollment meetings, provide investment-
related and financial wellness education, and assist participants with basic retirement planning and gap analysis.
Plan fiduciaries retain ultimate responsibility for decisions regarding the plan, its investments, and its service
providers
Potential Additional Retirement Services Provided Outside of the Agreement
We and our IARs, in the course of providing Retirement Plan Services or otherwise, may establish a client
relationship with one or more plan participants or beneficiaries. Such client relationships develop in various ways,
including, without limitation:
• as a result of a decision by the plan participant or beneficiary to purchase services from us not involving
the use of plan assets;
• as part of an individual or family financial plan for which any specific recommendations concerning the
allocation of assets or investment recommendations relating to assets held outside of a plan; or
through a rollover of an Individual Retirement Account ("IRA Rollover").
•
When a participant requests assistance with an IRA Rollover from his/her plan to an account advised or managed
by us, we will have a conflict of interest if our fees are reasonably expected to be higher than those we would
otherwise receive in connection with the Retirement Plan Services. For participants invested in plans which we
do not advise, we also have a conflict of interest given that we may not earn any compensation if they remain
invested in their current plan. We will disclose relevant information about the applicable fees charged by us prior
to opening an IRA account. Any decision to affect the rollover or about what to do with the rollover assets remain
that of the plan participant or beneficiary alone.
Disclosure Regarding Rollover Recommendations
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you
regarding your retirement plan account or individual retirement account, we are also fiduciaries within the
meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests.
A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may
engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll
over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an
MATTSON FINANCIAL SERVICES, LLC
FEBRUARY 2026 | PAGE 7
Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s
age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for
which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an
asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no
compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets
into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest,
there are various factors that our Firm will consider before recommending a rollover, including but not limited to:
(i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and
expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s
investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments,
(v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our
Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has
regarding the oversight.
Assets
MFS has the following assets under management:
Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
$514,734,350
$246,518
December 31, 2025
ITEM 5 - FEES AND COMPENSATION
CO-ADVISOR FEES
MFS has entered into a Referral Agreement with Gradient Investments, LLC (“GI”). GI is a Registered Investment
Advisor registered with the Securities and Exchange Commission that provides investment portfolio advice and
supervisory services. Additionally, MFS participates in a loyalty program provided through Gradient Investments.
The program does not change the cost to the client and is a sharing arrangement paid from the portion of the fee
paid to GI.
GI offers an actively managed program of mutual fund and stock portfolios. The fee will be disclosed to the Client
in the Investment Advisory Agreement and are negotiable. The Clients fee for these services will be based on a
percentage of assets under management as follows:
STRATEGIC, TACTICAL, ALLOCATION & DEFINED OUTCOME PORTFOLIOS
All Assets
Annual Fee
1.50%
GI
0.40%
MFS
1.10%
Traditionally, GI’s Tactical Portfolio was billed with a max annual fee of 2.00%. Since GI is the sub-advisor to the
Tactical Portfolio and will receive an annual fee of 0.20% from the ETF, GI has reduced its annual fee of the Tactical
Portfolio so as not to double dip.
For example, a client investing $100,000 in the GI Tactical portfolio prior to November 2022 would pay an annual
fee to GI of $2,000 or $100,000 x 2.00% = $2,000. After November 2022 the same client would pay GI an annual
MATTSON FINANCIAL SERVICES, LLC
FEBRUARY 2026 | PAGE 8
fee of $1,500 or $100,000 x 1.50% = $1,500 and pay the internal fees of $200 or $100,000 x 0.20% = $200. For a total
of $1,500 + $200 = $1,700.
STRATEGIC, TACTICAL, ALLOCATION & DEFINED OUTCOME PORTFOLIOS
All Assets
Annual Fee
1.50%
GI
0.40%
MFS
1.10%
CLIENT DIRECTED ACCOUNTS
Annual Fee
GI
MFS
All Assets
$300
$300
$0
For Client Directed Accounts (CDA), GI will assist in the opening, closing and transferring of accounts. GI will not
have discretion at any time on these accounts. Client is solely responsible for the assets held within the accounts
and their values which could increase or decrease (potential loss of principal). GI will not execute trades in CDA
accounts. GI exceptions will be made for withdrawals to client or assets transferred into a GI managed portfolio.
GI will also provide performance reporting on these accounts and can furnish 3rd party analysis reports per the
client’s request. Similar services may be available through other sources for a lower fee.
These are flat fee schedules, the entire portfolio is charged the same asset management fee.
