A. Firm Information MBE Wealth Management, LLC (“MBE Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). MBE Wealth is organized as a Limited Liability Company (“LLC”) under the laws of the State of Wisconsin. MBE Wealth was founded in November 2012 and became a registered investment advisor in July 2017. MBE Wealth is owned and operated by James Greenwood, Timothy Moy, Joseph Berry, Brent Brinker, Jacob Krueger and Michael Pruitt. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by MBE Wealth. B. Advisory Services Offered MBE Wealth offers investment advisory services to a wide variety of clients, including, but not limited to: individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, retirement plans and financial institutions (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. MBE Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. The Advisor provides financial planning and investment advisory services. Client engagements typically commence with an Advisory Person performing an analysis of the Client’s existing assets, investments, insurance, tax situation, investment objectives and overall financial situation. The details of these services are provided below. Financial Planning Services MBE Wealth will typically provide a variety of financial planning and consulting services to Clients, either as a component of investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, insurance needs, investment planning, retirement planning, and other areas of a Client’s financial situation. The scope of services is detailed in the financial planning or consulting agreement with each Client. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. MBE Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Page 5 Investment Management Services MBE Wealth provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. MBE Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. MBE Wealth will then construct a portfolio, consisting primarily of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, or government-issued securities to meet the needs of its Clients. For certain Clients, the Advisor may recommend investment in Class F-2 shares offered through American Funds Services (“AFS”), a low-cost mutual fund option, which do not include 12(b)-1 fees. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction based on portfolio fit and/or tax considerations. MBE Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. MBE Wealth will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. MBE Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. MBE Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. MBE Wealth may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. MBE Wealth may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the

Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will MBE Wealth accept or maintain custody of a Client’s funds or securities, except for limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the investment advisory agreement. Please see Item 12 – Brokerage Practices. Use of Independent Managers – When deemed to be in the Client’s best interest, MBE Wealth will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager’s Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Held Away Assets - Clients may engage MBE to advise on certain investment products that are not maintained at their primary Custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, MBE directs or recommends the allocation of Client assets among the various investment options available with the respective products. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor may recommend that a Client rollover its retirement plan account into an account managed by the Advisor. In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Page 6 Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by the Advisor. Retirement Plan Advisory Services MBE Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring and/or Review
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Ongoing Investment Recommendation and Assistance These services are provided by MBE Wealth serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA section 408(b)(2), the Plan Sponsor is provided with a written description of MBE Wealth’s ERISA fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Financial Institution Consulting Services MBE Wealth provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services, pursuant to a written agreement with MBE Wealth. Consulting services are strictly on products Clients have purchased through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details C. Client Account Management Prior to engaging MBE Wealth to provide investment advisory services, each Client is required to enter into one or more investment advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – MBE Wealth, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – MBE Wealth will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – MBE Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – MBE Wealth will provide investment management and ongoing oversight of the Client’s relationship’s investment portfolio. D. Wrap Fee Programs MBE Wealth includes securities transaction fees, custody fees, administrative fees, and other fees and expenses (herein “Covered Costs”) together with its investment advisory fees. Including these fees into a single asset- based fee is considered a “Wrap Fee Program.” The Advisor customizes its investment management services for its Clients. The Advisor sponsors the MBE Wealth Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. Page 7 E. Assets Under Management As of December 31, 2023, MBE Wealth manages $725,462,165 in Client Assets, $547,957,715 of which are managed on a discretionary basis and $177,504,450 of which are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.