A. Martel Wealth Advisors, Inc. (hereinafter the “Firm”) was approved as an SEC registered investment advisor on August 1, 2018. The Firm is based in Vancouver, WA. While SEC registration does not imply a certain level of skill or training, the Firm requires that advisors are Series 65 or 66 registered. Mark S. Martel, CFP® is the sole owner of the Firm. He has been in business since 1982. B, C. We offer the following investment advisory services, personalized to each individual client:
• Wealth Management Services
• Wealth Planning Services
• Pension Consulting Services Each investment advisory service is listed below and describes how we tailor our advisory services to your individual needs. Wealth Management Services The Firm provides clients with wealth management services which include a broad range of retirement planning and pension consulting services as well as discretionary management of investment portfolios. The Firm’s approved custodians are Charles Schwab & Co, Inc. and SEI Private Trust Company as well as Transamerica and Lincoln Financial Group for variable annuity contracts. As MWA does not actively sell annuity contracts, these contracts are grandfathered into MWA’s practice. The Firm primarily allocates client assets among various mutual funds and exchange-traded funds (ETFs) in accordance with client stated investment objectives and risk profile. Less frequently, the Firm will allocate assets among individual debt and equity securities. The Firm evaluates a new client's existing investments with respect to the client's investment objective and works with the client to develop a plan to transition from the client's existing portfolio to the client’s desired portfolio. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients may engage the Firm to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, the Firm directs or recommends the allocation of client assets among the various investment options available within the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. The Firm tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. The Firm consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify the Firm if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if the Firm determines, in its sole discretion, the conditions will not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. The Firm occasionally offers educational seminars for current and prospective clients that are informational in nature. These events are not selling events but a chance for clients to grow as investors and network with others. There is no charge for clients to attend and event topics are focused on investing and economic topics that are relevant to clients. Wealth Planning Services The Firm offers clients a broad range of wealth planning which may include:
• Business Planning
• Cash Flow Forecasting
• Charitable Giving
• Distribution Planning
• Financial Reporting
• Manager Due Diligence
• Retirement Planning
• Risk Management
• Tax Planning
• Trust and Estate Planning When performing these services, the Firm is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Clients retain absolute discretion over all decisions regarding implementation of recommendations and are under no obligation to act upon any of the recommendations made by the Firm under a wealth planning engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s recommendations and/or services. Pension Consulting Services The Firm provides investment advice about the structure, management, implementation and supervision of company sponsored retirement plans. The retirement plan itself is the client in this advisory relationship and not individual participants. The Firm gives advice to pension plans and their trustees with respect to (1) identifying investment objectives; (2) allocating plan assets to those objectives; (3) selecting money managers to mange plan assets to achieve objectives (4) select mutual funds that plan participants can choose for investment; (5) monitoring performance of money managers and mutual funds and make recommendations for changes; (6) selecting other service providers such as custodians and third party administrators (TPA). In providing services for pension consulting, the Firm does not provide any advisory services concerning the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITs), participant loans, non-publicly traded securities or

assets, other illiquid investments, or brokerage window programs (collectively, Excluded Assets). All pension consulting services shall follow the applicable state laws regulating pension consulting services. This applies to client accounts that are retirement or other employee benefit plans (Plan) governed by Employee Retirement Income Security Act (ERISA). If the client accounts are part of a Plan, and the Firm accepts appointment to provide services to such accounts, the Firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Fiduciary Services to Plan Fiduciary – Section 3(21) of ERISA The Firm offers ongoing investment and compliance consulting services, which include, but are not limited to, formalizing committee processes, reviewing and recommending investment managers, quarterly investment review reporting, annual review of plan costs/revenues and fiduciary education. The retirement plan sponsor retains and exercises the final decision-making authority for implementing or rejecting our recommendations with respect to investment selection and de-selection. We acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA with respect to the provision of services described in the Schedule of Plan Services with you. The Firm creates and delivers annual educational and enrollment meetings for plan participants under the terms of the Schedule of Plan Services. Discretionary Fiduciary Services – Section 3(38) of ERISA We accept discretionary fiduciary responsibility within the meaning of Section 3(38) of ERISA for the investment selection and monitoring process of investment options in a retirement plan (except for company stock) consistent with the investment objective designated by the Plan trustees. In such engagements, The Firm will serve as an investment fiduciary as that term is defined under ERISA and make the investment decisions in its sole discretion without the retirement plan sponsor’s prior approval. The Firm will generally provide services on an “assets under management” fee basis per the terms and conditions of the Schedule of Plan Services between the Plan and the Firm. Rollover Recommendations When the Firm provides advice about retirement plan accounts and individual retirement accounts (IRA) including whether to maintain investments and /or proceeds in retirement plan accounts, rollover such investments from the retirement plan account to an IRA or make a distribution from the retirement plan account, the Firm acknowledges that it is a fiduciary within the meaning of ERISA and/or the Internal Revenue Code (IRC) as applicable, which are laws governing retirement accounts. The Firm acts as a fiduciary to a retirement plan account or IRA under ERISA meaning:
• The Firm gives loyal advice to clients by putting client interests before Firm interests.
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that the Firm gives advice that is in the client’s best interest.
• Charge no more than is reasonable for the services of the Firm; and
• Give clients basic information about conflicts of interest. To the extent the Firm recommends a client rollover an account from a current retirement plan account to an IRA account managed by the Firm there is a conflict of interest. The Firm earns investment advisory fees by recommending that a client rollover their account at the retirement plan to an IRA managed by the Firm. The Firm will earn fewer investment advisory fees if the client does not rollover the funds in the retirement plan to an IRA managed by the Firm. Our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that a client open an IRA account to be managed by the Firm based on our economic incentive and not based exclusively on whether moving the IRA to our management program is in the client’s overall best interest. The Firm has taken steps to manage this conflict of interest by adopting an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding rollover of fund from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in the Firm receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by the Firm and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to clients regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of the Firm or our affiliated personnel. D. The Firm does not sponsor a wrap program nor is the Firm an investment adviser to a wrap program. E. As of December 31, 2022, the Firm has $745,861,785 in discretionary assets under management and $151,291,264 in non- discretionary assets under management for a total of $897,153,049 in assets under management.