Example:
Portfolio
Calculation
Quarterly Fee
Strategic Portfolio:
($750,000*1.50%) * (91/365)
$2,804.79
Tactical Portfolio:
($750,000*1.50%) * (91/365)
$2,804.79
Allocation & Defined Outcome Portfolio:
($750,000*1.50%) * (91/365)
$2,804.79
Preservation Portfolio:
($750,000*1.0%) * (91/365)
$1,869.86
Fee Calculation: (Quarter End Value x Annual Fee %) x (Days in Quarter/Days in Year) + $15 Quarterly Service
Fee*
* The $15 Quarterly Service Fee is the technology fee charged per account or investment strategy for performance
and other reporting. This fee is disclosed in our ADV Part 2A (Item 5: Fees and Compensation) and in our
Investment Proposal and Contract (Schedule D: Schedule of Fees).
The above fees are negotiable. Fees are assessed quarterly in arrears based on the amount of the assets managed
as of the end of the previous quarter. All management fees are withdrawn from the Client’s account unless
otherwise noted. GI does not require a prepayment of fees. GI will receive written authorization from the Client
to deduct advisory fees from their account held by a qualified custodian. GI will pay MFS their share of the fees.
MFS does not have access to deduct Client fees. Clients may terminate their account within five (5) business days
of signing the investment advisory agreement without penalty or obligation. For terminations after the initial five
business days, GI will be entitled to a pro-rata fee for the days service was provided in the final quarter. GI will pay
MFS their portion of the final fee.
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Financial Planning and Consulting Fees
For clients only engaging our Firm for financial planning services, financial planning is offered under a separate
agreement and separate fee. Fees may vary based on the extent and complexity of your individual or family
circumstances. Our fee will be agreed in advance of services being performed and negotiated with you. Financial
planning and consulting fees are set hourly and start at $300 per hour. The specific fee for your financial plan will
be discussed with you and specified in your planning agreement with our Firm. 100% of the fee is due upon
engagement.
Typically, we will complete a plan within a month and will present it to you within 90 days of the contract date, if
you have provided us all information needed to prepare the financial plan. Fees are billed and payable at the time
the financial plan is delivered to you. Stand-alone financial plannings are paid via check.
We will not require prepayment of more than $500 in fees per client, six (6) or more months in advance of providing
any services. In no case are our financial planning fees based on, or related to, the performance of your funds or
investments.
Client may cancel within five (5) business days of signing Agreement for a full refund without obligation or penalty.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid
earned fees will be due to MFS. MFS reserves the right to waive the fee should the Client implement the plan
through MFS.
Employee Retirement Income Security Act Retirement Plan Advisory Services
Fees for the Retirement Plan Services (“Fees”) are calculated and deducted from Plan assets and paid to MFS by
the platform provider (“Third Party Payor”) in the method and frequency as set out in the Third Party Payor’s
authorization form signed by the Plan Sponsor.
Assets Held Away
MFS offers discretionary direct asset management services to advisory Clients. MFS charges a maximum annual
fee of .50% of the assets under management.
The annual fee is not negotiable. The Advisory Fee for the initial period will be paid on a pro rata basis based on
the number of days left in the billing period for which services under this Agreement were provided, in arrears,
based on the billing period ending value of the Client’s managed assets, in accordance with the fee schedule listed
in the Agreement. For all future periods, the Advisory Fee will be assessed and payable each billing period, in
advance, based on the balance of Client’s managed assets as of the ending balance of the prior period-end, in
accordance with the fee schedule listed in the Agreement. Client will pay MFS directly via check or Electronic
Payment via a third-party payment processor in which the client will securely input payment information and pay
the advisory fee through a secure portal. MFS will not have continuous access to the Client’s banking information.
No fee adjustment will be made for Account deposits and withdrawals during a billing period.
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In addition to the fees paid to MFS, investments used in managing the Account may subject Client to additional
fees. For example, mutual funds, index funds, exchange traded funds and private funds typically charge ongoing
management fees and have other expenses for the operation of those funds. These fees should not be confused
with “loads” or commissions. MFS does not receive any additional compensation, either directly or indirectly, from
these investments.
Clients may terminate their account within five (5) business days of signing the investment advisory agreement
with no obligation and for a full refund. For terminations after the initial five (5) business days, Client will be
entitled to a pro-rata refund for the days service was provided in the final quarter.
