MFL is a Wyoming limited liability company that was formed in June 2015 for the purpose of providing discretionary and non-discretionary portfolio management and investment advisory services to individuals, high net-worth individuals, pension and profit-sharing plans ("Clients"). MFL is headquartered in Laramie, WY. Since May 24th, 2019, MFL has been registered with the SEC pursuant to the Advisers Act. Registration of an investment adviser does not imply any level of skill or training. MFL is solely owned by Shannon Markle.
Advisory Services MFL renders discretionary portfolio management, non-discretionary investment advisory and/or co- advisory services to a range of advisory Clients, principally high and non-high net worth individuals and sponsors of pension and profit- sharing plans. In most engagements MFL assumes responsibility for investing and re-investing the assets of each Client account in accordance with the investment objectives, policies and guidelines set forth in the Client's investment advisor contract with the Firm and other account documents. Services consist of directly managing Client portfolios, including but not limited to sourcing, selecting, and monitoring investments across a broad set of security asset classes including domestic and international equity, fixed income (corporate, state/municipal and/or U.S. Government and/or agency), real estate and alternative investments, either directly or by means of investing in such pooled investment products as mutual (open-end) or closed-end investment funds, exchange-traded funds, REITs, variable insurance products, privately offered hedge, private equity/debt, structured finance and other vehicles following alternative investment strategies. When MFL serves as investment adviser, it enters into a written investment advisor contract with each of its advisory Clients. Investment advisor contracts include provisions related to termination rights, proxy voting and sub-adviser arrangements, as applicable.
MFL tailors its investment advice to the specific needs of its Clients and works with Clients to formulate appropriate and agreed-upon investment objectives and guidelines. The Firm also follows any applicable investment restrictions as are set forth in Client investment advisor contracts and other account documents. Clients who restrict their investment portfolios may experience inferior performance results as compared with similarly situated portfolios held by Clients who have not imposed such restrictions. MFL reserves the right to decline or to terminate relationships with Clients that seek to impose restrictions which MFL finds difficult to abide by in striving to satisfy the overall investment objectives as initially approved by the Client.
To best facilitate a Client's exposure, as appropriate, to a range of investment strategies and/or asset classes, MFL may recommend that all or a portion of the Client's account assets be directed to one or more third-party investment advisers ("TPAs" or "advisers") for day-to-day active management, typically through SEI Private Trust ("SEI"). In some cases MFL will act in a co-advisory capacity. MFL will ensure that each TPA and their representatives are, properly registered or licensed and currently in good standing with the requisite federal (ordinarily, the SEC), state or territorial regulatory body having jurisdiction regarding the TPA's business activities. MFL also subjects each TPA to a detailed initial selection and ongoing due diligence monitoring process including, in the latter respect, periodic reviews of the performance of Client TPA investment accounts. Markle's authority varies depending upon the type of investment management services which the Firm is retained to render.

•Discretionary Portfolio Management Services. Generally, Markle accepts, but does not require, discretionary authority to manage securities accounts on behalf of its Clients. Except as otherwise set forth in the applicable Client investment advisor contract, our Clients authorize MFL to actively manage, on a discretionary basis, the funds, securities 5 and other assets held by one or more qualified custodians comprising their account assets with the Firm. MFL is authorized to execute purchases and sales of securities on Client's behalf without consulting Client regarding each sale or purchase. The Client may, however, terminate MFL's discretionary authority immediately upon issuance of written notice to us.
•Non-Discretionary Investment Management Services. In these types of Client arrangements, MFL is authorized to execute purchases and sales of securities only after securing the Client's approval regarding each transaction.
•Third-Party Adviser Arrangements. Accounts for which placements with TPAs are contemplated are required to provide Markle with discretionary authority. The Client approves, with informed consent, Markle's selection of the TPA(s), the platform sponsor and custodian(s) to be used as transaction execution (if any) and other account administration fees and expenses associated with the arrangement. Markle, as co- adviser, and the TPA are granted authority to determine, without obtaining specific Client consent, the securities and the amount thereof to be bought or sold in the account or portions of the account which are subject to the arrangement.
•MFL may recommend American Funds advisory platform for certain client investments based on client suitability.
