MH & ASSOCIATES SECURITIES MANAGEMENT CORP

MH & Associates Securities Management Corporation 2888 Loker Avenue East, Suite 318 Carlsbad, CA 92010 23901 Calabasas Road, Suite 2005 Calabasas, CA 91302 www.mhinvestments.net May 31 2025 FORM ADV, PART 2A BROCHURE This brochure provides information about the qualifications and business practices of MH & Associates Securities Management Corporation. If you have any questions about the contents of this brochure, please feel free to contact us at (626) 440-9694 or lara@mhandassociates.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 MH & Associates is also available on the SEC’s website at www.adviserinfo.sec.gov. Our SEC CRD number is 110516. 1  Material Changes Annual Update MH & Associates is providing this information as part of our annual updating amendment which contains material changes from our last annual update. This section discusses only material changes since the last annual update which most recently occurred on May 31, 2024. Material Changes Since the Last Update The Securities and Exchange Commission adopted amendments to Part 2 of Form ADV effective October 2010. The newly revised Part 2 consists of Part 2A (the “Brochure”) and Part 2B (the “Brochure Supplement”). Each update of the Brochure must now include a summary of all material changes since the last annual update. • Item 8 – Methods of Analysis - We added a sentence to indicate that “Additionally, we may employ artificial intelligence tools to aid and enhance our own analysis.” Full Brochure Availability The full brochure for MH & Associates is available by contacting Lara Heilman at Lara@mhandassociates.com or by calling (626) 440-9694. 2  Table of Contents Item 1 - Cover Page………………………………………………………………………………………………………………………………………………..…………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……………………………………………….……………………………………………………………………………………6 Item 7 – Types of Clients…………………………………………………………………………………………………………………………………………………..6 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…………………………………………………………………………………………….9 Item 11 – Code of Ethics………………………………………………………………………………………………………………………………………………….10 Item 12 – Brokerage Practices…………………………………………………………………………………………………………………………………………13 Item 13 – Review of Accounts…………………………………………………………………………………………………………………………………………15 Item 14 – Client Referrals and Other Compensation……………………………………………………………………………………………………….15 Item 15 – Custody…………………………………………………………………………………………………………………………………………………………..16 Item 16 – Investment Discretion……………………………………………………………………………………………………………………………………..16 Item 17 – Voting Client Securities……………………………………………………………………………………………………………………………………17 Item 18 – Financial Information………………………………………………………………………………………………………………………………………17 Item 19 – Privacy Policy…………………………………………………………………………………………………………………………………………………..18 3  Advisory Business Firm Description MH & Associates (“the firm”) is a registered investments advisor with the Securities and Exchange Commission. The Firm was incorporated in June 1981. MH & Associates is an independent firm with no outside corporate ties or affiliations. Registration of an investment advisor does not imply any level of skill or training. Principal Owners John Z. Heilman, Daniel J. Meichelbock, Andrew Heilman, and Lara Heilman are the principal owners of MH & Associates. John Heilman is the President, Chief Financial Officer and Chief Investment Officer of the firm. Types of Advisory Services MH & Associates Securities Management Corporation primarily provides investment management services using a “balanced” investment style/approach. This balanced approach utilizes various investment vehicles including equities, fixed income securities and mutual funds. In its full discretionary relationships the firm provides the following investment management services: • Continuous asset allocation between equities, convertible securities, long term securities, short-term debt securities and cash equivalents. • Supervision and review of all securities held in client’s account. • Determination of which securities should be held, purchased and sold and execution of transactions. • Periodic reports and, as agreed to by client, meetings to explain and review investment policy and strategy and performance results. Tailored Relationships The firm also provides the same services, as described above, that are not fully discretionary. Due to different investment objectives, investment time horizon or risk tolerances of a client, the client can request that the account, within the framework of a balanced investment style, have different investment orientation, i.e. higher income orientation or higher equity exposure. Client Assets As of the time of producing this brochure (May 31, 2025), MH & Associates managed $151 million of client assets, all but $9 million on a fully discretionary basis. 4  Fees and Compensation Description MH & Associates is compensated for our advisory services by fees paid by our clients. The basic fees for discretionary investment management services are based on a percentage of market value of the assets as listed in the next section. Fee Schedule Account Size First $3,000,000 Next $3,000,000 Next $4,000,000 Over $10,000,000 Annual Rate 1.0% Per Annum 0.8% Per Annum 0.6% Per Annum 0.5% Per Annum The fee can, in some cases, be higher in taxable accounts depending on the tax planning and monitoring the firm does. Occasionally, the firm has reduced its fees to non-profit organizations and/or in competitive situations. Prior to 08/1/2008, the firm operated under a different fee structure. Fee Billing Fees are calculated at the end of each quarter and are based on the market value of assets on the last business day of each quarter. One fourth (1/4) of the annual fee is payable at the time of each computation. Upon client approval and dependent on the custodian having the technology, the firm will charge the client’s account directly for fees due on a quarterly basis. Under this direct charge method, the invoice(s) will be submitted to the custodian three business