Other Additional Fees
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from
other registered (or unregistered) investment advisers for similar or lower fees. In addition to the advisory fees
paid to our Firm, clients also incur certain charges imposed by other third parties, such as broker-dealers,
custodians, trust companies, banks, and other financial institutions (collectively “Financial Institutions”). These
additional charges include custodial fees, charges imposed by a mutual fund or ETF in a client’s account, as
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges,
odd-lot differentials, regulatory fees assessed by the SEC and/or FINRA, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual Fund Fees: When purchasing mutual funds, our policy is to select institutional share classes whenever
possible. The institutional share class generally has the lowest expense ratio relative to other classes. Mutual fund
expense ratios are in addition to our fee, and we do not receive any portion of these charges. If an institutional
share class is not available, or is not the optimal solution given trading frequency, the advisor will purchase the
least expensive share class available. As share classes with lower expense ratios become available, we may convert
the existing mutual fund position to the lower cost share class.
please
visit
their
websites:
www.sec.gov/fast-answers/answerssec31htm.html
Regulatory Fees: To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to
applicable sales transactions. The Securities and Exchange Commission (SEC) regulatory fee is assessed on client
accounts for sell transactions, and a FINRA fee is assessed on client accounts for sell transactions, for certain
covered securities. This fee is not charged by our Firm but is accessed and collected by the custodian. The
Custodian that our Firm uses, is a FINRA member firm. These fees recover the costs incurred by the SEC and
FINRA, for supervising and regulating the securities markets and securities professionals. The fee rates vary
depending on the type of transaction and the size of that transaction. For more information on the SEC and FINRA
fees,
or
www.finra.org/industry/trading-activity-fee
MFS, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory 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 more details on the brokerage practices, see Item 12 of this brochure.
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ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Our Firm does not engage in performance-based fees. No supervised person is compensated by performance-
based fees. Performance-based fees may create an incentive for the advisor to recommend an investment that
may carry a higher degree of risk.
ITEM 7 - TYPES OF CLIENTS
Our Firm works with the following types of clients: individuals, trusts, estates and corporations or business entities.
MFS does not require a minimum to open an account. For accounts using a platform provider, there is a client
account minimum of $10,000.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
We take an active approach in managing our client’s assets. Each account is rebalanced on either a quarterly,
semi-annual, or annual basis. The frequency of rebalancing is based on the account’s time horizon, investment
objective current economic climate and tax situation. While there may be some similarities in the portfolios
created by the Firm, we understand that every client has their own unique planning needs. We have the ability
and flexibility to create portfolios to help our client achieve their goals. We may utilize the following forms of
analysis:
Asset Allocation: Our primary investment philosophy attempts to identify the appropriate ratio of diversified
securities, fixed income, and cash suitable to the client's investment goals and risk tolerance. Our asset allocation
strategy de-prioritizes individual security selection. We utilize software to monitor each client's mix of securities,
fixed income, and cash. If the ratio drifts outside of our target tolerance, then we will evaluate a rebalance of the
portfolio back to the target ratio. In addition, we attempt to rebalance on an annual basis each account back to the
target ratio of securities, fixed income, and cash. A risk of asset allocation is that the client may not participate in
sharp increases in a particular security, industry, or market sector. Another risk is that rebalancing a portfolio can
generate taxable capital gains. Another risk is that the ratio of securities, fixed income, and cash will change over
time due to stock and market movements and, if not corrected will no longer be appropriate for the client's goals.
Fundamental Analysis: We utilize fundamental analysis when evaluating the intrinsic value of a security by looking
at economic and financial factors. Those factors include the overall economy, industry conditions, and the financial
condition and management of the company itself. We utilize those factors to determine if the company or fund is
underpriced or overpriced. Fundamental analysis does not aid in anticipating market movements. As a result, this
presents a potential risk, as the price of a security can move up or down along with the overall market regardless
of the economic and/or financial factors evaluated when we considered the investment.
Quantitative Analysis: We utilize quantitative analysis by reviewing mathematical ratios and other performance
metrics as part of our due diligence research of a fund manager's investment acumen, idea generation, consistency
of purpose and overall ability to match or outperform their stated benchmark through a full market cycle.
Additionally, we perform periodic measurements to assess the accuracy and authentic of a manager's published
returns. A risk with quantitative analysis is that the mathematical models and ratios we utilize may be based on
assumptions that prove to be incorrect.