•Cash Management. MFL has entered into an agreement with a third party provider to facilitate a FDIC insured cash management solution for their clients. This program has a $100,000 account minimum in order to participate. MFL will not charge an advisory fee for funds held in the cash management program, however MFL is compensated by the Cash Management program. Such compensation is disclosed within the account opening documents and is calculated as a fixed percentage of the interest earned in the client accounts.
• MFL has entered into investment advisory contracts with certain third-party investment advisory firms to act as day-to-day managers of all or a portion of the portfolios of MFL Client accounts. Clients may specify a third-party adviser for all or a portion of their assets. MFL will receive its standard fee in addition to the fee which the Client pays to the third-party adviser. This relationship will be memorialized in each contract between MFL and the third- party adviser. Currently, MFL may

direct Clients to the following third-party investment advisers for management of all or a portion of their portfolios: SEI Private Wealth Management (CRD# 105146), (CRD# 158667), and The Pacific Financial Group Inc. (CRD# 105203).
•ERISA 3(21) "Investment Manager Engagements. Our authority and responsibility in these engagements is limited to performing analysis and providing recommendations with regard to the mutual funds included as investment options in self-directed employee retirement plans sponsored by Client employers. In this capacity, we provide, as an ERISA fiduciary, retirement plan sponsors with recommendations and monitoring of funds included on plan investment "menus", assisting the Client plan sponsor with making and retaining responsibility for these investment-related decisions.
•Wrap Fee Programs. MFL causes certain Clients to participate in wrap fee programs as a result of the use of TPAs. Such wrap fee programs are sponsored by third-parties. 6 A "wrap fee program" is a securities investment program where an investor pays one stated fee in consideration of the investment management, transaction execution and other account administration services which he/she will be receiving as a participant in the program. MFL causes some of its Clients to participate wrap fee programs sponsored and advised by third-parties. For more information concerning a specific wrap fee program, please review the appropriate Disclosure Brochure (Form ADV Part 2) and the Wrap Fee Disclosure Brochure for a complete description of the service, fee schedules, and account minimums for their wrap fee programs.
•Financial Planning. MFL offers financial planning and consulting services to both prospective and existing Clients. MFL will obtain pertinent information about you and use the information as a basis for our recommendations, which may include, but are not limited to topics such as insurance, tax planning and cash flow needs, retirement, investments, education needs, and estate planning. Such financial planning recommendations may be implemented, at your sole discretion, with the professional consultants of your choosing (including your broker, accountant, attorney, etc.). MFL and the Client will review all pertinent data and discuss the analysis required under the financial planning engagement. Portfolio Management Services for Pooled Investment Vehicles Our firm currently provides investment advisory services to a private investment fund. Our affiliate serves as the manager of the private investment fund. We base our advice to such private investment Funds on the investment objective and restrictions (if any) set forth in the applicable offering memorandum, organizational documents, investment management agreement, and/or subscription agreements, as the case may be (each and collectively, the "Governing Documents"). Such Funds are available for investment only by sophisticated, high-net-worth investors, who meet the eligibility requirements of the applicable fund set forth in its Governing Documents. The fund is exempt from registration as an investment company under the U.S. Investment Company Act, as amended (the "Investment Company Act"), under Section 3(c)(1) or 3(c)(7) thereof. The detailed terms, strategies and risks applicable to the Funds are described in each Fund's organizational and offering documents regarding the investment of client funds based on the individual needs of the client. Details of the guidelines, parameters and restrictions on investments relating to the Fund clients may be found in the applicable Fund's Private Placement Memorandum. 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 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); 7
•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.
The Firm maintains publications, newsletters and videos on its website. Information posted on that site is for general public information purposes only and does not constitute professional investment or other financial services advice.
Regulatory Assets Under Management As of December 31, 2023, MFL managed approximately $97.3 million of advisory Clients' assets, $5.4 million of which was managed on a non-discretionary basis and $91.8 million of which was managed on a discretionary basis. The SEC has adopted a uniform method for advisers to calculate assets under management for regulatory purposes which it refers to as an adviser's "regulatory assets under management." Regulatory assets under management are generally an adviser's gross aggregate Client assets under management without deduction for outstanding indebtedness or other accrued but unpaid liabilities. MFL reports its regulatory assets under management in Item 5 of Part 1 of Form ADV which you can find at www.adviserinfo.sec.gov.