days after the firm’s statement and invoice are sent via mail. Contract termination procedures and conditions are that either party be given written notice of termination. In the eventof termination during a quarterly billing period, the amount of the final fee payable shall be prorated as of the date of termination. The client has the right to terminate the contract, without penalty or cost, within five (5) business days after entering the contract. Other Fees The firm utilizes, in certain circumstances, mutual funds and/or Exchange Traded Funds (ETFs) in its investment management services and the client will indirectly incur additional investment management fees and other expenses that are charged by the mutual fund and/or ETF. The circumstances in which mutual funds and/or ETFs are typically used are: (1) To achieve a broader diversification in a specialized industry or group (2) To achieve investment diversification in a specific country or region (3) Closed-end funds that are selling at a discount to its net asset value. In addition, the firm occasionally invests in foreign companies through American Depository Receipts (ADRs) and the client may incur administrative fees. Additional Compensation MH & Associates receives no compensation other than that of its primary business as laid out above. 5  Performance-Based Fees MH & Associates receives no performance-based fees. Types of Clients Description MH & Associates current clients include: • Individuals • High Net Worth Individuals Account Minimums Generally, the firm requires a minimum of $300,000 to establish an investment advisory account. In certain circumstances the firm will consider establishing an account with less than $300,000 due to expected additional cash flow or a pre- existing client relationship. 6  Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis MH & Associates investment philosophy is to search for fundamentally sound investments with potential for long term growth. The firm determines buy and sell recommendations individually based on the conditions of the issuer, industry sector, and market conditions. The firm relies on information from a wide range of sources, the Wall Street Journal, Barron’s, brokerage research reports, a company’s annual and quarterly reports and public information and information on sites such as Bloomberg. We may also speak with members of management teams of companies we wish to consider for investment. Additionally, we may employ artificial intelligence tools to aid and enhance our own analysis. Approach to Equity Investments: When determining the merits of an equity security, MH & Associates uses a variety of financial analysis techniques and quantitative methods to arrive at a given investment decision. Below is a list of common ways we may evaluate potential equity investments: •Balance sheet analysis •Income statement analysis •Cash flow analysis •Ratio analysis •Common size financial statements •Comparative relative multiple analysis •Dividend discount analysis •Technical analysis •Statistical analysis These techniques and methods can indicate important characteristics of the security including financial strength and flexibility, operational performance, earnings and growth potential, relative and intrinsic value, buy and sell points, volatility, correlation with other portfolio assets, and other recognized means of security evaluation. Furthermore, consideration of other variables such as technological innovation, new product or service launches, economies of scale, and changes in market power may play a significant role in the decision making process. Approach to Fixed Income Investments: MH & Associates uses fixed income securities to add stability and income to our client portfolios. When the firm evaluates fixed income securities it considers the broad economic environment, including factors such a current and expected future interest rates, GDP growth, and inflation expectations. Additionally, the attributes of a potential fixed income security such as credit quality, duration, payment structure and maturity are factored in the analysis to determine if the yield or total return is reasonable given the broad economic environment. Common fixed income securities that the firm may invest in are investment grade corporate bonds, high yield bonds, U.S. government securities, mortgage linked securities, foreign government securities, floating rate bonds, preferred and convertible preferred securities. 7  The firm typically uses discounted closed end mutual funds, open ended mutual funds, along with exchange traded funds when making fixed income investments due to liquidity and diversification concerns of holding individual names. However, the firm has and will select individual names when appropriate. We make investment decisions within the context of the overall domestic and/or global economy as well as the condition of the financial markets. Macroeconomic indicators, political events and geopolitical situations are closely monitored as these factors often can have dramatic effects on the economy and financial markets. However, the ultimate decision about an investment lies in the strength and merit of its unique characteristics, determining whether it is acquired for client portfolios and in what quantity it is maintained therein. When deciding to sell securities, the firm uses many of the same criteria discussed above. We often sell when, in our judgment the price of a given security has risen to meet our target, or exceeded our estimate of its fair value. We also may sell a security when either economic conditions underlying our original decision change, or changes in the security itself differ from our original assumptions. Investment Strategies MH & Associates Securities Management Corporation primarily provides investment management services using a “balanced/tactical” investment approach. This approach utilizes various equity and fixed income securities. The firm does not have any formal guidelines as to minimum or maximum commitment levels