McGuire Capital Advisors, Inc.

MCGUIRE CAPITAL ADVISORS, INC. (CRD #164549) Firm Brochure The date of this Brochure is June 9, 2026 MCGUIRE CAPITAL ADVISORS, INC., (CRD #164549) Successor to McGuire Capital Management, L.L.C. 6632 NW 39th Expressway Bethany, Oklahoma 73008- 2760 Telephone: (405) 760-5863 mmcguire@mcguireCapital.com Website: www.mcguireCapital.com This Brochure provides information about the qualifications and business practices of McGuire Capital Advisors, Inc. (in this Brochure, we refer to McGuire Capital Advisors, Inc. as McGuire Capital or the Firm). If you have any questions about the contents of this Brochure, please contact Michael W. McGuire, President, using the contact information above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC), the state of Oklahoma Department of Securities (Oklahoma Department of Securities) or any other regulatory authority. McGuire Capital is registered or licensed as an investment adviser in the states of Oklahoma and Texas and will register or become licensed in any other jurisdiction where its activities require it to do so. Representatives of the Firm are registered or licensed as investment adviser representatives (Representatives) of the Firm in Oklahoma and in any other jurisdictions where their activities require them to be so registered or licensed. Registration or licensing does not imply that any of the Firm or its Representatives has any certain level of skill or training. Public Information about McGuire Capital may be found by searching for McGuire Capital on the Website of the SEC, by accessing either of the following links, searching for the Firm by its name or by its CRD Number listed above, a unique identifying number assigned by the SEC: https://www.adviserinfo.sec.gov or https://www.investor.gov Information about the Firm may also be found by contacting the Oklahoma Department of Securities using the following link or contact information below. securities.ok.gov/main/ 204 North Robinson Avenue, Suite 400 Oklahoma City, Oklahoma 73102-7001 Telephone: (405) 280-7700 Fax: (405) 280-7742  Item 2 - Material Changes The following changes have been made since the last update of this brochure on March 23, 2026: 1. Item 4 has been amended to reflect the updated assets under management. 2. Item 5 has been updated with a new fee schedule for Gradient Investments. 2  Item 3 - Table of Contents Item 1 – Cover Page ............................................................................................................... 1 Item 2 - Material Changes ...................................................................................................... 2 Item 3 - Table of Contents...................................................................................................... 3 Item 4 - Advisory Business ..................................................................................................... 6 A. The Firm ...................................................................................................................... 6 B. Types of Services ......................................................................................................... 6 1. Separate Account Management ................................................................................................. 6 2. Co-Advisor Services ..................................................................................................................... 6 3. Types of Investments .................................................................................................................. 6 C. Tailoring Services to Needs of Clients ........................................................................... 7 1. Advisory Contract and Investment Profile .................................................................................. 7 2. Investment Profile ....................................................................................................................... 7 3. Client Portfolio ............................................................................................................................ 7 4. Subsequent Reviews ................................................................................................................... 8 D. Wrap Fee Programs ..................................................................................................... 8 E. Assets Under management .......................................................................................... 8 Item 5 - Fees and Compensation ............................................................................................ 8 A. Fees Charged ............................................................................................................... 8 1. Separate Account Management ................................................................................................. 8 2. Co-Advisor Services ..................................................................................................................... 9 3. Additional Services .................................................................................................................... 10 B. Payment of Advisory Fees .......................................................................................... 11 1. Deduction of Fees ..................................................................................................................... 11 2. Statements ................................................................................................................................ 11 C. Other Fees Paid by Clients ......................................................................................... 11 Investments in Funds ................................................................................................................ 11 1. 2. Custody ..................................................................................................................................... 11 3. Brokerage and other Costs ....................................................................................................... 11 D. Advance Payments and Refunds ................................................................................ 12 1. Fees Due in Advance ................................................................................................................. 12 2. Proration of Fees and Refunds .................................................................................................. 12 E. Compensation for Sales of Securities.......................................................................... 12 Item 6 - Performance-Based Fees and Side-By-Side Management......................................... 12 Item 7 - Types of Clients ...................................................................................................... 13 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................................... 13 A. Methods of Analysis and Investment Strategies ......................................................... 