MATTSON FINANCIAL SERVICES, LLC
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Technical Analysis: We use this method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value,
but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts
believe that the historical performance of stocks and markets are indications of future performance. Technical
analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given
security's price and trading volume data. A decision might be made based on a historical move in a certain direction
that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume
for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading
decision being made incorrectly, since future trading volume is an unknown. Technical analysis is also done
through observation of various market sentiment readings, many of which are quantitative. Market sentiment
gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such
sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy
the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish,
then there are very few traders left in a position to sell the security in question, so it becomes advantageous to
buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading
can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish
signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become
more bearish, which may result in a premature purchase of a security.
Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund
or ETF in attempt to determine if that manager has demonstrated an ability to invest over a period of time and in
different economic conditions. We also monitor the funds or ETFs in attempt to determine if they are continuing
to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not
guarantee future results. A manager who has been successful may not be able to replicate that success in the
future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds
held by the client may purchase the same security, increasing the risk to the client if that security were to fall in
value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund
or ETF, which could make the holding(s) less suitable for the client’s portfolio.
Model Manager Analysis: We examine the experience, expertise, investment philosophies, and past performance
of Model Managers in attempt to determine if that manager has demonstrated an ability to invest over a period of
time and in different economic conditions. We monitor the manager’s underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-
diligence process, we survey the Model Manager’s compliance and business enterprise risks.
Risk of Loss
A client’s investment portfolio is affected by general economic and market conditions, such as interest rates,
availability of credit, inflation rates, economic conditions, changes in laws and national and international political
circumstances.
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Investing in securities involve certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. The Firm will assist Clients in determining an appropriate
strategy based on their tolerance for risk.
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 Firm shall rely on the 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 Firm of any changes in financial condition, goals or
other factors that may affect this analysis.
Our methods rely on the assumption that the underlying companies within our security allocations are accurately
reviewed by the rating agencies and other publicly available sources of information about these securities, are
providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always
a risk that our analysis may be compromised by inaccurate or misleading information.
Investors should be aware that accounts are subject to the following risks:
MARKET RISK – Even a long-term investment approach cannot guarantee a profit. Economic, political, and
issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios
will fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon
liquidation.
FOREIGN SECURITIES AND CURRENCY RISK – Investments in international and emerging-market
securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential
for illiquid markets and political instability.
CAPITALIZATION RISK – Small-cap and mid-cap companies may be hindered as a result of limited resources
or less diverse products or services Their stocks have historically been more volatile than the stocks of larger, more
established companies.
INTEREST RATE RISK – In a rising rate environment, the value of fixed-income securities generally declines,
and the value of equity securities may be adversely affected.
CREDIT RISK – Credit risk is the risk that the issuer of a security may be unable to make interest payments
and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s
financial strength may affect a security’s value and thus, impact the fund’s performance.
SECURITIES LENDING RISK – Securities lending involves the risk that the fund loses money because the
borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of
the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls.
These events could also trigger adverse tax consequences for the fund.
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LIQUIDITY RISK - liquidity risk is the risk that there may be limited buyers for a security when an
investor wants to sell. Typically, this results in a discounted sale price in order to attract a buyer. Certain
non-liquid alternative investment funds may also have the ability, at the fund sponsors sole discretion,
to limit or stop its investor’s ability to withdrawal investments in the fund.
DEFAULT RISK - a default occurs when an issuer fails to make payment on a principal or interest
payment.
EVENT RISK - event risk is difficult to predict because it may involve natural disasters such as
earthquakes or hurricanes, as well as changes in circumstance from regulators or political bodies.
POLITICAL RISK - political risk is the risk associated with the laws of the country, or to events that
may occur there. Particular political events such as a government’s change in policy could restrict the
flow of capital.
DURATION RISK - duration is a way to estimate a bond's price sensitivity to changes in interest rates.
The duration of a bond is determined by its maturity date, coupon rate, and call feature. Duration is a
method to compare how different bonds will react to interest rate changes. For example, if a bond has
a duration of five (5) years it means that the value of that security is estimated to decline by
approximately five percent (5%) for every one percent (1%) increase in interest rates, all else equal.
REINVESTMENT RISK - reinvestment risk is the risk that future interest and principal payments may
be reinvested at lower yields due to declining interest rates.
TAX RISK - for municipal bonds, depending on the client’s state of residence, the interest earned on
certain bonds may not be tax-exempt at the state level. Also, changes in federal tax policy may impact
the tax treatment of interest and capital gains of an investment.
REGULATORY RISK - market participants are subject to rules and regulations imposed by one or more
regulators. Changes to these rules and regulations could have an adverse effect on the value of an
investment.
CONCENTRATION RISK - the risk of amplified losses that may occur from having a large portion of
your holdings in a particular investment, asset class or market segment relative to your overall portfolio.
