Description of Services and Fees Millennium Capital Advisors, LLC (MCA) is a registered investment adviser based in Little Rock, Arkansas. We are organized as a limited liability company under the laws of the State of Arkansas. We have been providing investment advisory services since 1996. Capital Services Group, LLC (CSG) and Milrocket, Inc. (Milrocket) are the principal owners of MCA. Patrick D. Miller is President and sole owner of Milrocket, an Arkansas LLC that was formed to manage investments and holdings, including MCA and Millennium Insurance Services, LLC (MIS), a licensed insurance agency. For more information on CSG and MIS, please see Item 10 below, Other Financial Industry Activities and Affiliations. Currently, we offer the following investment advisory services, which are personalized to each individual client:
•Portfolio Management Services
•Advisory Consulting Services
•Pension Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our" and "us" refer to Millennium Capital Advisors, LLC (MCA) and the words "you," "your" and "client" refer to you as either a client or prospective client of our firm. In addition, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Portfolio Management Services We offer discretionary investment supervisory services (continuous account management on an individualized basis), whereby we monitor your accounts on a regular basis, and make recommendations for rebalancing your portfolio as changes in market conditions, and your circumstances may require. We develop a strategic asset allocation model, based on your needs, objectives and risk profile, to determine the various types of assets to include or exclude from your portfolio, and in what proportion those asset types should be held, based on your goals/objectives, risk tolerance and other constraints. On a limited basis, we also offer non-continuous asset allocation services, whereby we will periodically monitor and rebalance the account.
Subject to any written guidelines, which you may provide, we will be granted discretion and authority to manage the account. Accordingly, we are authorized to perform various functions, at your expense, without further approval from you. Such functions include making all investment decisions on the securities and the amount of securities to be purchased and/or sold. Once the portfolio is constructed, we provide ongoing supervision and re-balancing of the portfolio as changes in market conditions and your circumstances may require. In limited circumstances, we may enter into non-discretionary arrangements with you, where we will obtain your approval prior to the execution of a trade.
We do not hold ourselves out as a financial planner, but we may provide financial planning related services incidental to portfolio management services. We are not compensated separately for financial planning related services.
4 We will gladly meet with your legal and tax advisors to discuss your needs and to help develop investment recommendations. We will act as a project manager to coordinate the work of the appropriate parties in a manner consistent with your long-term desired outcome. As your financial situation, goals, objectives, or needs change, you must notify us promptly.
SEI Programs Some Clients may participate in certain programs administered by SEI Investments Management Corporation ("SIMC"). We offer these services through SEI Investments Management Corporation ("SIMC"), an independent investment adviser registered with the Securities Exchange Commission ("SEC"). These programs provide Clients with access to mutual funds that are otherwise available only to institutional Clients through a network of selected investment advisers.
In connection with Clients enrolled in SEI programs, we will supervise your accounts and otherwise provide management and/or monitoring services to you, including: (i) obtaining information from you about your particular financial situation and investment objections (including any reasonable investment restrictions you may wish to impose on the management of your account); (ii) contacting each Client at least annually to determine whether there have been any changes in your financial situation or investment objectives, or whether you wish to impose any reasonable restrictions on the management of the account or modify an existing restriction in any reasonable manner; and, (iii) notifying each Client in writing at least quarterly to contact us if there have been any changes in your financial situation or investment objectives, or if you wishes to impose or clarify an investment restriction.
The SEI Asset Allocation Program is offered to high net worth individuals, defined benefit plans, participant, and non-participant directed defined contribution plans, institutions, endowments, and foundations.
With the SEI Asset Allocation Program, we serve as the investment adviser to the Client, and are responsible for analyzing your current financial situation, return expectations, risk tolerance, time horizon, and asset class preference, pursuant to our investment advisory agreement. Based upon your information, we and/or you select an investment strategy and choose from one of many mutual fund asset allocation models, which may be provided by SEI Investments Management Corporation ("SIMC"), or us.
We will allocate the assets placed in your account among the SEI Funds (a family of mutual funds advised by SIMC) in accordance with the investment strategy or model selected by you. You may adjust your asset allocation through us to help ensure that the mix reflects the objectives of the chosen strategy. At any time, you may impose reasonable restrictions on the management of your account or choose a new investment strategy. For participant-directed plans, assets will be invested in the SEI Asset Allocation mutual funds and other style-specific SEI Funds (if applicable).