13 B. Risks of Strategies Used ............................................................................................. 13 3  C. Risks of Securities ...................................................................................................... 13 D. Other Types of Risks .................................................................................................. 14 1. Cybersecurity Breaches ............................................................................................................. 14 2. Privacy and Confidentiality ....................................................................................................... 14 3. Third Party Vendors .................................................................................................................. 15 4. Policies and Procedures ............................................................................................................ 15 Item 9 - Disciplinary Information ......................................................................................... 15 A. Criminal or Civil Actions ............................................................................................. 15 B. Administrative Proceedings ....................................................................................... 16 C. Action by Self-Regulatory Organizations .................................................................... 16 D. Additional Information .............................................................................................. 17 Item 10 - Other Financial Industry Activities and Affiliations ................................................ 17 A. Broker-Dealer Registration ........................................................................................ 17 B. Futures and Commodities Registration....................................................................... 17 C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest 17 D. Recommendation of Investment Advisers .................................................................. 18 Item 11 - Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 18 A. Code of Ethics ............................................................................................................ 18 B. Conflicts in Securities Holdings ................................................................................... 19 C. Conflicts in Securities Investing .................................................................................. 19 D. Conflicts in Contemporaneous Transactions ............................................................... 19 Item 12 - Brokerage Practices .............................................................................................. 19 A. Recommending Broker-Dealers .................................................................................. 19 1. Selection of Broker and Custodians. ......................................................................................... 19 2. Best Execution ........................................................................................................................... 19 3. Research and Other Soft Dollar Benefits .................................................................................. 20 4. Brokerage for Client Referrals ................................................................................................... 20 5. Fund Management Costs .......................................................................................................... 20 B. Aggregation and Bunching of Orders .......................................................................... 20 Item 13 - Review of Accounts ............................................................................................... 20 A. Regular Review .......................................................................................................... 20 B. Factors Triggering Extra Reviews ................................................................................ 21 C. Reports to Clients ...................................................................................................... 21 Item 14 - Client Referrals and Other Compensation .............................................................. 21 A. Economic Benefits for Providing Advice ..................................................................... 21 B. Payment for Referrals ................................................................................................ 21 4  Item 15 - Custody ................................................................................................................ 22 Item 16 - Investment Discretion ........................................................................................... 22 Item 17 - Voting Client Securities ......................................................................................... 22 Item 18 - Financial Information ............................................................................................ 22 A. Prepayment of Fees ................................................................................................... 22 B. Financial Condition .................................................................................................... 22 C. Bankruptcy ................................................................................................................ 22 5  Item 4 - Advisory Business A. The Firm Michael W. McGuire founded McGuire Capital Management, L.L.C. in November 2011 as an Oklahoma limited liability company. On April 1, 2023, the Firm was converted to an Oklahoma corporation, McGuire Capital Advisors, Inc. (McGuire Capital). Michael McGuire is the sole owner. Scott McPherson is the Chief Compliance Officer. B. Types of Services 1. Separate Account Management McGuire Capital provides asset management services to individuals or entities (Clients), in separately managed accounts (Separate Accounts), based on each Client’s individual objectives and financial situation (see Subsection C, below). McGuire Capital only accepts Clients who grant the Firm discretion to implement the transactions in securities the Firm recommends for its Clients (see Item 16). The Firm also selects the broker-dealers to process orders for transactions in Client securities (see Item 12) and the custodians to maintain the Client’s assets (see Item 15). McGuire Capital does not manage assets for Clients on a nondiscretionary basis and does not allow Clients to select the broker-dealers through which their transactions are processed or the custodian for their assets. The Firm is not affiliated with the broker-dealers or custodians it recommends for Client assets. 