EXCHANGE-TRADED FUNDS – ETFs face market-trading risks, including the potential lack of an active
market for shares, losses from trading in the secondary markets, and disruption in the creation/redemption process
of the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net
asset value.”
PERFORMANCE OF UNDERLYING MANAGERS – We select the mutual funds and ETFs in the asset
allocation portfolios. However, we depend on the manager of such funds to select individual investments in
accordance with their stated investment strategy.
CYBERSECURITY RISK – In addition to the Material Investment Risks listed above, investing involves various
operational and “cybersecurity” risks. These risks include both intentional and unintentional events at our firm or
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FEBRUARY 2026 | PAGE 15
one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in
the unauthorized release or other misuse of confidential information, and generally compromise our Firm’s ability
to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to
our clients’ information, including social security numbers, home addresses, account numbers, account balances,
and account holdings. Our Firm has established business continuity plans and risk management systems designed
to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans
and systems, including that certain risks may not have been identified, in large part because different or unknown
threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because
our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a
risk that cybersecurity breaches may not be detected.
ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING - Certain service providers utilized by the Firm
to service client accounts have artificial intelligence components, such as our client relationship management
system that utilizes artificial intelligence to summarize client meeting notes. The use of artificial intelligence and
machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid
advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As
a measure to mitigate these risks to our clients, our Firm performs periodic due diligence of our service providers
for assurance that the service providers have appropriate controls in place to protect our clients’ information and
to limit data inaccuracies when artificial intelligence is used by the service provider.
ITEM 9 - DISCIPLINARY INFORMATION
Criminal or Civil Actions
MFS and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
In October of 2019, MFS, without admitting or denying the allegations, entered into a Stipulation and
Consent Order with the State of Florida. The Order alleges MFS exceeded the di minis exemption for
registration and fined MFS $10,625.
Self-Regulatory Organization Enforcement Proceedings
MFS and its management have not been involved in legal or disciplinary events related to past or present
investment Clients.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Insurance
Some of the registered advisory personnel of our Firm are licensed insurance agents and may recommend
insurance products through the affiliated insurance entity. They may sell various life insurance products, long term
care and fixed annuities. IARs receive compensation (commissions, or other compensation from the respective
product sponsors) as a result of effecting insurance transactions for clients. A portion of the time IARs spend
(generally 50%) is in connection with these insurance activities and it represents 15% of the ongoing revenue for
our IARs. The advisor has an incentive to recommend insurance and this incentive creates a conflict of interest
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between your interests and our Firm. Clients should note that they have the right to decide whether or not to
engage the services of our IARs. Further, clients should note they have the right to decide whether to act on the
recommendations and the right to choose any professional to execute the advice for any insurance products
through our IAR or any licensed insurance agent not affiliated with our Firm. We recognize the fiduciary
responsibility to place your interests first and have established policies in this regard to avoid any conflicts of
interest.
Third Party Platform Providers
Our Firm has entered into an agreement with platform providers that offer asset management services that
include model money managers, portfolio managers, strategists, marketing and billing/administrative services. As
part of the program, Clients provide our Firm and the platform provider discretion to select third party, non-
affiliated investment managers (“Model Managers”) to design and manage model portfolios. The Firm will utilize
the services of the platform provider to select appropriate products. Platform providers may offer special incentive
compensation to meet certain overall sales goals by placing annuities and/or other insurance products through
their platform. The receipt of commissions and additional incentive compensation itself creates a conflict of
interest. Clients are not required to purchase any insurance products through us in our separate capacity as
insurance agents. The purpose of the platform provider is to assist us to find the insurance company that best fits
the client’s situation.
Platform providers offer marketing assistance and business development tools to acquire new clients, technology
with the goal of improving the client experience and our firm’s efficiency, back office and operations support to
assist in the processing of our insurance and investment services for clients, business succession planning,
business conferences and incentive trips for our firm. Although some of these services can benefit a client, other
services obtained by us from the platform providers, such as marketing assistance, business development and
incentive trips will not benefit an existing client. The Firm can also receive bonus payments from an insurance
company for selling a targeted number of annuities during a specified period of time which creates a conflict of
interest. Our Firm has taken steps to manage these conflicts of interest by requiring that each investment adviser
representative:
• Only recommend insurance and annuities when in the best interest of the client and without regard to
the financial interest of our Firm and its investment adviser representative.
