MA Private Wealth Advisors, LLC (“MAPW” or the “Firm”) is a limited liability company organized in the State of Delaware. MAPW is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). MAPW is majority owned by Martin S. Miller. The MAPW Wrap Fee Program (the “Program”) is an investment advisory program sponsored by MAPW. This Brochure describes the Program as it relates to clients receiving services through the Program. In addition to the Program, the Firm offers a variety of advisory services, which include financial planning and consulting services and investment management services under different arrangements then those described in this Brochure. Information about these services is contained in the Firm’s Form ADV Part 2A. A. Description of the Program MAPW provides investment management services as the sponsor and manager of the Program. The Program utilizes primarily individual equity securities, but may also utilize individual fixed income instruments, UITs and exchange traded funds (“ETFs”), in addition to the maintenance of cash postions for liquidity or other needs. MAPW is the sole portfolio manager in the Program. The Program is limited in its investment scope and may be utilized for only a portfion of a client’s investable assets. Clients of the Program often also receive the other more varied advisory services of the Firm as described in the Firm’s Form ADV Part 2A. Under the Program the client pays a single fee (“Program Fee”) for MAPW’s investment advice, custody and commissions for securities transactions executed through the Program custodian/broker-dealer, as described below. See Additional Fees and Expenses below for information regarding fees and expenses not included in the Program Fee. Prior to receiving services under the Program, clients are required to enter into a written agreement with MAPW setting forth the relevant terms and conditions of the advisory relationship. Clients must also open a new securities brokerage account and complete a new account agreement with Fidelity Brokerage Services LLC (“Fidelity”), or Charles Schwab & Co. (“Schwab”) which are “qualified custodians” as that term is described in Rule 206(4)-2 of the Advisers Act, or another brokerdealer that MA Private Wealth approves under the Program (collectively “Financial Institutions”). B. The Program Fee The Program Fee covers MAPW’s advisory services, custody and commissions for securities transactions effected through Fidelity. The number of transactions made in clients’ accounts, the size of the accounts, and the securities used to construct a portfolio, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Participants in the Program may pay a higher or lower aggregate fee than if the investment management and brokerage services are purchased separately. MAPW does not charge its clients higher advisory fees based on their trading activity, but clients should be aware that MAPW may have an incentive to limit its trading activities in client accounts because MAPW is charged for executed trades. In addition, MAPW personnel may have an incentive to recommend that MAPW clients utilize the Program rather than the other advisory services of MAPW due to the fact that the Program Fee is greater than the advisory only services fee as set forth in MAPW’s Form ADV Part 2A. MAPW addresses this conflict of interest by this disclosure and by its policies and procedures which work to ensure that client assets are placed in the appropriate advisory service offered by MAPW, or otherwise are placed in accordance with the specific instructions of the client. Cash Positions At any specific point in time, depending upon perceived or anticipated market conditions or events (there being no guarantee that such anticipated market conditions/events will occur), MAPW may maintain cash positions for defensive or other purposes. All cash positions (money markets, etc.) will be included as part of assets under management for purposes of calculating the Program Fee. Additional Fees and Expenses In addition to the Program Fee, clients will be responsible for transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees and any charges, taxes or other fees mandated by any federal, state or other applicable law,

retirement plan account fees (where applicable), electronic fund and wire fees. Furthermore, MAPW fees do not cover transaction fees or “trade away” fees imposed for trades placed away from Fidelity or Schwab. Fee Schedule MAPW charges an annual Program Fee that is agreed upon with each client and set forth in an agreement executed by MAPW and the client. The Program Fee is based on a percentage of the value of assets under management and the Program Fee for the initial quarter shall be paid, on a pro rata basis, in advance, based on the value of the net Program assets under management at the time the account becomes subject to the Program. For subsequent quarters, the Program Fee shall be paid, in advance, based on the asset value of the client’s Program account(s) as of the last business day of the preceding quarter as provided by third-party sources, such as pricing services, custodians, fund administrators, and client-provided sources. Following is MAPW’s asset based fee schedule for the Program Fee: PORTFOLIO VALUE BASE FEE Up to $250,000 1.50% $250,001 - $1,000,000 1.25% $1,000,001 - $2,500,000 1.00% $2,500,001 - $5,000,000 0.85% $5,000,001 - $10,000,000 0.80% $10,000,001 - $20,000,000 0.75% $20,000,001 - $30,000,000 0.70% $30,000,001 - $40,000,000 0.65% Above $40,000,000 Negotiable Notwithstanding the foregoing, MAPW and the client may choose to negotiate a Program Fee that varies from the schedule set forth above. Factors upon which a different Program Fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. In addition, some legacy clients may be grandfathered under the fee schedules as listed in their individual account agreements in effect at the time they became a client, which may result in fees higher or lower than those listed above. The Program Fee charged by the Firm will apply to all of the client’s assets in the Program, unless specifically excluded in the client agreement. Although MAPW believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. Payment of Fees MAPW generally deducts the program fee from a client’s investment account(s) held at his/her custodian. Upon engaging MAPW to manage such account(s) through Independent Mangers, a client grants MAPW this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or properly calculated. Although clients generally are required to have their investment advisory fees deducted from their accounts, in some cases, MAPW will directly bill a client for program fees if it determines that such billing arrangement is appropriate given the circumstances. MAPW does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. Fees for Financial Planning and Consulting Services MA Private Wealth generally charges a fixed ongoing fee for providing financial planning and consulting services under a stand-alone engagement. The fee charged for such services are negotiable and depend upon the complexity of a client’s plan and services provided. Clients receive invoices reflecting the amount of the fee due and payable. The terms and conditions of the financial planning and/or consulting engagement are set forth in the client agreement with MA Private Wealth. Fees are due semiannually and billed in arrears in June and December every year, regardless of when the agreement is signed and accepted. MAPW does not prorate or rebate financial planning fees. If during the course of the year, a new client enters into a new Financial Planning agreement, MAPW will not collected prorated fees, and will delay billing until the scheduled June or December billing cycle, whichever comes first. Further, if a client elects to terminate an agreement, there are no rebates given (as billing is in arrears). C. Compensation for Recommending the Program MAPW does not have any arrangements where it receives an economic benefit from a third party for recommending the Program.