2. Co-Advisor Services McGuire Capital has also entered into a Co-Advisor relationship with Gradient Investments, LLC (GI). McGuire Capital will provide information to each client regarding the services offered by GI as the portfolio manager. McGuire Capital will assist the Client to determine the appropriate model selection based on the Client’s investment objectives and risk tolerance. McGuire Capital will have full discretion on an ongoing basis to select suitable models to maintain client’s risk tolerance. McGuire Capital will share in the management fees charged by GI as described in Item 5 of this brochure. 3. Types of Investments McGuire Capital has developed a policy (Investment Policy) that includes the kinds of securities that it recommends to its clients. Each Representative selects investments individually for each Client based on the Client’s Investment Profile and the Firm’s Investment Policy (see Subsection C, below). Generally, the Firm’s Investment Policy includes recommendations of publicly traded securities, such as stocks, Exchange Traded Funds and Mutual Funds; as well as bonds and fixed income securities, depending on the needs and risk tolerance of the Client. The Firm’s Investment Policy does not include options, short term trading or other investments or strategies that the Firm considers to be high risk. Note, however, that all investments involve some risk. See Item 8. 6  C. Tailoring Services to Needs of Clients 1. Advisory Contract and Investment Profile McGuire Capital requires its Clients to sign an investment advisory contract (Advisory Contract) before providing any investment advisory services to the Client (see Subsection 2, below). McGuire Capital uses the information in the Client’s Investment Profile to develop an initial, recommended portfolio of investments to be held in a Separate Account for that Client at the Custodian. Once the Separate Account is funded with the initial assets, each Representative works with each Client, individually, to recommend investments that are specifically selected for that Client . The Representative continues to review the Client’s account regularly, but at least annually and will make ongoing recommendations about the purchase, sale or holding of assets in the Client’s Account (see Subsection 3, below). 2. Investment Profile Each Representative develops the Client’s Investment Profile by having the Client provide some or all of the following information: • • • • • • • • • • • • • • investment objectives; financial goals, short-term and long-term; risk tolerance levels; current income and anticipated future income; personal situation, such as marital situation, dependents, special needs; financial and other assets; anticipated future financial requirements; anticipated future needs; educational funding; retirement plans; estate plans; insurance; securities or categories of securities the Client wants to acquire; and securities or categories of securities the Client wants to avoid. 3. Client Portfolio After an initial meeting, the Representative will analyze the Client’s Investment Profile using research and financial planning tools available to the Firm (see Item 12.A.1) to develop the structure of an investment portfolio for the Client. The Representative takes into consideration the Client’s Investment Profile and the Firm’s Investment Policy in developing recommendations, as well as market conditions and research concerning investments. The Representative will schedule at least one additional meeting with the Client to review the planned investments and to answer any questions the Client might have or any comments on the proposed portfolio structure. Subsequently, the Representative will have the Client sign the Advisory Agreement, confirm the Investment Profile information and sign other documents required to transfer the assets to the custodian for the Client’s account, after which, the Representative will implement the recommendations and oversee the management of the assets in the portfolio. 7  4. Subsequent Reviews After the initial plan is implemented, the Representative reviews the Client’s account continuously to monitor the investments in the account and will communicate with the Client from time to time. The Representative will make changes to the investments as the Representative believes necessary or appropriate to manage the accounts, based on each Client’s disclosed financial situation and objectives (see Item 13). D. Wrap Fee Programs McGuire Capital does not offer wrap fee programs. E. Assets Under management As of March 23, 2026, McGuire Capital had $202,424,203 in regulatory assets under management, all of which were being managed on a discretionary basis. Item 5 - Fees and Compensation A. Fees Charged 1. Separate Account Management McGuire Capital typically charges the following annual fees for managing Client assets held in Separate Accounts: Assets Under Management Annual Fee % of Assets Quarterly Fee % of Assets .5000 Up to $2,000,000 2.00 .3750 $2,000,000 up to $3,000,000 1.50 .3125 $3,000,000 up to $4,000,000 1.25 .2500 Over $4,000,000 1.00 The above table describes the fees that McGuire Capital charges client under normal circumstances. Fees may be negotiable based on factors such as the length of time the Firm has been managing the assets for the Client; the nonprofit or charitable status of a Client; the percentage of Client holdings in fixed income assets; and/or the number of related accounts under management. Under no circumstances, will the Firm charge fees greater than those described above. The Client and McGuire Capital must agree on the fees that will be charged in the signed Advisory Agreement before McGuire Capital will start managing the assets. Fees are billed quarterly in advance at the beginning of each quarter. Fees are calculated based on the value of assets under management at the end of the last quarter or if the assets are deposited between quarters, at the value of the assets when deposited with the custodian for management by McGuire Capital. To calculate its fee, McGuire Capital uses the value of the assets determined by the custodian of the assets. If the custodian does not provide the values, McGuire Capital may use values 8  determined by an independent pricing agent, such as a broker-dealer through which McGuire Capital processes Client transactions. If McGuire Capital is unable to determine a market value, McGuire Capital will use a value based on comparable sales of similar securities or other methods determined to be reasonable by McGuire Capital. Currently, Charles Schwab & Co., the Firm’s custodian, calculates the value of the assets in each Client’s account to determine the fee to be charged. Assets managed through Gradient would be valued by Gradient and its custodians. McGuire Capital may borrow against the securities in a Client’s Account (using margin) as a strategy in managing a Client’s account (see Item 8.B). In addition, some Clients may also use margin in their accounts to cover cash flow needs. In charging fees to accounts invested using margin, McGuire Capital charges fees based on the gross market value of all the securities in the Client’s account, without consideration of the amount of margin or borrowings against those securities. 