• Not recommend insurance and/or annuities which result in its investment adviser representative
and/or our Firm receiving unreasonable compensation related to the recommendation; and,
• Disclose material conflicts of interest related to insurance or annuity recommendations.
Other Affiliations
Additionally, management personnel of our Firm may engage in outside business activities. As such, these
individuals can receive separate, yet customary commission compensation resulting from implementing product
transactions on behalf of investment advisory Clients. Clients are not under any obligation to engage these
individuals when considering implementation of these outside recommendations. The implementation of any or
all recommendations is solely at the discretion of the Client.
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Gary Mattson, Laurel Steward, Taylor Steward, and Gerald Green all owners of Mattson Financial Services, LLC.
Our Firm does not have an application pending to register, as a futures commission merchant, commodity pool
operator, a commodity trading adviser, or an associated person of the foregoing entities.
Neither our firm nor any of its management persons are registered or have an application pending to register as a
broker-dealer.
Managing Partner Gary Mattson’s principal businesses is a licensed insurance agent with Mattson Insurance
Agency, LLC and Lakeview Financial Group, LLC. From time to time, he offers Clients advice or products from
those activities. Greater than 50% of his time is spent in these practices. Clients are not required to purchase any
products.
Tax Preparation Services
Mattson Financial Services is affiliated with Mattson Tax Solutions, LLC, providing preparation tax services. Some
affiliated persons of the Firm will provide tax preparation services to individuals and corporations. Any fees
received through the tax services do not offset advisory fees the client may pay for advisory services under our
Firm. As a result, a conflict of interest arises between your interests and our Firm’s interest. However, at all times
our Firm and its IARs will act in your best interest and act as a fiduciary in carrying out services provided to you.
Disclosure of Conflicts of Interest
Clients should be aware that the ability to receive additional compensation by our Firm and its management
persons or employees creates conflicts of interest that impair the objectivity of the Firm and these individuals
when making advisory recommendations. Our Firm endeavors at all times to put the interest of its clients first as
part of our fiduciary duty as a registered investment adviser; we take the following steps, among others to address
this conflict:
• We disclose to clients the existence of all material conflicts of interest, including the potential for the Firm
and our employees to earn compensation from advisory clients in addition to the Firm's advisory fees.
• We disclose to clients that they have the right to decide to purchase recommended investment products
from our employees.
• We collect, maintain and document accurate, complete and relevant client background information,
including the client’s financial goals, objectives, and liquidity needs.
•
the Firm conducts regular reviews of each client advisory account to verify that all recommendations made
to a client are in the best interest of the client’s needs and circumstances.
• We require that our employees seek prior approval of any outside employment activity so that we may
ensure that any conflicts of interest in such activities are properly addressed.
• We periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by the Firm.
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INTEREST
IN CLIENT
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR
TRANSACTIONS AND PERSONAL TRADING
Our Firm and persons associated with us are allowed to invest for their own accounts, or to have a financial
investment in the same securities or other investments that we recommend or acquire for your account and may
engage in transactions that are the same as or different than transactions recommended to or made for your
account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in your best interest
and have established polices to mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our
advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal
trading, gifts, and the prohibition against the use of inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel regarding
the Firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and
must act with complete propriety at all times, protect the reputation of the firm, safeguard against the violation
of the securities laws, and establish procedures for personnel to follow so that we may determine whether their
personnel are complying with the Firm’s ethical principles.
We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities:
• No supervised employee of MFS shall prefer his or her own interest to that of the advisory client. Trades
for supervised employees are traded alongside client accounts.
• We maintain a list of all securities holdings of anyone associated with this advisory practice with access to
advisory recommendations. These holdings are reviewed on a regular basis by an appropriate
officer/individual of MFS.
• We emphasize the unrestricted right of the client to decline implementation of any advice rendered, except
in situations where we are granted discretionary authority of the client’s account.
• We require that all supervised employees must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
• Any supervised employee not in observance of the above may be subject to termination.
• None of our associated persons may affect for himself/herself or for accounts in which he/she holds a
beneficial interest, any transactions in a security which is being actively recommended to any of our clients,
unless in accordance with the Firm’s procedures.
You may request a complete copy of our Code by contacting us at the address, telephone, or email on the cover
page of this Part 2; ATTN: Laurel Steward, Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer or bank. MFS does
not recommend or select broker-dealers for client transactions.
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We recommend that you establish accounts with these Custodians to maintain custody of your assets and to affect
trades for your accounts. Some of the products, services and other benefits provided by the Custodian benefit us
and may not benefit you or your account. Our recommendation/requirement that you place assets with a
custodian may be based in part on benefits they provide us, and not solely on the nature, cost or quality of custody
and execution services provided by the custodian. The Custodian we utilize makes available to us other products
and services that benefit us but may not benefit your accounts in every case.
