MCM WEALTH

PART 2A OF FORM ADV Marin Capital Management, LLC 7250 Redwood Blvd., Suite 300 Novato, CA 94945 Phone: (844) 626-4949 www.marincapitalmanagement.com www.mcmwealth.com 03/30/2026 Item 1: Firm Brochure (Form ADV Part 2A) This brochure provides information about the qualifications and business practices of Marin Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at (844) 626-4949 or geoff@mcmwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Marin Capital Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 Material Changes Pursuant to SEC rules, Marin Capital Management (“MCM”) will ensure that clients receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after the Firm’s fiscal year end, December 31. This means that if there were any material changes over the past year, clients will receive a summary of those changes no later than April 30. At that time, MCM will also offer a copy of its most current disclosure brochure and may also provide other ongoing disclosure information about material changes as necessary. If there are no material changes over the past year, no notices will be sent. Clients and prospective clients can always receive the most current disclosure brochure MCM at any time by contacting their investment advisor representative. Since our last update on 09/12/2025, the Firm has the following material changes to report. Item 4 & 5: We have added an options overlay service in Item 4 and added a new fee in Item 5 for this service. 2  Item 3 Table of Contents Item 1 Firm Brochure (Form ADV Part 2A) 1 Item 2 Material Changes 2 Item 3 Table of Contents 3 Item 4 Advisory Business 4 Item 5 Fees and Compensation 5 Item 6 Performance-Based Fees and Side-By-Side Management 6 Item 7 Types of Clients 7 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 7 Item 9 Disciplinary Information 9 Item 10 Other Financial Industry Activities and Affiliations 10 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 10 Item 12 Brokerage Practices 11 Item 13 Review of Accounts 13 Item 14 Client Referrals and Other Compensation 13 Item 15 Custody 13 Item 16 Investment Discretion 14 Item 17 Voting Client Securities 14 Item 18 Financial Information 15 3  Item 4 Advisory Business Firm Description Marin Capital Management, LLC, (“MCM”) an investment advisory firm based in Novato California, was established in 1997. The firm’s principal owners are Geoffrey A. Hakim (CFP®), and Robert Hoyt MCM applies investment research and portfolio-construction principles to our client’s investment and/or retirement accounts. More broadly, MCM expands its investment and service applications to include tax-efficient investing, insurance planning, estate planning of various types and complexities, other methods that tailor solutions to specific needs and objectives. MCM offers its services to individuals, trusts, small business retirement plans, other RIAs, family offices and institutions. MCM’s investment approach is a multi-asset class approach. MCM offers investment opportunities in mutual funds, exchange-traded funds, options, individual stocks and bonds, and real estate funds. The mutual funds, exchange-traded funds consist of stock, fixed income and, occasionally, alternative investments. MCM uses a core and satellite portfolio construction methodology in which the core emphasizes broad market exposure to stock and/or bond markets, primarily in the US, typically using ETFs or individual securities. Satellites typically emphasize specialized purposes to align with a client’s investment objectives including but not limited to higher growth, specialized sectors, socially- aware preferences, and emerging trends. Client portfolios are custom-tailored to the specific needs, risk tolerances and desires of each individual client. Accredited investor clients may use private investments to the degree they wish. MCM will also accommodates smaller investment portfolios with no alternative investments. MCM utilizes formal and informal methods for defining financial, tax, family, and other client objectives.. MCM fees include these services as well as periodic updates. Estate Planning MCM evaluates each client’s long-term planning in the form of existing and needed revocable and irrevocable trusts. This includes reviews of various long-term care preferences such as advanced directives and medical powers of attorney. MCM will use non-MCM experts, strategies, and tools on a discretionary basis upon the client’s written request. A client can either be referred to one of our approved estate planning providers or clients may hire MCM to play a “quarterback” role to ensure that miscommunications or misunderstandings are rectified and expedite the project. Such an arrangement would be for a separate fee with a separate agreement. Omni Overlay Strategy (Options-Based Overlay Program) 4  MCM offers an options-based overlay strategy (the “Omni Overlay”) designed to implement rules- based short call spread (“SCS”) and short put spread (“SPS”) strategies on client portfolios. The Omni Overlay is implemented using a proprietary rules-based technology platform (the “Platform”) Omni Portfolio Overlay, Inc. (“Omni”), a Delaware corporation solely owned by Kirk Loury, who also functions as MCM’s general manager for MCM’s division that serves clients at or below a certain asset level and/or with less complex planning needs. Omni is a technology provider and is not registered as an investment adviser. Omni does not provide investment advice, make recommendations, exercise discretion over client assets, or maintain any client relationship. All investment advisory services, including strategy selection, suitability determinations, and client oversight, are provided by MCM. All trading activity associated with the Omni Overlay is executed by a designated third-party trading desk, currently Mindset Asset Management, an SEC- registered investment adviser, which executes trades pursuant to parameters established by MCM. MCM