2. Co-Advisor Services McGuire Capital has entered into a Co-Advisor Agreement with Gradient Investments, LLC (“GI”) SEC number 801-70812. GI is a Registered Investment Advisor registered with the Securities and Exchange Commission that provides investment portfolio advice and supervisory services. 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: Portfolio GI Fee* Asset Valuation Stated Total Annual Fee Custom Indexing - Strategic Strategic Custom Indexing - Allocation Allocation Tactical Defined Outcome Private Wealth Preservation Client Directed Accounts All Assets All Assets All Assets All Assets All Assets All Assets All Assets All Assets All Assets 1.65% 1.50% 1.65% 1.50% 1.50% 1.50% 1.50% 1.00% $300 0.65% 0.50% 0.65% 0.50% 0.50% 0.50% 0.50% 0.40% $300 McGuire Capital Fee (Negotiable) 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 0.60% $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. Example: Portfolio Calculation Quarter Fee Custom Indexing – Strategic & Allocation ($750,000*1.65%) * (91/365) $3,085.27 ($750,000*1.50%) * (91/365) $2,804.79 Strategic, Tactical, and Allocation & Defined Outcome Portfolios 9  Private Wealth Portfolio: ($750,000*1.50%) * (91/365) $2,804.79 Preservation Portfolios ($750,000*1.00%) * (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 and will take into account additions and withdrawals in the time period. All management fees are withdrawn from the Client’s account unless otherwise noted. GI will receive written authorization from the Client to deduct advisory fees from their account held by a qualified custodian. GI will pay McGuire Capital their share of the fees. McGuire Capital 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 McGuire Capital their portion of the final fee. Incentive Program - GI In addition to the regular advisory fee, GI has instituted a long-term incentive arrangement by McGuire Capital can share in GI’s portion of the management fee. This does not change the cost to the Client; it is a sharing arrangement paid from GI’s portion of the advisory fee. The incentive arrangement will be paid annually according to the following table: McGuire Capital Quarterly AUM with GI $10,000,000 $25,000,000 $50,000,000 $75,000,000 Participation rate in GI’s fee 3.00% 10.00% 12.50% 15.00% Once McGuire Capital reaches and maintains the thresholds listed above, the participation rate applies to all of the AUM for the quarter. To receive the incentive award, McGuire Capital needs to meet two qualifications. First, the quarter end billable AUM must be above the threshold amounts specified. Second, McGuire Capital must be an advisor “in good standing” with GI at the time the annual checks are issued. “In good standing” means the advisor is proactively placing assets with GI. This relationship will be disclosed to the Client in each contract between McGuire Capital and Third Party Money Manager. McGuire Capital does not charge additional management fees for Third Party managed account services. Client's signature is required to confirm consent for services within Third Party Investment Agreement. Client will initial McGuire Capital Investment Advisory Agreement to acknowledge receipt of Third Party fee Schedule and required documents including Form ADV Part 2 disclosures. 3. Additional Services 10  McGuire Capital does not currently charge for providing any additional services to Clients, such as providing additional copies of statements or monthly expense charges. McGuire Capital reserves the right to charge such fees in the future, if necessary to cover extraordinary costs it might be asked to incur in providing extra services. B. Payment of Advisory Fees 1. Deduction of Fees Clients must agree to have all fees due to McGuire Capital deducted directly from their accounts. McGuire Capital assures that each Client is sent a statement at the beginning of each quarter describing the amounts that will be deducted from their accounts for fees due to McGuire Capital for advisory services during the next quarter. The statement must be sent within the first fifteen days of each quarter. Generally, the custodian of the assets calculates the fees and sends the statements to each Client with copies to McGuire Capital, and, if not already provided to the Client, the formula used to calculate the fee. If, for some reason, fees cannot be deducted from a Client’s account, the Client will be billed directly and required to pay within 30 days of billing. 2. Statements The custodian sends quarterly reports to each client describing the value of the assets held in the Client’s account at the beginning of each period, the value of transactions during the period, the management fees paid to McGuire Capital during the quarter then ended and any other fees deducted from the account during the period (see Subsection c, below). The report also includes a description of each transaction in each security bought, sold and those in the account at the end of the period. C. Other Fees Paid by Clients In addition to the fees charged by McGuire Capital, Clients investing in securities through McGuire Capital will be required to pay additional fees as described below in this section. 1. Investments in Funds Clients investing in securities of investment companies, such as Exchange-Traded Funds (ETF’s), mutual funds or hedge funds, should be aware that funds charge management and administration fees to the shareholders (investors) in the funds. Those fees are charged to shareholders in the funds on a prorata basis and are in addition to the fees McGuire Capital charges its Clients. Similarly, for Clients invested in the Gradient program, the investment advisers managing the assets in each of the different strategies charge management fees that are in addition to the fees that McGuire Capital and Gradient charge. 2. Custody Clients using the services of McGuire Capital must place their assets in an account held by a custodian selected by McGuire Capital. Those custodians charge fees for their custodial services. Clients are responsible for payment of the fees charged by those custodians, which are generally deducted from the Clients’ accounts. 3. Brokerage and other Costs 11  The broker-dealer through which McGuire Capital places orders for the purchase or sale of securities charge Clients brokerage fees, which are usually deducted from the Client’s account or deducted from the proceeds of sales of securities. Those fees include commissions for the execution of securities transactions, administrative fees, taxes and other costs or fees for services provided by the bd directly to the Client. Clients are responsible for all brokerage fees and costs incurred in connection with the management of their accounts. See Item 12. D. Advance Payments and Refunds 1. Fees Due in Advance As described above in Item 5.A., McGuire Capital collects payment for its management fees in advance at the beginning of each quarter. In no event will McGuire Capital collect fees of more than $1,200 per Client, more than six months in advance. 