The Custodian provides various benefits and payments to registered investment advisers that are new to the
custodial platforms to assist the firm with the costs associated with starting a Registered Investment Advisory
firm and transitioning the business to the Custodian. Some of the other Custodian products and services assist us
in managing and administering your accounts. These include software and technology that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of
aggregated trade orders for multiple client accounts), provide research, pricing information and other market data,
facilitate payment of our fees from your account, and assist with back-office functions, recordkeeping and
reporting.
We are independently owned and operated and not affiliated with any Custodian. They provide us with access to
their institutional trading and custody services. These services include brokerage, custody, research and access to
mutual funds and other investments that are otherwise generally available only to institutional investors.
You may be able to obtain lower commissions and fees from other brokers and the value of products, research and
services given to us is not a factor in determining the selection of broker/dealer or the reasonableness of their
commissions. The Custodian's execution quality may be different than other broker-dealers.
Many of these services generally may be used to service all or a substantial number of our accounts. The Custodian
also makes available to us other services intended to help us manage and further develop our business enterprise.
These services may include consulting, publications and conferences on practice management, information
technology, business succession, regulatory compliance, and marketing. In addition, the custodian may make
available, arrange and/or pay for these services rendered to us by third parties. The Custodian may discount or
waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party
providing these services to us.
While as a fiduciary, we endeavor to act in your best interest, our recommendation that you maintain your assets
in accounts at our recommended custodians may be based in part on the benefit to us or the availability of some
of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage
services provided by the custodian, which may create a conflict of interest. IARs endeavor at all times to put the
interest of our clients first as a part of their fiduciary duty.
There is no direct link between our participation in a Custodian’s platform and the investment advice we give to
our clients. We/you may receive economic benefits through our participation in a platform that may not be
available to other advisors. These benefits include the following products and services (provided without cost or
at a discount): receipt of duplicate Client statements and confirmations; research related products and tools;
consulting services; access to a trading desk serving Adviser participants; access to block trading (which provides
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the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client
accounts); the ability to have advisory fees deducted directly from Client accounts; access to an electronic
communications network for Client order entry and account information; access to mutual funds with no
transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research,
technology, and practice management products or services provided to us by third party vendors. The Custodian
may also have paid for business consulting and professional services received by some of our related persons.
Some of the products and services made available by the Custodian through the program may benefit us but may
not benefit your account. These products or services may assist us in managing and administering your account,
including accounts not maintained at the Custodian. Other services made available by the Custodian are intended
to help us manage and further develop our business enterprise. The benefits received by our firm or our personnel
through participation in the program do not depend on the amount of brokerage transactions directed to the
Custodian. As part of our fiduciary duties to clients, we endeavor at all times to act in the best interest of our
clients. You should be aware, however, that the receipt of economic benefits by us or our related persons in and
of itself creates a conflict of interest and may indirectly influence our choice of the Custodian for custody and
brokerage services.
Brokerage for Client Referrals
The Firm does not receive client referrals from our Custodians or any third party in exchange for using our
Custodians or any third party.
Aggregation and Allocation of Transactions
MFS does not trade for its or its Clients’ accounts and therefore aggregation of securities transactions is not
applicable.
Trade Errors
We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts
cannot always be avoided. Consistent with the Firm’s fiduciary duty, it is the Firm’s policy to correct trade errors
in a manner that is in the best interest of the client. In cases where the client causes a trade error, the client will
be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade
error, the client may not be able to receive any gains generated as a result of the error correction. In all situations
where the client does not cause the trade error, the client will be made whole and we will absorb any loss resulting
from the trade error if the error was caused by the firm. If the error is caused by the custodian, the custodian will
be responsible for covering all trade error costs. We will never benefit or profit from trade errors.
ITEM 13 - REVIEW OF ACCOUNTS
Account Reviews and Reviewers – Investment Supervisory Services
Our Investment Adviser Representatives will monitor client accounts on a regular basis and perform annual
reviews with each client. All accounts are reviewed for consistency with client investment strategy, asset
allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent reviews may be
triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical and macroeconomic
specific events may also trigger reviews. You are urged to notify us of any changes in your personal circumstances.
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Statements and Reports
The custodian for the individual client’s account will also provide clients with an account statement at least
quarterly. You are urged to compare the reports provided by the Firm against the account statements you receive
directly from your account custodian.