In accordance with your investment objectives, we may also allocate assets placed in your account among the SEI Funds through SEI's Private Client Models, which reflect SIMC's institutional asset allocation models more aligned with individual Clients' goals. SIMC expects to make changes to the Private Client Models periodically to incorporate changes to the mutual fund asset allocations underlying the models. Upon consent from us (on behalf of the Client), these asset allocation changes will be made to your accounts invested in the Private Client Models.
5 Fees Our annual fee for portfolio management services is billed quarterly in arrears based on the market value of account assets as of the last business day of the relevant calendar quarter. Fees will be assessed pro rata in the event the investment advisory agreement is executed at any time other than the first day of a calendar quarter. Additional deposits to the Client's account may also be billed on a prorated basis. If either party cancels the investment advisory agreement before the end of the calendar quarter, the management fee for such quarter will be prorated through date of termination. Our annual fee for portfolio management services is negotiable and will not exceed 1.5% of the market value of your assets under our management. The agreed upon annual management fee will be set forth clearly in the investment advisory agreement you sign with our firm. For those Clients that invest in the SEI asset models, SEI charges various administrative fees, which are clearly set forth in the SEI Investments Investor Application and Agreement. Additionally, SEI will assess management fees and other fund expenses associated

with the underlying investments in the given model. SEI Trust Company, a subsidiary of SEI Investments Co. acts as the transfer agent and custodian for your account. SEI Trust Company, on your behalf and will debit the advisory fee from your account quarterly. SEI does not participate in the advisory fee. The SEI Funds are administered, distributed, and in some cases advised by SIMC or its affiliates for which it is paid fees as disclosed in the SEI Funds' prospectuses. You should carefully read the prospectuses before investing in the SEI Funds.
At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee.
We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy.
You have the right to terminate the investment advisory agreement upon written notice and without penalty within five (5) business days after entering into the agreement. After the initial five-day period, the agreement shall continue in effect until terminated by either party for any reason upon 30 days' prior written notice to the other party. You will incur a pro rata charge for services rendered prior to the termination of the investment advisory agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a Client. Upon and after such notice, fees for services performed, but not billed, shall be due and immediately paid by you. Advisory Consulting Services We offer consulting services, which primarily involves advising you on specific financial-related topics. The topics we address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation. We charge an hourly fee for advisory consulting services of $300, which may be negotiable depending upon the scope of the engagement and the Client's individual circumstances. Our consulting fee is payable upon completion of the agreed upon consulting services.
6 Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries (the Client) based upon an analysis of the needs of the plan. In general, these services may include asset allocation advice, investment performance monitoring, ongoing consulting, and/or discretionary or non- discretionary asset management of the plan assets. The scope of these services, the fees, and the terms of the agreement for these services will be negotiated on a case-by-case basis with each Client. We may be compensated on a basis of the amount of the plan assets, an hourly fee, or a combination of fee arrangements based on the complexity of the plan and the agreement with the Client. In any case, we will not have access to Client funds for payment of fees without written consent by the Client. The terms regarding payment of fees, termination, and refund will be set forth in the agreement executed between our firm and the Client.
These accounts are regulated under the Employee Retirement Income Securities Act of 1974, as amended ("ERISA"). We will provide advisory services to the plan fiduciaries as described above. The named plan fiduciary must make the ultimate decision as to investments and services recommended by us and is free to seek independent advice about the appropriateness of any recommended investments or services for the plan.
We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy.
The Client may terminate the agreement for services within five business days of execution without penalty. Thereafter, the Client may terminate the pension consulting agreement upon 30 days written notice. The plan will incur a pro rata charge for bona fide pension consulting services rendered prior to such termination. If applicable, any pre-paid, unearned fees will be promptly refunded to the Client.
Typically, we require a minimum of $50,000 to open and maintain an advisory account. However, in our discretion, we may waive this requirement. Additionally, in its discretion, we may allow accounts of members of the same household to be aggregated for purposes of determining the advisory fee. For example, we may allow such aggregation where we service accounts on behalf of minor children of current Clients, individual and joint accounts for a spouse, and other types of related accounts. This consolidation practice is designed to allow Clients the benefit of an increased asset total, which could potentially cause the accounts to be assessed a reduced advisory fee.
Types of Investments We primarily offer advice on exchange traded funds, equity securities (stocks), corporate and government debt securities (bonds), mutual funds, certificates of deposit, and other market securities.
Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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 7 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2023, we manage $159,059,178 in client assets on a discretionary basis, and $21,546,011 in client assets on a non-discretionary basis.