2. Proration of Fees and Refunds If advisory services begin or end on a date other than the first or last day of a quarter, the fees charged by McGuire Capital will be prorated based on the number of days during the quarter that assets were, or are expected to be managed by McGuire Capital. If a Client or McGuire Capital ends the management of a Client’s account during a quarter, before all fees have been earned, any unearned fees will be refunded to the Client within 30 days following the date on which the advisory services ended. E. Compensation for Sales of Securities As described in Item 5.C., above, Clients are charged sales commissions and other transaction costs by the broker-dealers executing transactions recommended by McGuire Capital. Neither McGuire Capital nor any individual employed by McGuire Capital (Associated Persons) accepts any compensation for executing transactions in securities for Clients. Under its arrangement with Gradient, McGuire Capital shares in the management fees charged by Gradient for those services as described in the separate Brochure for those services. Investment Advisor Representatives of McGuire Capital receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures, and McGuire Capital’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. Item 6 - Performance-Based Fees and Side-By-Side Management McGuire Capital does not charge fees for management of Client assets that are based on a share of Capital gains on, or Capital appreciation of the assets in the Client’s account (performance-based fees). McGuire Capital charges the same fee structure for all Client accounts it manages, though it may negotiate higher or lower fees based on various factors discussed in Item 5.A. Clients with assets being managed through Gradient should view the Brochure for that Program to determine if fees are charged differently. 12  Item 7 - Types of Clients The Clients of McGuire Capital are primarily individuals, including high net worth individuals and small businesses. McGuire Capital also manages assets for other types of investors, such as larger businesses, non-profits, charitable organizations, endowments, trusts or estates. McGuire Capital does not have a minimum fee or minimum account size; however, McGuire Capital may decline to accept a Client if the amount of assets to be managed is not large enough to allow McGuire Capital to manage the assets effectively. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies In selecting securities, McGuire Capital uses charting, which includes the analysis of past market data, primarily price and volume information, as a tool to assist in predicting future trends. McGuire Capital also uses fundamental methods of analysis by reviewing both quantitative and qualitative aspects of companies under consideration, to evaluate their strengths and weaknesses. McGuire Capital uses these methods to determine which companies, in its opinion, will offer the most appropriate for Clients. McGuire Capital uses research and other information available through its custodian and other sources of information including: • • • • • • financial newspapers, magazines, newsletters and other periodicals; annual reports, prospectuses and other filings with the SEC; research materials prepared by others; company press releases; corporate rating services; and technical analytical tools. The investment strategies used to implement any investment advice given to Clients consist primarily of a combination of long-term and short-term purchases and sales. McGuire Capital and some Clients may elect to set up a margin account and use margin in managing their assets. B. Risks of Strategies Used All investments are subject to market risks, risks related to the type of industry involved and other risks of investments. The use of margin is subject to regulatory requirements that include a forced sale of securities in the event the level of borrowings exceeds regulatory limits. That can occur in the event of unexpected market drops affecting the entire account or drops in the market price of securities subject to margin. In that event, the securities may be sold at a discounted value resulting in a loss to the Client. The manner in which McGuire Capital uses margin, includes monitoring for market risks and attempting to address a drop as quickly as possible. Other than margin, McGuire Capital does not use strategies that it believes create a high risk. McGuire Capital does not use frequent trading, market-timing, option writing, or similar strategies that McGuire Capital believes may increase risk for Clients. C. Risks of Securities McGuire Capital recommends investments in securities of most types, including exchange listed and over the counter equities, mutual funds, exchange-traded funds (EFTs), debt securities, commercial paper, 13  certificates of deposit, other fixed income securities, municipal securities, interests in partnerships and government securities. McGuire Capital does not invest in unregistered private funds or penny stocks. Investing in mutual funds or EFTs can involve payment of fees to the manager of those funds in addition to the fees Clients pay to McGuire Capital for managing their assets. High-grade debt securities, certificates of deposit and government securities can provide lower risk of loss for Clients, but they may result in lower long-term returns than do low-grade debt or equity securities of smaller Capitalized companies. Interests in partnerships, hedge funds or similar securities may require a long-term investment and may involve limits on liquidity. D. Other Types of Risks 1. Cybersecurity Breaches Regulators have recently identified unauthorized access to Client Confidential Information through Cybersecurity Breaches or other failure to protect Confidential Information as having high-risk consequences for investors. Although McGuire Capital does not have custody of the assets it manages for Clients, it collects personal non-public information and other Confidential Information about Clients and their assets (Client Confidential Information) in connection with managing their assets. There is a risk that unauthorized third parties could obtain access to such information through hacking or otherwise penetrating the Firm’s electronic systems (Cybersecurity Breaches) on which Client Confidential Information is stored. Such access could subject Clients to potential theft of funds from Client accounts, identity theft or ransomware. 