Retirement Plan Services
We will contact you at least once a year to review our Retirement Plan Services. It is important that you discuss
any changes in the Plan's demographic information, investment goals, and objectives with your IAR. Plans may
receive written reports directly from their IAR based upon the services being provided, including any reports
evaluating the performance of Plan investment manager(s) or investments.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Our Firm does not receive nor pay compensation for client referrals.
Our Firm may be asked to recommend a financial professional, such as an attorney, accountant, or mortgage
broker. In such cases, our Firm does not receive any direct compensation in return for any referrals made to
individuals or firms in our professional network. Clients must independently evaluate these firms or individuals
before engaging in business with them and clients have the right to choose any financial professional to conduct
business. Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm
does not pay any direct compensation in return for any referrals made to our Firm. Our Firm does recognize the
fiduciary responsibility to place your interests first and have established policies in this regard to mitigate any
conflicts of interest.
From time to time, we may receive expense reimbursement for travel and/or marketing expenses from distributors
of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at
due diligence and/or investment training events hosted by product sponsors. Marketing-expense reimbursements
are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs
incurred for marketing such as advertising, publishing and seminar expenses. Although receipt of these travel and
marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor
reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales
will be made.
ITEM 15 – CUSTODY
Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client
funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If
an investment advisor has the ability to access or control client funds or securities, the investment advisor is
deemed to have custody and must ensure proper procedures are implemented.
While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian,
as discussed above), our Firm is deemed to have constructive custody over those client accounts where we are
able to deduct our fees directly from the account. As long as we comply with certain regulatory requirements, this
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constructive custody does not mandate that we undergo a surprise audit for those accounts. Our clients receive
account statements directly from the qualified custodian at least quarterly. We strongly urge our clients to
compare such reports with the statements received from the qualified custodian. Furthermore, the co-advisor
calculates our investment management fees and will deduct the fees directly from clients’ accounts. The custodian
does not verify our calculation of fees. We perform quarterly testing to ensure that our fees are charged in
accordance with the client’s Agreement.
ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging our Firm to provide investment advisory services, you will enter a
written Agreement with us granting the Firm the authority to supervise and direct, on an on-going basis,
investments in accordance with the client’s investment objective and guidelines. MFS does not have discretionary
authority to determine the securities to be bought or sold within a specific portfolio model. The Co-Advisory
Agreement grants MFS limited discretionary authority over your account.
The Client approves the custodian to be used and the commission rates paid to the custodian. MFS does not
receive any portion of the transaction fees or commissions paid by the Client to the custodian on certain trades.
ITEM 17 – VOTING CLIENT SECURITIES
Our Firm will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent third-
party at your own discretion. You designate proxy voting authority in the custodial account documents. You must
ensure that proxy materials are sent directly to you or your assigned third party. We do not act with respect to
any securities or other investments that become the subject of any legal proceedings, including bankruptcies.
Clients can contact our office with questions about a particular proxy solicitation by phone at 800-536-8907.
ITEM 18 – FINANCIAL INFORMATION
Our Firm does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not
subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to
clients. Finally, we have not been the subject of a bankruptcy petition at any time.
Related Party Expense Sharing
The Adviser participates in expense-sharing arrangements with its entities under common ownership or control.
Certain operational expenses (such as rent, technology, and administrative support) are allocated between the
Adviser and the affiliates based on a reasonable and consistently applied methodology designed to reflect each
entity’s actual use and benefit.
There is a risk that expense-sharing arrangements could create conflicts of interest if expenses are not properly
allocated or reimbursed. The Adviser maintains written policies and procedures designed to ensure that:
• Clients do not bear expenses unrelated to advisory services;
• Expense allocations are reviewed periodically for accuracy and reasonableness; and
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• Any material conflicts arising from these arrangements are disclosed.
Privacy Policy
Our Firm collects nonpublic personal information about Clients from information provided on applications or other
forms, as well as from information regarding Client transactions with our Firm, our affiliates, or others. In
accordance with Regulation S-P, our Firm does not disclose any nonpublic personal information about current or
former Clients to third parties, except as permitted or required by law, or as necessary to service Client accounts.
Access to Client information is restricted to Firm personnel who require such information to provide investment
advisory services. Our Firm maintains physical, electronic, and procedural safeguards designed to protect Client
information in compliance with federal standards and Regulation S-P. Our Firm provides a copy of its Privacy
Policy to Clients at the time of account opening, upon request, and annually if the Policy is amended.
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