retains ultimate responsibility for best execution and oversight of all trading activity. MCM will only implement The Omni Overlay strategy when it determines that the strategy is suitable and in the best interest of the client based on the client’s investment profile. MCM will show other risk management options as well whenever possible. Omni retains control over the design, functionality, and ongoing development of the Platform, including the ability to modify its operation, rules, and associated execution arrangements from time to time. Any modifications to the Platform made by Omni are reviewed by MCM for advisory impact, and MCM supervises all advisory decisions associated with the Omni Overlay. Wrap Fee Program versus Portfolio Management Program MCM does not offer a Wrap Fee Program. Assets Under Management As of December 31, 2025, MCM has the following assets under management: Discretionary assets: Non-discretionary assets: $ 109,388,812 $ 61,393,899 Item 5 Fees and Compensation Investment Advisor fees are billed in advance and deducted quarterly from the client’s brokerage account(s) based on the value of the assets in the account on the first business day of the new quarter as reported by the custodian or administrator. For those clients that either do not have brokerage accounts managed by MCM and/or prefer to pay through outside sources, this is permissible. For partial quarters, the fee will be prorated based upon the number of days the account was open during the billing period. For alternative investments with delayed capital 5  account values, MCM will bill using the most recent value that we have from the fund administrator at the time of billing. For clients with less than one million dollars in investible assets, MCM may charge an hourly fee of $500 an hour for financial planning. This time could be spent doing everything from meeting with clients, data entry, data analysis or research. The terms and conditions of the financial planning and engagement are set forth in the Advisory Agreement and MCM generally requires payment in advance. The Firm does not, however, solicit or require $1200 or more in prepaid fees in excess of six months in advance of services rendered. Reimbursements are provided to clients upon termination of these investments based on the amount of days (assuming a 30-day month) the investment was under management. The fee schedule for MCM’s clients starts at an annual fee of 1.1% and is reduced to .6% based on the amount of assets under management per client household. Breakpoints for fee reductions are specified in the Client Agreement. Fees are negotiable at the discretion of MCM and will generally only be negotiable in extraordinary or special circumstances. Certain legacy clients have been waived into a prior fee schedule that differs from the fee schedule described above; such clients should refer to their specific Investment Advisory Agreement for a complete description of the applicable fee schedule and fee-billing methodology. Investment managers also charge fees. Their fees vary, sometimes dramatically (typically .10% to 2%) and are recommended by MCM only when suitable for a client’s portfolio relative to their investment objectives. Portfolios are customized to suit the needs, preferences and suitability of each client. Portfolios are typically comprised of varied investment ideas from various sources. Mutual funds expense ratios vary greatly depending upon the strategy. Depending on the assets held within a client portfolio and the custodian of the IRA accounts, clients may pay custodian fees as well as transaction costs associated with the assets and activity in a given time period. In all instances, MCM will work to keep these costs to a minimum. Omni Overlay Fee Clients who elect to participate in the Omni Overlay pay an annual fee of up to 0.50% (i.e., 50 basis points) on assets to which the overlay is applied (“Overlay Fee”); there are no breakpoints based on asset levels The Overlay Fee is separate and in addition to MCM’s standard advisory fee and MCM does not charge our standard assets under management fee or any other fee on the assets to which the overlay is applied. A client at the minimum fee level of 1.10% that chooses to have the Omni Overlay applied to a portfolio as additive income, the client will be assessed a fee of 1.60% The Overlay Fee is allocated as follows: • Approximately 0.25% (25 basis points) is paid to the designated sub-adviser/trading desk (currently Mindset Asset Management); and • The remaining 0.25% (25 basis points) is retained by MCM. 6  Clients do not pay any fees directly to Omni Item 6 Performance-Based Fees and Side-By-Side Management MCM does not assess or accept any performance-based fees in addition to its standard management or advisory fee. However, certain investments that MCM may direct clients to (e.g., hedge funds) may assess a performance-based fee that is typically subject to a high-water mark (the highest value that has been earned by the fund to date). Item 7 Types of Clients The types of clients that the firm services are individuals, trusts, small-business pension plans and small, closely held corporations, other RIAs and family offices, pooled investment vehicles. The minimum account size that the firm will accept is $2,000,000; however, this minimum account requirement may be waived by MCM at its discretion. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss MCM primarily employs exchange traded funds (ETFs) individual stocks and bonds, and mutual funds. For certain clients, MCM may recommend private investment funds, closed-end funds, and/or business development companies. For these investments, MCM will offer these specialized satellite investment only after undertaking a supplementary planning analysis to assess suitability and application compared to more standardized investments. Since alternative strategies may involve frequent trading which can affect investment performance, particularly through increased brokerage (and related transaction costs) along with related taxation, we advise using funds of this sort within retirement accounts. MCM runs portfolios on a discretionary basis (see item 16 for a more detailed explanation of the MCM’s discretionary authority), which means that any adjustments made to the portfolio must typically have the prior approval of the client. Investment Risk Considerations Investing in securities involves risk of loss that clients should be prepared to bear. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of ETFs, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Risks Associated with Alternative Investments. Alternative investments typically include investments in direct participation program securities (partnerships, limited liability companies, 7  business development companies or real estate investment trusts), commodity pools, private equity, private debt, or hedge funds. Investors considering an investment strategy utilizing alternative investments should understand that alternative investments are generally considered speculative in nature and may involve a high degree of risk, particularly if concentrating investments in one or few alternative investments. These risks are potentially greater and substantially different than those associated with traditional equity or fixed income investments. Alternative investments do not trade on a national securities exchange, and as such may have limited liquidity due to the lack of secondary markets. This may impair the ability of the client to exit such investments in times of adversity. Alternative investments may also utilize highly speculative investment strategies, including leverage; the calculation of fair market value of alternatives can be difficult or delayed; and alternatives typically have fees that are higher compared to publicly traded securities. Most of these offerings are sold by prospectus or offering memorandum which contains more complete information including risks, costs and expenses. Investors should read these carefully before investing. Digital Assets: We may invest client accounts in virtual currencies, crypto-currencies, and digital coins and tokens (“Digital Assets”). The investment characteristics of Digital Assets generally differ from those of traditional currencies, commodities, or securities. Importantly, Digital Assets are not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Rather, Digital Assets are market-based: a Digital Asset’s value is determined by (and fluctuates often, according to) supply and demand factors and can be extremely volatile. These assets are speculative in nature, may experience sudden and significant price fluctuations, and are not covered by FDIC or SIPC insurance. In addition to market volatility, trading Digital Assets involves significant risks including limited regulatory oversight, cybersecurity threats, and operational failures at exchanges or trading platforms. Regulatory developments or government actions may also materially impact the value or legality of Digital Assets. Due to these risks, investors must have the financial capacity, investment experience, and willingness to bear the risk of total loss when considering exposure to Digital Assets. Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. We may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. For this reason, we include model-related results as part of our investment decision process but we often weigh professional judgment more heavily in making trades or asset allocations. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by MCM may be affected by the risk that currency devaluations affect Client purchasing power. 8  Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisers. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. Tax Risks. Tax laws and regulations applicable to an account with MCM may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of particular any account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve her investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. MCM and its representatives are not responsible to any account for losses unless caused by MCM breaching our fiduciary duty. Item 9 Disciplinary Information 9  Registered investment advisers are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the advisory business or integrity of the Firm’s management. Neither the Firm nor any advisers have been subject to any disciplinary action. Item 10 Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative MCM is not registered and does not have an application pending to register, as a broker dealer and its management persons are not registered as broker/dealer representative. B. Registration as a Futures Commission merchant, Commodity Pool Operator MCM and its management persons are not registered and do not have an application pending to register, as a futures commission merchant, commodity pool operator/advisor. C. Relationships Material to this Advisory Business and Possible Conflicts of Interest MCM is affiliated with Omni Portfolio Overlay, Inc. (“Omni”), a Delaware corporation that is owned and controlled by Kirk Loury as defined in Item #4 above. Omni is not registered as an investment adviser and does not provide investment advice, make recommendations, or exercise discretion over client assets. Omni’s role is limited to licensing its technology and maintaining the Platform. Omni does not receive any portion of the overlay fee attributable to MCM client accounts. While Omni does not receive compensation from MCM client accounts, MCM believes a conflict still exists as Mr. Loury due to his MCM role and responsibilities. MCM addresses this conflict by making recommendations against utilizing the Omni service when we believe the service would be unsuitable for the Client. D. Selection of other Advisors MCM does not receive, directly or indirectly, compensation from sub-advisers that it recommends or selects for its clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. MCM will disclose any material conflicts of interest to clients. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its clients. MCM and its representatives have a fiduciary duty to all clients. MCM and its 10  representatives’ fiduciary duty to clients is considered the core underlying principle for MCM’s Code of Ethics and represents the expected basis for all representatives’ dealings with clients. MCM has the responsibility to ensure that the interests of clients are placed ahead of it or its representatives’ own investment interest. All representatives will conduct business in an honest, ethical, and fair manner. All representatives will comply with all federal and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to services being conducted. All representatives have a responsibility to avoid circumstances that might negatively affect or appear to affect the representatives’ duty of complete loyalty to their clients. A copy of the Code of Ethics will be provided to any client or prospective client upon request. B. Personal Trading From time-to-time MCM’s investment advisor representatives may purchase or sell products or investments that they also recommend to clients. MCM has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the Firm. In addition, the Code of Ethics governs personal trading by each employee of MCM deemed to be an Access Person and is intended to ensure that securities transactions effected by Access Persons of MCM are conducted in a manner that avoids any actual or potential conflict of interest between such persons and clients of the Firm or its affiliates. MCM collects and maintains records of securities holdings and securities transactions effected by Access Persons. These records are reviewed to identify and resolve potential conflicts of interest. Item 12 Brokerage Practices A. Selection and Recommendation MCM has a duty to select brokers, dealers and other trading venues that provide best execution for clients. The duty of best execution requires an investment adviser to seek to execute securities transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances, taking into account all relevant factors. The lowest possible commission, while very important, is not the only consideration. MCM uses a Qualified Custodian for custody and trading of listed securities. For the custody of alternative investments (largely, but not exclusively required for retirement accounts only), MCM will use a qualified custodian. . It is the policy of the Firm to seek best execution in all portfolio trading activities for all investment disciplines and products, regardless of whether commissions are charged. This applies to trading in any instrument, security, or contract including equities, bonds, and forward or derivative contracts. MCM evaluates the execution, performance, and risk profile of the broker-dealers it uses at least annually. The broker dealer that MCM currently utilizes is Fidelity Brokerage Services LLC (“Fidelity”). 11  B. Research and Other Soft Dollar Benefits Soft dollar practices are arrangements whereby an investment adviser directs transactions to a broker‐dealer in exchange for certain products and services that are allowable under SEC rules. Client commissions may be used to pay for brokerage and research services and products as long as they are eligible under Section 28(e) of the Exchange Act of 1934. Section 28(e) sets forth a “safe harbor,” which provides that an investment adviser that has discretion over a client account is not in breach of its fiduciary duty when paying more than the lowest commission rate available if the adviser determines in good faith that the rate paid is commensurate with the value of brokerage and research services provided by the broker‐dealer. MCM does not receive soft-dollar benefits from any custodial arrangement listed above. MCM also receives no trading commissions for any transaction. C. Brokerage for Client Referrals MCM does not receive client referrals from third parties for recommending the use of specific broker-dealer brokerage services. D. Directed Brokerage Securities transactions are executed by brokers selected by MCM in its discretion and without the consent of clients. MCM will generally recommend clients to direct the Firm to execute transactions through a specified broker-dealer. Not all investment advisers require their clients to direct brokerage. E. Order Aggregation MCM may, at times, aggregate sale and purchase orders of securities (“block trading”) for advisory accounts with similar orders in order to obtain the best pricing averages and minimize trading costs. This practice is reasonably likely to result in administrative convenience or an overall economic benefit to the client. Clients also benefit relatively from better purchase or sale execution prices, or beneficial timing of transactions or a combination of these and other factors. Aggregate orders will be allocated to client accounts in a systematic, non-preferential manner. MCM may aggregate or “bunch” transactions for a client’s account with those of other clients in an effort to obtain the best execution under the circumstances. F. Trade Error Policy MCM maintains a record of any trading errors that occur in connection with investment activities of its clients. In the event a trading error does occur in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. 