2. Privacy and Confidentiality There is also a risk that unauthorized persons could access Client Confidential Information through inadequate privacy protections, such as allowing third parties to use a computer on which Confidential Information is stored or from which Client Confidential Information may be accessed or transporting Client Confidential Information on flash drives or laptops without adequately protecting those devices from theft or loss. 14  3. Third Party Vendors Finally, there is a risk that Client Confidential Information shared by the Firm with third party vendors, such as custodians of Client assets or broker-dealers executing Client transactions, could be subject to Cybersecurity Breaches or privacy risks if the Client Confidential Information is not adequately protected by those third parties. McGuire Capital has no control over those third parties, except through contracts it executes with those parties, if any. 4. Policies and Procedures McGuire Capital has adopted policies and procedures that it believes are reasonably designed to address the risks described above. Those procedures contain the following provisions, among other requirements: a. b. c. d. e. The Firm must identify an individual as the Firm’s Chief Information Security Officer who is responsible for identifying and addressing any Cybersecurity Breaches or other unauthorized access to Confidential Information. Jacob McGuire is serving as the Firm’s Chief Information Security Officer. He relies on unaffiliated third parties to assist him in carrying out his responsibilities as Chief Information Security Officer. The Firm must install software on its computers reasonably designed to identify unauthorized access to the Firm’s electronic systems. The Firm must update security software on its systems on a regular basis. The Firm must obtain written representations from third party vendors with which the Firm shares Client Confidential Information that such vendors have adopted and implemented policies and procedures reasonably designed to prevent unauthorized access to Client Confidential Information that the Firm provides to those vendors. The Firm must notify Clients and regulators as soon as it learns that there has been any unauthorized access to Client Confidential Information or its electronic systems that could have compromised Client Confidential Information. There is no assurance that the Firm’s procedures or those of third party vendors will be adequate to protect the Firm and the information that flows through the Firm from all unauthorized access by third parties. Item 9 - Disciplinary Information None of McGuire Capital, its Representatives nor any other person having the power to exercise a controlling influence, directly or indirectly, over the management of McGuire Capital (Management Person) has been involved in any material legal or disciplinary proceedings that regulatory authorities consider material to an evaluation of McGuire Capital by its Clients or potential Clients. Regulatory authorities consider the following types of matters to be material: A. Criminal or Civil Actions Conviction of a crime; 1. 15  pleading guilty, nolo contendere, or no contest in any criminal proceeding; 2. being named in a currently pending criminal action; 3. having been found to have violated any investment-related statute or regulation; or 4. 5. being named in any order, judgment or decree permanently or temporarily enjoining, or otherwise limiting, the person from engaging in any investment-related activity, or from violating any investment-related statute, rule or order. B. Administrative Proceedings Administrative proceedings before the U.S. Securities and Exchange Commission, any other federal regulatory agency, any state regulatory agency or any foreign financial regulatory authority in which the person was: 1. found to have caused an investment-related business to lose its authorization to do business; or 2. found to have been involved in a violation of an investment-related statute or regulation and was the subject of an order by the agency or authority: a. denying, suspending, or revoking the person’s authority to act in an investment- related business; b. barring or suspending the person from association with an investment-related business; c. otherwise significantly limiting the person’s investment-related activities; or d. imposing a civil monetary penalty. C. Action by Self-Regulatory Organizations Any proceeding before any self-regulatory organization, such as the Financial Industry Regulatory Authority, in which a person was: 1. found to have caused an investment-related business to lose its authorization to do business; or found to have been involved in a violation of the organization’s rules and was: 2. a. barred or suspended from membership or from association with other members, or was expelled from membership; or otherwise significantly limited from investment-related activities; or b. subject to a monetary fine. c. 16  D. Additional Information To confirm the above statements and to review any public information about disciplinary actions involving McGuire Capital, its Representatives or any other Management Person, or information about any other investment adviser and its associated persons, please review the information available on the website of the SEC or contact the Oklahoma Department of Securities using the contact information on the cover of this Brochure. Item 10 - Other Financial Industry Activities and Affiliations A. Broker-Dealer Registration None of McGuire Capital, its Representatives or any Management Person is registered with the SEC as a broker dealer or representative of a broker-dealer. B. Futures and Commodities Registration None of McGuire Capital, its Representatives or any Management Person is registered or has applied to be registered as a futures commission merchant commodity pool operator, a commodity trading advisor, or as a Management Person of any of those entities. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Michael McGuire has been licensed to sell Insurance as an Insurance Producer in the state of Oklahoma since 2013. He currently offers insurance through McGuire Retirement Solutions, LLC a limited liability company owned by him that he has licensed as an Insurance Producer in Oklahoma. He is currently authorized to offer and sell Accident and Health or Sickness insurance; Variable Life and Variable Annuity Contracts; and Life Insurance policies. Retirement Solutions shares office space with McGuire Advisors in Bethany, Oklahoma. Michael McGuire receives ongoing commissions for the insurance policies he sells to Clients, which could create a conflict of interest. He only offers insurance policies to Clients for whom he believes the insurance would be in the Clients’ best interest. Clients are not obligated to purchase insurance from Michael McGuire. In May 2021, Mr. McGuire formed McGuire Holding Company, LLC to hold title to the real estate he purchased in Bethany, Oklahoma, where McGuire Advisors currently maintains its principal office. Mr. McGuire would be eligible to any earnings that the holding company would earn from McGuire Advisors and any other third parties renting space in the office building. In October 2007, Michael W. McGuire formed Sooner Cash Advance, LLC, a firm that holds real estate investments. He continues to provide services as a co-member of that entity and would earn a share of distributions from it. His services do not involve securities investments or investment advice. In April 2024, Michael W. McGuire formed McGuire Tax Advisors, LLC, a tax advisory and tax