to either equities or fixed income securities. Commitments to these asset classes have historically varied widely. In its full discretionary relationships the firm provides the following investment management services: (a) continuous asset allocation between equities, convertible securities, long term securities, short-term debt securities and cash equivalents, (b) supervision and review of all securities held in client’s account, (c) determination of which securities should be help, purchased and sold and execution of transactions, (d) periodic reports, as agreed to by client, meetings with client to explain and review investment policy and strategy and performance results. The firm also provides the same services, as described above, that are not fully discretionary. Due to different investment objectives, investment time horizon or risk tolerances of a client, the client can request that the account, within the framework of a balanced investment style, have different investment orientation, i.e. higher income orientation or have greater exposure to growth investments. Additionally, on a selected “case-by-case” basis the firm will provide(s) investment management services using an investment style other than the balanced approach i.e. equity investment management. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. The firm controls risk of loss primarily through diversification within its balanced investment style. Decision & Review Process The portfolio and associate managers (here forth referred to as “the investment managers”) of the firm make all investment decisions jointly and conduct the investment reviews. The investment managers conduct informal meetings to exchange views, to analyze one another’s investment ideas, and agree upon transactions. The investment managers are aware at all times of the timing of client transactions. Investments are reviewed on a continuous basis. In the review process the account is assessed to insure that the “asset mix” is consistent with the current strategy as well as client objectives. 8  Investment Limitations MH & Associates has discretion to determine, without client consent, the type and quantity of securities to be purchased or sold for a client’s account. Limitations, is any, are typically conveyed, orally or written, by the client in the form of investment guidelines. Also, the firm, as an internal policy, has a limitation as to the maximum commitment to any one security (other than mutual Funds and U.S. government securities) of 5%, at cost, of the account value. Disciplinary Information MH & Associates and our management personnel are not currently, nor have they ever been a part to any legal or disciplinary action. Other Financial Industry Activities and Affiliations Broker-dealer or Registered Representative None of MH & Associates management persons are registered or have an application pending to register as a broker- dealer or a registered representative of a broker-dealer. Material Relationships or Arrangements with Financial Industry MH & Associates has no material relationships or arrangements with the financial industry. 9  Code of Ethics Introduction The Board of Directors of MH & Associates Securities Management Corporation has adopted this Code of Ethics to assist and guide its employees in the maintenance of the high standard of conduct in the performance of their duties. Purpose This purpose of this Code of Ethics is to promote: • honest and ethical conduct between the firm's employees and its professional relationships; • compliance with applicable governmental laws, rules and regulations; • the internal reporting of violations and the accountability for adherence to the Code of Ethics • compliance with the reporting requirements Covered Employees This Code of Ethics is designated for all permanent employees of the firm. All employees will agree to be bound by this Code of Ethics and shall annually acknowledge in writing the understanding of, and the intention to comply, with this Code of Ethics. Section 1: Ethical Conduct/Conflict of Interest Issues MH & Associates Securities Management Corporation endeavors to operate and conduct its business in a high ethical and professional manner. The employees are required to adhere to high moral standards and be honest and ethical in carrying out their duties and in dealings with the firms' clients and third parties. MH & Associates as a fiduciary has a duty of loyalty to its clients and places the best interests of its clients first and foremost. The employees are expected to avoid engaging in activities that conflict with the best interests of the firms' clients. The following will serve as a guide to the types of activities that might create a conflict of interest, but it is not exclusive: Personal Trading When MH & Associates personnel invest for their own accounts, the interests of clients will come first and the client will not be disadvantaged by the activities/trading by the firm's employees. Certain procedures and safeguards are in place, through the firm’s Compliance Policy relating to personal trading, to assure that the clients are not being disadvantaged by the trading of the firm’s employees. Except for "Exempted Transaction" as noted below, employees are required to obtain approval of personal security transactions to ensure there will be no conflict with currently planned client transactions. A form/log shall be kept detailing all approved personal transactions. The following types of investment transactions, by the firm's employees, are "exempted transactions" from the requirement to submit and obtain approval through the submission of a Pre-clearance form: • Direct obligations of the United States Government; • Open-ended investment company shares; • Short term debt instruments (i.e. commercial paper, certificates of deposit, repurchase agreements); and 10  • Automatic investment plans whereas purchase and sales of securities are made automatically in accordance with a predetermined schedule and allocation, such as dividend