Overview

Headquarters
Tyler, TX
Total Firm Assets
$117 million
Average High-Net-Worth Client Portfolio Size
$3.4 million

Fee Disclosure

ADV PART 2A FIRM BROCHURE

MinMaxDisclosed Annual Rate
$0 $250,000 1.50%
$250,001 $500,000 1.25%
$500,001 $1,000,000 1.00%
$1,000,001 and above 0.75%
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
Portfolio ValueEstimated Annual FeeEffective Fee Rate
$1 million $11,875 1.19%
$5 million $41,875 0.84%
$10 million $79,375 0.79%
$50 million $379,375 0.76%
$100 million $754,375 0.75%

Clients

High-Net-Worth Share of Firm Assets
94.56%
Number of High-Net-Worth Clients
32
Total Client Accounts
49
Discretionary Accounts
48
Non-Discretionary Accounts
1

Services Offered

Services: Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
142783

Primary Brochure: ADV PART 2A FIRM BROCHURE (2026-09-03)

View Document Text
Murray Securities, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Murray Securities, Inc.. If you have any questions about the contents of this brochure, please contact us at (903) 561-5588 or by email at: frontdesk@murraysecurities.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 Murray Securities, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Murray Securities, Inc.’s CRD number is: 142783. 909 ESE Loop 323 Suite 200 Tyler, TX 75701 (903) 561-5588 frontdesk@murraysecurities.com http://www.murraysecuritiesinc.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 9/2/2026 i Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Murray Securities, Inc. on 12/5/2025, are described below. Material changes relate to Murray Securities, Inc.’s policies, practices or conflicts of interest. • Murray Securities, Inc. has transitioned to registration with the United States Securities and Exchange Commission from its current registration at the state level. • Murray Securities, Inc. has disclosed FINRA’s issuance of an Acceptance, Waiver & Consent (AWC) against Murray Securities, Inc. (Item 9) ii Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................5 Item 7: Types of Clients ..........................................................................................................................................6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................6 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 ...............11 Item 12: Brokerage Practices ................................................................................................................................12 Item 13: Review of Accounts ................................................................................................................................13 Item 14: Client Referrals and Other Compensation ..........................................................................................14 Item 15: Custody ....................................................................................................................................................14 Item 16: Investment Discretion ............................................................................................................................14 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................15 Item 18: Financial Information .............................................................................................................................15 iii Item 4: Advisory Business A. Description of the Advisory Firm Murray Securities, Inc. (hereinafter “MSI”) is a Corporation organized in the State of Texas. The firm was formed in October 2006, and the principal owner is Gary Von Murray. B. Types of Advisory Services Portfolio Management Services MSI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. MSI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring MSI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. MSI 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 are documented in the Investment Policy Statement, which is given to each client. MSI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of MSI’s economic, investment or other financial interests. To meet its fiduciary obligations, MSI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, MSI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is MSI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments MSI generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs and treasury inflation protected/inflation linked bonds. MSI may use other securities as well to help diversify a portfolio when applicable. 2 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. C. Client Tailored Services and Client Imposed Restrictions MSI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. MSI does not participate in wrap fee programs. E. Assets Under Management MSI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $98,795,111 $17,851,250 August 2026 3 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $250,000 1.50% $250,001 - $500,000 1.25% $500,001 - $1,000,000 1.00% $1,000,001 - AND UP 0.75% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of MSI's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by MSI. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees MSI collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client’s account. 4 For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients Gary Von Murray is a registered representative of a broker-dealer and in this role, accepts compensation for the sale of investment products to MSI clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset based sales charges or service fees from the sale of mutual funds to MSI's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receives compensation, MSI will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase MSI recommended products through other brokers or agents that are not affiliated with MSI. 3. Commissions are not MSI's primary source of compensation for advisory services Commissions are not MSI’s primary source of compensation for advisory services. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management MSI does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 5 Item 7: Types of Clients MSI generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals There is no account minimum for any of MSI’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis MSI’s methods of analysis include Fundamental analysis, Quantitative analysis and Technical analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies MSI uses long term trading, short term trading and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in 6 stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies MSI's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized MSI's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. 