preparation business. He is a co-owner and spends less than 5% of his time on this activity. Scott McPherson has been licensed to sell Life Insurance as an Insurance Producer in the state of Oklahoma since 2021. He is currently authorized to sell Accident & Health or Sickness insurance; and Life insurance policies. Scott McPherson is entitled to receive ongoing commissions for the insurance policies he sells to Clients, which could create a conflict of interest. He only offers insurance policies to Clients for 17  whom he believes the insurance would be in the Clients’ best interest. Clients are not obligated to purchase insurance from Scott McPherson. Scott McPherson is involved in his CPA consulting and tax services business unrelated to his investment advisory services for McGuire Capital (see Item 2.B, above). He estimates that he currently spends less than one hour per day during market trading hours on his consulting and tax business. Mr. McPherson believes that his consulting and tax service business does not currently create a material conflict on the time he can spend advising Clients through McGuire Capital. In April 2024, Scott McPherson formed McGuire Tax Advisors, LLC, a tax advisory and tax preparation business. He is a co-owner/business manager and spends Approximately 10% of his time on this activity. These practices represent conflicts of interest because it gives an incentive to recommend products or services based on the commission or fee amount received. These conflicts are mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products or services. Clients have the option to purchase these products or services through another insurance agent or co-owner/business manager of their choosing. D. Recommendation of Investment Advisers McGuire Capital utilizes the services of Third Party Money Managers to manage client accounts. In such circumstances, McGuire Capital receives Co-Advisor fees from the Third Party Manager. This situation creates a conflict of interest. However, when referring clients to a Third Party Money Manager, the client’s best interest will be the main determining factor of McGuire Capital. These fees do not include brokerage fees that may be assessed by the custodian. Fees for these services are based on a percentage of Assets Under Management not to exceed any limit imposed by any regulatory agency. The final fee schedule is disclosed in the Client agreement. This Co-Advisor relationship is disclosed to the client in each contract between McGuire Capital and Third Party Money Manager. McGuire Capital does not charge additional management fees for Third Party Managed Account Services. Client's signature is required to confirm consent for services within Third Party Investment Agreement. Client initials McGuire Capital 's Investment Advisory Agreement to acknowledge receipt of Third Party Fee Schedule and required documents including Form ADV Part 2 disclosures. Item 11 - Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. Code of Ethics McGuire Capital has adopted a Code of Ethics that governs the activities of its Associated Persons. The Code is intended to prevent insider trading and to avoid conflicts with the interests of the Firm’s Clients. Under the Code, McGuire Capital prohibits all Associated Persons from having any personal interest in a securities transaction if the transaction would cause a conflict or if the transaction appears to be based on inside information. The Code requires that all personal transactions by Associated Persons be reviewed to assure that Associated Persons are not trading in conflict with Client transactions. McGuire Capital will prohibit, or restrict trading by Associated Persons in securities that would involve conflicts of interest or that would be based on inside information. Any interested person may obtain a copy of the Firm’s Code of Ethics by contacting the President of the Firm at the address listed on the cover of this Brochure. 18  B. Conflicts in Securities Holdings McGuire Capital does not recommend, buy or sell for Clients any securities in which McGuire Capital or any related person has a material financial interest, except that McGuire Capital or a related person may invest in the same securities as Clients. See Subsection C, below. C. Conflicts in Securities Investing Persons associated with McGuire Capital may buy or sell for their own account or their spouse’s account securities that have been recommended to Clients. Associated persons are not authorized to submit their personal transactions for execution until transactions for Clients have been completed. McGuire Capital keeps copies of all transactions by Associated Persons and reviews them periodically to assure that no Associated Person is trading in conflict with the interests of Clients. D. Conflicts in Contemporaneous Transactions The Code generally prohibits McGuire Capital or any Associated Persons from buying or selling a security at the same time as a Client. The Code also prohibits McGuire Capital or any related person from simultaneously buying a security while McGuire Capital recommends that a Client sell the same security or from simultaneously selling a security while McGuire Capital recommends that a Client purchase the same security. Item 12 - Brokerage Practices A. Recommending Broker-Dealers 1. Selection of Broker and Custodians. Clients are required to use broker-dealers and custodians selected by McGuire Capital for execution of transactions in the securities in the Clients’ accounts and holding Client assets. For management of most Clients, McGuire Capital uses Charles Schwab & Co. or a comparable firm to serve as custodian of Client assets and to serve as the broker-dealer to execute Client transactions. Clients are not able to designate an alternate broker-dealer or custodian. Each Client’s assets are held in Separate Accounts in the name of the Client at the custodian and are not commingled for any purpose with the assets of other unrelated Clients or of McGuire Capital. 2. Best Execution McGuire Capital seeks to select brokers that will provide the best service or best execution for each transaction. Regulators define best execution as the execution of a securities transaction in a way that, when all aspects are considered, provides the best value to the Client for the transaction under the circumstances. To evaluate best execution McGuire Capital takes into consideration the range and quality of the broker’s services, including: a. b. c. d. e. f. the broker’s access to different markets; the broker’s efficiency and timeliness of execution of transactions; the commission rates the broker charges; the financial responsibility of the broker; the broker’s ability to serve as custodian of Client assets; the broker’s ability to provide complete and timely valuation of Client assets; 19  g. h. i. the broker’s ability and willingness to provide custodial reports to Clients when requested by McGuire Capital; the value to McGuire Capital and its Clients of research provided by the broker (see Research and Other Soft Dollar Benefits, below); and the broker’s responsiveness to McGuire Capital and its Clients McGuire Capital reviews the above factors at least annually to confirm that the broker-dealer and custodian currently serving McGuire Capital Clients continue to provide best execution for Clients of McGuire Capital. 