reinvestment plan. Significant Ownership The firm or its employees will not own a significant position (greater than 5% of the outstanding equity) in any public entity in which the firm invests for its clients. Gifts/Entertainment Employees shall not accept gifts, entertainment, special accommodations or other things, valued at more than $250.00, from any person or entity that does business with or on behalf of the firm. Further, employees many not give or offer any gift of more than $250.00 in value to existing clients, prospective clients, or any other entity that does business with or on behalf of the firm without prior approval by the chief compliance officer. Employees shall not give or accept cash or cash equivalents to or from a client, prospective client, or any entity that does business with or on behalf of the firm. In addition, the following additional activities are considered as prohibited activities and are to be avoided: Inside Information Employees shall not trade in any securities based upon knowledge or information that has not been reported publicly ("inside information"). IPO's and Private Placements Employees are required to obtain prior approval from the Compliance Officer before investing in an IPO's (Initial Public Offering) or Private Placements. Confidentiality The firm's relationships with its clients are confidential. Information concerning client's personal and financial circumstances shall not be revealed except as required by law or in the maintenance of the client's account. Directorship No employee shall serve as director of any publicly traded company without first obtaining approval of the Compliance Officer. Section 2: Compliance with Government Rules and Regulations Each employee is required to comply with all applicable laws, rules and regulations governing the conduct of the firm's business. Employees are to report any suspected violations to applicable laws, rules and regulations to the Compliance Officer or Co-compliance officer. Section 3: Accountability for Adherence to the Code of Ethics Known or suspected violations of this Code of Ethics must be immediately reported to the Compliance Officer or the Co- compliance Officer and shall be reviewed and investigated promptly. 11  Violations of this Code of Ethics may result in disciplinary action. The Compliance Officer shall determine, or shall designate appropriate person(s) to determine, suitable action in response to violations of this Code of Ethics. Disciplinary action shall be based on, among other things, the severity of the violation, whether it is a first or repeat offense, and whether it is a pattern of disregard for the letter and intent of this Code of Ethics. If there is a question about this Code of Ethics, guidance should be sought from the Compliance Officer. Every year, each employee shall receive and read the firms Code of Ethics and acknowledge as such by signing the following statement: I have received and read the Code of Ethics and I understand its contents. I agree to comply fully with the Code of Ethics and understand that I have an obligation to report any suspected violations of the Code of Ethics to the Compliance Officer or the Co-compliance Officer. Section 4: Reporting For purposes of this section the reports indicated below are to be submitted to the Chief Compliance Officer or the Co- Compliance Officer. Investment Holding Report Within 10 business days of becoming any employee of the firm, and annually thereafter, an investment holdings reports shall be submitted for review. The report shall show the name and type of security, ticker or CUSIP number, number of shares, market and or principal value, the name of financial institution in which investments are held, and the date the report is submitted for review. The information supplied must be current as of the date submitted and no more than 45 days before the initial or annual report is submitted. Monthly Transaction Report Within a timely, but no longer than 15 business days of month-end, all employees will submit, for review, a transaction report covering all transactions during the month. The report shall contain the name of the security transacted, date of transaction, ticker symbol or CUSIP number, interest rate and maturity date (in the case of bonds), number of shares or principal amount, nature of transaction, price in which security was transacted, the name of financial institution in which transaction was affected. It is noted that the official requirement is for quarterly reporting. However, the firm already has in-place a procedure whereas monthly transaction reports are submitted under its Policy & Procedure relative to Personal Transactions. Thus, this requirement is satisfied through that procedure. A full copy of our Code of Ethics can be obtained for any client or prospective client upon request. 12  Brokerage Practices Selecting Brokerage Firms The firm’s role in the selection of a broker-dealer used to effect security transactions varies. Due to commission savings that are offered, the firm suggests that client’s maintain or establish a custodial relationship with a discount brokerage firm. Most of the firm’s accounts have custody relationships with discount brokerage firms and all transactions for these accounts are placed with the client’s corresponding discount brokerage firm. Directed Brokerage MH & Associates does accept accounts whereby the client has directed the firm to place security transactions through a particular broker-dealer. Client Directed Broker-Dealer (Non-Consultant Relationship) Absent a preference by the client, and due to significant commission savings that are offered, the firm does suggest that clients establish a custodial relationship with a discount brokerage firm. Some research services are made available to the firm, but these are not the result of a soft dollar arrangement. Client Directed Broker-Dealer (Consultant Relationship) This refers to relationships where the broker-dealer acts as an intermediary between the client and the firm. While