7 Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex 8 investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings On April 8, 2024, FINRA issued an Acceptance, Waiver & Consent (AWC) against Murray Securities, Inc. (CRD No. 142783). Without admitting or denying the findings, the firm consented to findings that it willfully violated Rule 15L-1(a)(1) of the Securities Exchange Act of 1934 (Regulation Best Interest) by failing to establish written policies and procedures, and a supervisory system, including Written Supervisory Procedures (WSPs), reasonably designed to achieve compliance with Reg BI. Specifically, the firm's written policies and procedures contained no provisions relating to Reg BI following its implementation date, and the subsequently 9 updated policies and procedures addressed Reg BI only in general terms, without addressing conflicts of interest obligations, care obligations, or specific supervisory review procedures. The firm also consented to findings that it violated Exchange Act Section 17(a)(1) and Exchange Act Rule 17a-14 by omitting required information from its Form CRS and failing to establish a supervisory system, including WSPs, reasonably designed to achieve compliance with its Form CRS obligations. The firm's WSPs contained no reference to Form CRS until more than a year after the Form CRS implementation date. As a result, the firm was censured, fined $35,000, and required to undertake remediation, including certifying in writing that it has reviewed and remediated the deficiencies in its Form CRS and has implemented a supervisory system and training reasonably designed to achieve compliance with both Regulation Best Interest and Form CRS requirements. The matter is final. The firm has satisfied the fine and is implementing the required supervisory system, WSPs, and training.. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative MSI is registered as a broker-dealer with the Financial Industry Regulatory Authority (FINRA) and the U.S. Securities and Exchange Commission (SEC). In addition to providing investment advisory services, MSI engages in broker-dealer activities, including the execution of securities transactions for clients and other broker-dealer functions. As a result of this dual registration, MSI and its associated persons may act in the capacity of both investment adviser and broker-dealer with respect to client accounts. When acting as a broker-dealer, MSI may receive commissions, markups, markdowns, or other transaction-based compensation in connection with the purchase or sale of securities for clients. This compensation is separate from, in addition to, advisory fees charged to clients. This dual registration creates a conflict of interest: MSI has a financial incentive to recommend securities transactions that generate broker-dealer compensation rather than recommendations that are solely in the client's best interest. MSI addresses this conflict through its best interest obligation under Regulation Best Interest (Reg BI) and its fiduciary duty in the advisory context, as well as through disclosure and supervisory procedures designed to ensure that recommendations are appropriate for each client. Clients are not required to execute transactions through MSI in its broker-dealer capacity. Clients who direct brokerage to MSI should be aware that this may result in higher transaction costs than if the client used an unaffiliated broker-dealer, and that MSI may not be able to obtain best execution in all cases. 10 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither MSI nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Gary Von Murray is a registered representative of Murray Securities, Inc. and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. MSI always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of MSI in such individual’s capacity as a registered representative. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections MSI does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics MSI 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. MSI's Code of Ethics is available free upon request to any client or prospective client. 11 B. Recommendations Involving Material Financial Interests If an agency cross transaction arises, MSI will only execute such transaction with the consent of the applicable client. An agency cross transaction is generally defined as a transaction where a person acts as investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of MSI may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of MSI to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. MSI will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of MSI may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of MSI to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, MSI will never engage in trading that operates to the client’s disadvantage if representatives of MSI buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on MSI’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and MSI may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in MSI's research efforts. MSI will never charge a 12 premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. MSI will require clients to use Hilltop Securities. 1. Research and Other Soft-Dollar Benefits MSI receives no research, product, or services other than execution from broker- dealers or custodians in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals MSI receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use MSI will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If MSI buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, MSI would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. MSI would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for MSI's advisory services provided on an ongoing basis are reviewed at least Quarterly by Gary Von Murray, Owner, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at MSI are assigned to this reviewer. 13 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of MSI's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) MSI does not receive any economic benefit, directly or indirectly from any third party for advice rendered to MSI's clients. B. Compensation to Non – Advisory Personnel for Client Referrals MSI does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, MSI will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion MSI provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, MSI generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. 14 Item 17: Voting Client Securities (Proxy Voting) MSI will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet MSI neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither MSI nor its management has any financial condition that is likely to reasonably impair MSI’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years MSI has not been the subject of a bankruptcy petition in the last ten years. 15

Frequently Asked Questions