3. Research and Other Soft Dollar Benefits McGuire Capital does not accept any benefits from a broker if the broker provides the benefit for free only if McGuire Capital sends securities transactions that generate a designated minimum amount of commissions to the broker (a practice known as using soft dollars). Similarly, McGuire Capital does not accept any equipment, data or other items provided directly to McGuire Capital by a third party, which items are paid for by the broker or custodian of Client assets or the broker processing Client transactions, provided the investment adviser sends a specified minimum amount of commission and/or custodial business to the party paying for the service or benefit (a practice known as soft dollar arrangements). The broker-dealer and custodian that McGuire Capital uses, makes research and related information available without cost to all similarly situated investment advisers using their platforms, including McGuire Capital. 4. Brokerage for Client Referrals McGuire Capital does not take into consideration referrals from a broker or third party in recommending broker-dealers to Clients. McGuire Capital does not receive referrals from any party that would be related to the selection of that broker-dealer for execution of Client transactions. 5. Fund Management Costs Commissions charged for sales of mutual fund shares are not negotiable; however, in those situations where McGuire Capital recommends that a Client invest in a mutual fund, McGuire Capital seeks to recommend institutional shares or other no-load shares for Clients, if possible. B. Aggregation and Bunching of Orders McGuire Capital makes investment decisions independently for each Client based on that Client’s Investment Profile. McGuire Capital does not combine (bunch or aggregate) securities orders for one Client with orders for other Clients. Some advisers and brokers use bunching or aggregating securities transactions for multiple Clients to reduce commissions or provide more efficient execution. McGuire Capital is not aware if its designated broker dealer bunches or aggregates trades for different Clients. Item 13 - Review of Accounts A. Regular Review Representatives are required to review their Client accounts regularly and at least annually. The reviews must take into account factors such as market changes, economic changes, changes affecting the holdings 20  in the account or changes in the Client’s circumstances, goals, objectives or risk tolerance. The Representatives will communicate regularly with each Client to determine if any changes need to be made to the Client’s Investment Profile or if the Client has any questions or concerns. The Representative will communicate more often with Clients in the event of any unusual market activity that might affect the Client or at the request of a Client. Representatives are required to meet at least annually, in person or electronically, with their Clients to review the Investment Profile information, to confirm that there are no changes to the Client’s situation that would require adapting the management of the Client’s investments and to discuss any changes to the portfolio. B. Factors Triggering Extra Reviews Representatives are required to review Client Accounts immediately, if there are no significant changes in the economic environment, financial markets, or Client circumstances known to the Representative, or if McGuire Capital believes it to be in the best interests of Clients to require such a review. C. Reports to Clients The Custodian of Client accounts prepares account reports at least quarterly and provides the reports directly to Clients with copies to McGuire Capital . Reports include a list of all account holdings, changes in account value and details of all transactions during the preceding period. The reports also include information about the amount and the method of calculating advisory fees that the custodian deducts from the account (see Item 5.B). Item 14 - Client Referrals and Other Compensation A. Economic Benefits for Providing Advice McGuire Capital receives a portion of the annual management fees collected by the TPM(s) to whom McGuire Capital refers Clients. This situation creates a conflict of interest because McGuire Capital and/or its Investment Advisor Representative have an incentive to decide what TPMs to use because of the higher referral fees to be received by McGuire Capital. However, when referring Clients to a TPM, the Client’s best interest will be the main determining factor of McGuire Capital. McGuire Capital’s investment advisor representatives may receive certain benefits from Gradient Investments, LLC (and/or its affiliated companies) based on achieving certain production thresholds. These thresholds are not based on the sale of any specific product or specific product type. These incentives include marketing assistance, access to technology, office support, and business trainings and trips. While some of these benefit the client, such as technology and training, some do not. This creates a conflict of interest because it gives an incentive to the representative to meet this threshold. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first. Clients are not required to use Gradient Investments, LLC or any of its affiliated companies. B. Payment for Referrals Neither McGuire Capital nor any related person pays any third party to refer business to McGuire Capital. 21  Item 15 - Custody McGuire Capital does not maintain custody of Client assets. Clients are required to maintain their assets at the custodian selected by McGuire Capital. Item 16 - Investment Discretion McGuire Capital is granted discretionary authority to manage securities accounts for its Clients. McGuire Capital will not accept any Client, unless the Client has granted McGuire Capital discretion, in writing, under the terms of its Advisory Contract with each Client. Item 17 - Voting Client Securities McGuire Capital does not maintain custody of Client assets and therefore does not have the ability to vote proxies related to Client securities. All Clients receive proxies for their securities holdings and are able to vote proxies directly or through the custodian of their securities. Item 18 - Financial Information A. Prepayment of Fees McGuire Capital does not require payment of more than $1,200 in fees per Client, more than six months in advance; therefore, McGuire Capital is not required to provide financial statements. B. Financial Condition McGuire Capital is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to Clients. C. Bankruptcy McGuire Capital has not been subject to a bankruptcy petition at any time during the past ten years. 22