the firm has utilized these types of relationships in the past, at present, the firm does not have any relationships of this kind. Trading Practices MH & Associates policy is to prohibit unfair trading practices. In order to ensure that trading in clients’ accounts is fair and equitable, the firm has established certain procedures relative to trading securities for the clients account and in dealing with trading errors. Trading After discussing and deciding to make investments in our accounts, the appropriateness to the size of the position is examined in relation to the clients’ risk threshold. Based on this, the position is added (or changed if a current holding) to the model relating to those particular risk levels. A Directed Trade is then applied for the security to the model goal percentage. Our portfolio management system computes the trades necessary. A portfolio analyst will then review the trades before execution to ensure suitability, cash position, and cash flow expectations to ensure the appropriateness of the trade in question. Once completed the trade will be processed through the portfolio management system which will indicate which analyst processed the orders. The trades will then be executed at the Broker/Dealer. Following execution, trade information is received by the broker dealer and matched to orders processed in the system. Trade Allocation Allocating trades among clients shall be fair and equitable. In allocating trades, MH & Associates will not disproportionately favor certain client accounts over other client accounts. The firm will seek to allocate the full transactions equitably whenever concurrent decisions are made to purchase or sell securities of the accounts managed by the firm. 13  In the event the firm achieves a partial completion of its block trade the allocation shall be, in most cases, on a proportionate basis. In certain circumstances, a client might receive an allocation that is not proportionate. Factors that are considered which might lead to a disproportionate allocation are: Existing cash position and anticipated cash flow, possible excessive commission cost, investment objectives of the account, the relative size of the portfolio holdings of the same or comparable securities, and size of investment commitments generally held. Trade Aggregation In general, when client accounts are concentrated with one particular custodian or broker-dealer, the firm will aggregate the orders for its clients within that custodian or broker-dealer and will “block” trade to take advantage of certain administrative and cost benefits. In some cases, this procedure could have an adverse effect on the price and amounts of securities purchased or sold by clients domiciled in one particular custodian or broker-dealer over another depending upon the size and breadth of the market for each security. In order to be fair and not disfavor clients that are domiciled with a particular custodian or broker-dealer, the firm does have a policy of systematically rotating, between the various custodians and broker-dealers, the order in which block trading is initialized. Allocating cost in block trading shall be based upon average price. The firm does not aggregate orders on behalf of any other proprietary accounts of the firm, its employees and principals. Trade Errors The client shall not be disadvantaged due to any trading error. The client shall be reimbursed and shall be “made whole” in the event of a trading error. Any trading errors are to be reported to the Compliance Officer by the person executing the trade. A file shall be maintained documenting the correction of trading errors. 14  Review of Accounts Account Review Accounts are reviewed on a continuous basis. In the review process the account is assessed to ensure that it is being managed in a way that is consistent with the current strategy as well as client objectives. Account reviews are conducted by the investment managers of the firm and investment decisions are made jointly. The investment managers conduct informal meetings to exchange views, to analyze one another’s investment ideas, and agree upon transactions. The investment managers are aware at all times of the timing of client transactions Periodic Client Reviews The firm will obtain and maintain supporting client documentation in regard to the current financial status of the client. The investment managers will be responsible for initiating a discussion in this regard at least once during the calendar year, either in person, telephonically, or electronically. Any material outcome of these discussions shall be recorded on a memorandum to be stored in the correspondence file of each client. The goal of this policy is to ascertain whether the clients’ financial status or investment objectives have materially changed. Regular Reports Clients are provided with quarterly reports showing the holdings in their accounts, their performance for various periods (quarter, year-to-date, and since inception) and their quarterly management fee invoice. Also included in these reports is a newsletter discussing the firms economic and investment outlook. The custodian provides monthly holdings and transaction statements to the client. The firm confirms, no less than annually, that the client is receiving these statements from the custodian. Client Referrals and Other Compensation MH & Associates does not have any agreements in place where it is paid cash or receives economic benefit from a non- client in connection with giving advice to clients. 15  Custody The firm requires that all clients have a third party custodial relationship (i.e. bank or broker-dealer) to domicile the assets the firm manages. The firm has the authority to establish and maintain a broker-dealer or other financial institutional account once the client selects which broker-dealer or entity to utilize as a custodian. The firm is willing and prepared to deal with any type of custodial relationship. Safeguarding of Client Assets In order to ensure the safeguarding of client assets the firm has the following policies and procedures: 1) The firm will not take physical possession of clients’ cash or securities and will disclose as such in the firms Investment Management Agreement. 