12  Item 13 Review of Accounts MCM will generally review Client portfolios (without Clients) on at least a semi-annual basis depending upon how frequently performance statements is generated by those investments held within Client's portfolio. Regarding portfolio reviews with Client, MCM (through either the Principal or Senior Advisor) may meet and review a Client portfolio several times within the first year of the relationship to become comfortable with MCM’s process depending upon Client availability and/or desire. Subsequently, MCM suggests that client meet at least annually, but typically on a quarterly basis, depending upon Client availability and/or desire. Reviews with Client are generally timed to coincide with the receipt of quarterly performance statements. Financial plans are reviewed and updated at client’s request or as significant financial changes or life events occur relative to each Client. Reviews are conducted directly by MCM. MCM sends performance statements to clients for their aggregate portfolio on a quarterly basis. Item 14 Client Referrals and Other Compensation MCM has a formal referral agreement with a tax professional: Michael Haas. The agreement is to share a portion of the fees received annually with the referring tax professional. The Accountant believes that certain clientele would benefit from receiving professional, fee-only investment advice and will therefore occasionally offer such services to clientele in need. The Accountant has chosen to outsource such services and has selected MCM to recommend to those of his clients needing investment advisory services. MCM and the Accountant will discuss the investment needs of the Client, and the Accountant shall provide ongoing advice to the Client relative to tax strategies and general oversight of Client portfolio and, therefore, the Accountant should be provided with the Client's portfolio results on an ongoing quarterly basis for review of performance, to calculate estimated tax payments and to render such other accountancy services as Client may request. MCM agrees to convene with Client as requested by Client or the Accountant to provide performance reviews of the Client's account. For services provided, MCM will share 15% of MCM's advisor fee with the Accountant, paid quarterly, based on the client’s previous quarter-end portfolio value. It is understood by the parties, that the Accountant will continue to perform his/her historic and regular accountancy services for Client and will directly bill Client for such services in his regular manner. 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. As paying agent for our firm, your independent custodian will directly debit your account for the payment of our advisory fees. The ability to deduct our advisory fees from your account causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds or securities. Publicly traded client assets will be custodied primarily with a 13  Qualified Custodian. For alternative investments, non-retirement accounts will be held at the custodian of the respective manager’s choice and retirement accounts will be held at Inspira Financial or Columbia Private Trust. Clients will receive statements from the Qualified Custodian on a quarterly basis. Statements from Inspira Financial Company will be sent on a quarterly basis. Clients are instructed to carefully review those statements. Clients are also instructed to compare their account statements sent by MCM to the statements they receive from the Fund Administrator(s) and the investment custodian(s). Item 16 Investment Discretion MCM has limited power of attorney over client brokerage accounts, meaning MCM is authorized to trade these accounts on behalf of the clients. However, MCM generally acts in a non- discretionary manner when trading securities in client accounts and will typically seek prior approval before trading client accounts. However, full discretion is granted to the Sub-Advisor(s) of MCM-recommended investment vehicles, of which the client has granted prior written consent to employ. Such Sub-Advisor(s) have authorization, without Client’s prior consultation or consent, to buy, sell, and trade in stocks, bonds, mutual funds, index funds, exchange-traded funds (ETFs), and other securities and/or contracts relating to same (“Securities”), provided, however, that (i) Securities may be acquired on margin only if a separate margin authorization has been granted; and (ii) Client’s grant of discretionary authority shall not apply to Alternative Investments as defined in the Client Agreement. MCM has discretionary authority to hire and fire Sub-Advisor(s) along with full power and authority to carry out investment decisions by giving instructions, on behalf of Client, to brokers and dealers and Custodian(s) of client accounts. MCM has authorization to provide a copy of the Client Agreement (i) to any broker or dealer, through which transactions will be implemented on behalf of Client, and (ii) to any Sub-Advisor selected by MCM, as evidence of MCM’s authority under the Agreement. In the event MCM recommends Private Funds to Client, such recommendations will be made on a non-discretionary basis. In the event the Client cannot be reached or in the case of an exogenous event that requires MCM to act quickly to protect the interests of the Client, MCM may act on a discretionary basis. MCM will also act on a discretionary basis when rebalancing client portfolios. MCM does not maintain full power of attorney to disburse funds on behalf of the Client(s), and any distribution or disbursement of funds must first be authorized by the Client. MCM does have the authority, embedded in the client agreement, that the advisor can raise cash by selling securities, without prior approval of the client, in order to have sufficient cash on hand to pay the advisor fee or address periodic distributions to the client. Item 17 Voting Client Securities 14  MCM does not and will not accept the authority to vote on client securities on behalf of the client. Item 18 Financial Information A. Balance Sheet Requirement MCM is not the qualified custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, six (6) months or more in advance. B. Financial Condition MCM does not have any financial impairment that would preclude the Firm from meeting contractual commitments to clients. C. Bankruptcy Petition MCM has not been the subject of a bankruptcy petition at any time during the last 10 years. 15