Mtr Financial Services, LLC

Item 1 – Cover Page MTR Financial Services, LLC 900 Rockmead Drive, Suite 151 Kingwood, TX 77339 281.913.1844 www.mtrfinancial.com May 4, 2026 This Brochure provides information about the qualifications and business practices of MTR Financial Services, LLC [hereinafter “MTR”]. If you have any questions about the contents of this Brochure, please contact us at (281) 913-1844 and/or mrussell@mtrfinancial.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. MTR Financial Services, LLC is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about MTR Financial Services, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. i  Item 2 – Material Changes On July 28, 2010, the United State Securities and Exchange Commission published “Amendments to Form ADV” which amends the disclosure document that we provide to clients as required by SEC Rules. This Brochure dated January 1, 2011, is a new document prepared according to the SEC’s new requirements and rules. As such, this Document is materially different in structure and requires certain new information that our previous brochure did not require. The material changes in this brochure from the last annual updating amendment of MTR Financial Services, LLC on 01/07/2026 are described below. Material changes relate to MTR Financial Services, LLC’s policies, practices, or conflicts of interest. • MTR Financial Services, LLC has transitioned to registration with the United States Securities and Exchange Commission from its current state level registration. In the past we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a summary of any materials changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Matthew T. Russell, CFP®, President at (281) 913-1844 or mrussell@mtrfinancial.com. Our Brochure is also available on our web site www.mtrfinancial.com, also free of charge. Additional information about MTR Financial Services, LLC is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with MTR who are registered, or are required to be registered, as investment adviser representatives of MTR. ii  Item 3 -Table of Contents Item 1 – Cover Page .................................................................................................................................... i Item 2 – Material Changes ........................................................................................................................ ii Item 3 -Table of Contents .........................................................................................................................iii Item 4 – Advisory Services ....................................................................................................................... 1 Item 5 – Fees and Compensation ............................................................................................................. 3 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................... 4 Item 7 – Types of Clients ........................................................................................................................... 4 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................. 4 Item 9 – Disciplinary Information............................................................................................................ 4 Item 10 – Other Financial Industry Activities and Affiliations ........................................................... 5 Item 11 – Code of Ethics ............................................................................................................................ 5 Item 12 – Brokerage Practices ................................................................................................................... 5 Item 13 – Review of Accounts .................................................................................................................. 6 Item 14 – Client Referrals and Other Compensation ............................................................................. 6 Item 15 – Custody ...................................................................................................................................... 6 Item 16 – Investment Discretion .............................................................................................................. 6 Item 17 – Voting Client Securities ............................................................................................................ 7 Item 18 – Financial Information ............................................................................................................... 7 iii  Item 4 – Advisory Services MTR was established in January, 2009 as a fee-only financial planning and wealth management firm. Its principal owner is Matthew T. Russell, CFP®. INVESTMENT SUPERVISORY SERVICES MTR will offer ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Regular and/or continuous portfolio monitoring MTR will evaluate the current investments of each client with respect to their risk tolerance levels and time horizon. MTR will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels will be documented in the Investment Policy Statement, which will be given to each client. Fees for these services will be based on a percentage of Assets Under Management as follows: ASSETS UNDER MANAGEMENT ANNUAL FEE $1 - $500,000 1.25% $500,000 - $1,500,000 1.00% $1,500,000 - $2,500,000 0.85% Over $2,500,000 0.75% These fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Investment Advisory Contract. Fees are paid monthly in arrears, and clients may terminate their contracts with thirty days’ written notice. Because fees are charged in arrears, no refund policy is necessary. Clients may terminate their accounts without penalty, for full refund, within 5 business days of signing the advisory contract. IA will withdraw advisory fees directly from the client’s accounts with written authorization. There is no account minimum. 1  INVESTMENT ADVICE NOT INVOLVING SUPERVISION (FINANCIAL PLANNING SERVICES) Financial plans and financial planning may include, but are not limited to: life insurance; tax concerns; retirement planning; investment planning; college planning; and debt/credit planning. These services will be based on hourly fees and the final fee structure will be documented in Exhibit II of the Investment Advisory Contract. Depending upon the complexity of the situation and the needs of the client, the hourly fee for these services is $85 - $150. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Investment Advisory Contract. Fees are paid in arrears upon completion. Because fees are charged in arrears, no refund is necessary. Either party must provide 30 days written notice if they wish to terminate the Agreement. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. WRITTEN ACKNOWLEDGEMENT OF FIDUCIARY STATUS When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Management of client assets are offered on either a discretionary or non-discretionary basis. As of December 31, 2025, the amount of client assets managed for each were: Discretionary - $ 119,929,814.00 Non-Discretionary - $ 0.00 2  Item 5 – Fees and Compensation Fees for Investment Supervisory Services will be based on a percentage of Assets Under Management as follows: ASSETS UNDER MANAGEMENT ANNUAL FEE $1 - $500,000 1.25% $500,000 - $1,500,000 1.00% $1,500,000 - $2,500,000 0.85% Over $2,500,000 0.75% These fees are negotiable and the final fee schedule will be attached as Exhibit II of the Investment Advisory Contract. Fees are paid monthly in arrears, and clients may terminate their contracts with thirty days’ written notice. Because fees are charged in arrears, no refund policy is necessary. Clients may terminate their accounts without penalty, for full refund, within 5 business days of signing the advisory contract. IA will withdraw advisory fees directly from the client’s accounts with written authorization. There is no account minimum. INVESTMENT ADVICE NOT INVOLVING SUPERVISION Financial plans and financial planning may include, but are not limited to: life insurance; tax concerns; retirement planning; investment planning; college planning; and debt/credit planning. These services will be based on hourly fees and the final fee structure will be documented in Exhibit II of the Investment Advisory Contract. Depending upon the complexity of the situation and the needs of the client, the hourly fee for these services is $85 - $150. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Investment Advisory Contract. Fees are paid in arrears upon completion. Because fees are charged in arrears, no refund is necessary. Either party must provide 30 days written notice if they wish to terminate the Agreement. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. MTR’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees 3  and commissions are exclusive of and in addition to MTR’s fee, and MTR shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that MTR considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Item 6 – Performance-Based Fees and Side-By-Side Management MTR does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients MTR generally provides portfolio management services to individuals, trusts, estates, and/or charitable organizations. There are no account minimums nor are there any net worth minimums required to qualify as a potential client of MTR. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss The main source of information MTR uses for investment research and analysis include, but are not limited to, financial newspapers and magazines, research materials prepared by others, corporate rating services, company press releases, and mutual fund prospectuses. Investing in securities involves risk of loss that clients should be prepared to bear. The investment strategies used to implement any investment advice given to clients include long-term and short-term purchases. Other strategies that may be applicable to a client’s particular situation could include option writing. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of MTR or the integrity of MTR’s management. MTR has no information applicable to this Item. 4  Item 10 – Other Financial Industry Activities and Affiliations MTR has no outside financial industry activities or affiliations with any other financial institution or investment company. Item 11 – Code of Ethics MTR has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. ALL PROSPECTIVE AND CURRENT CLIENTS HAVE A RIGHT TO SEE OUR CODE OF ETHICS. FOR A COPY OF THE CODE OF ETHICS, PLEASE ASK YOUR FINANCIAL ADVISOR AT ANY TIME. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS From time to time, representatives of MTR may buy or sell securities for themselves that they also recommend to clients. MTR will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold. Item 12 – Brokerage Practices For those client accounts where MTR provides ongoing money management or investment advice with ongoing supervision, MTR will maintain limited power of attorney over client accounts with respect to securities to be bought and sold and amount of securities to be bought and sold. All buying and selling of securities will be explained to clients in detail before an advisory relationship has commenced. The Custodian, Charles Schwab & Co., Inc., was chosen based on their relatively low transaction fees. MTR will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian. Every attempt will be made to get group discounts on transactions when possible. 5  Item 13 – Review of Accounts The securities in every client's account will be under continuous review. Client accounts will typically be reviewed quarterly. Accounts will be reviewed by the President. Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations. Item 14 – Client Referrals and Other Compensation No additional income or economic benefit (including commissions, equipment, or non- research services) is received by MTR. Further no direct or indirect compensation is paid to any person for client referrals. Item 15 – Custody Clients should receive at least quarterly statements from the custodian that holds and maintains client’s investment assets, Charles Schwab & Co., Inc. MTR urges you to carefully review such statements. MTR does not provide separate account statements. As a result, the statements received from Charles Schwab & Co., Inc. should be viewed as your official account statement. Custody is also disclosed in Form ADV because MTR has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, MTR will follow the safeguards specified by the SEC rather than undergo an annual audit. Item 16 – Investment Discretion MTR usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought of sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, MTR observes the investment policies, limitations and restrictions of the clients for which it advises. For registered investment companies, MTR’s authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. 6  In addition to discretionary authority, MTR also gives their clients the ability to maintain a non-discretionary relationship as it pertains to an investment advisory relationship. In a non-discretionary relationship, MTR will provide investment recommendations to the client but will not execute any recommended trade, or client-directed trade, until written authorization has been received by the client. Investment guidelines and restrictions must be provided to MTR in writing. Item 17 – Voting Client Securities Clients may obtain a copy of MTR’s complete proxy voting policies and procedures upon request. Clients may also obtain information from MTR about how MTR voted any proxies on behalf of their account(s). Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about MTR’s financial condition. MTR neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. MTR has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of bankruptcy proceedings. 7