2) The firm requires the client domicile the assets in a “qualified” custodian to handle client funds and securities. 3) It is further noted that, in most “qualified” custodial relationships a limited power of attorney (LPOA) is utilized. The firms powers under a typical LPOA is limited to the following: a. Trading b. Requesting distributions/withdrawal of funds to client. c. Charging the client account for investment management fees only by client consent. 4) It is noted that the firm does, in many instances, have the ability to directly charge the clients account for its investment management charges. Before a fee is charged, the client will be provided with an invoice that will show the basis of the charge. The fee will be charged three (3) business days after the invoice is mailed. Investment Discretion MH & Associates has discretion to determine, without client consent, the type and quantity of securities to be purchased or sold for a client’s account. We assume authority over the account after the client has signed an Investment Management Agreement. Limitations, if any, are typically conveyed, orally or written, by the client in the form of investment guidelines. Examples of such limitations can include restrictions on certain securities. Also, the firm, as an internal policy, has a limitation as to the maximum commitment to any one security (other than mutual funds and U.S. Government securities) of 5%, at cost, of the account value. 16  Voting Client Securities Proxy Voting MH & Associates, as a matter of policy, disclaims proxy-voting authority with regard to client securities. That authority is to be retained by the client. Advising Clients In situations where no material conflict of interest exists, MH & Associates will provide, if requested by the client, advice concerning their proxy votes. MH & Associates will maintain a record of those clients that have requested assistance. The record will show the name of the client, date inquired, the nature of the question/advise sought by the client and the response/advise given the client by MH & Associates. Disclosure MH & Associates discloses to all potential new clients of the firms Proxy Voting policy via Form ADV Part 2 Brochure, which is included in the firms’ promotional packet. In addition, a statement relative to the firms Proxy voting policy will be included in the Investment Management Agreement. Class Action Litigation With respect to shareholder class action litigation, MH & Associates generally will assist/complete any filings in connection with any shareholder class action lawsuits involving securities currently or previously held in clients' accounts. Financial Information MH & Associates has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has never been the subject of a bankruptcy proceeding. 17  Privacy Notice At MH & Associates, information about you is fundamental to our ability to provide services to you, but we fully recognize the importance of keeping personal and account information secure. This document describes the privacy practices of MH & Associates and are required by law to deliver a Privacy Statement to our clients annually, in writing. We will also notify our clients of any material changes in our Privacy Policy. How We Obtain Information • From your applications or forms (examples: name, address, Social Security number, birth date, assets & income) • From transactional activity in your account (examples include trading history and balances) • Information we obtain from others at your request (such as information about assets held at another institution) • Information obtained when you contact us (via telephone, e-mail, etc…) How We Protect Your Information MH & Associates has always considered the protection of sensitive information to be a sound business practice and a foundation of client trust. Within MH & Associates, we restrict access to your information to those who require that access in order to provide services to you. These individuals are trained in the proper handling of client information. We do not disclose any nonpublic information about our clients or former clients to anyone, except as required by law or during the maintenance of your account (examples include disclosing information when opening brokerage accounts or transferring assets between accounts). We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We continually seek to enhance our security tools and processes. Such processes include, but are not limited to: • Using up to date anti-Virus, anti-Spyware, and anti-spam software on all computers used to access client data. • Using only trusted and secure computers to log into secure websites containing client data. Cybersecurity The firm recognizes that there are a multitude of risks involved in conducting business online. The firm strives to continue our “best efforts” to stay up to date with practices in regards to computer and mobile device security, client information security, client communications and policies around the movement of client funds. To date, the firm is unaware of any breaches involving the areas described above. In efforts to enhance our efforts to keep sensitive client information secure, the firm has elected to utilize the services of a dedicated company that will handle all aspects of cybersecurity. The services this company provides includes (but not limited to) the following: install and maintain anti-malware software o active monitoring of all MH computers and mobile devices o provide and maintain physical firewalls at each location o o monitor and keep MH up to date with the best practices in cybersecurity o maintain and monitor password and other heightened “dual authentication” systems Additionally, the company will assist MH & Associates in the event of a breach or another cyber security related event. 18