The MaQro Advisors Wrap Program (the “Program”) is an investment advisory program sponsored by MaQro Advisors. Prior to MaQro Advisors rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with MaQro Advisors setting forth the relevant terms and conditions of the advisory relationship (the “Client Advisory Agreement”). MaQro Advisors filed for registration as an investment adviser in July 2017 and is owned by David Corrie, Robert Burleigh, and John Flack as of October 13, 2017. MaQro Advisors is registered as an investment adviser with the SEC under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). As of December 31, 2023, MaQro Advisors managed $165,007,942 with $3,919,028 on a discretionary basis and $161,088,914 on a non-discretionary basis. While this brochure generally describes the business of MaQro Advisors, certain sections also discuss the activities of its Supervised Persons, which refer to MaQro Advisors’ officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on MaQro Advisors’ behalf and is subject to MaQro Advisors’ supervision or control. Description of the Program The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account agreement with Interactive Brokers LLC (“IB”) or another broker-dealer that MaQro Advisors approves under the Program (collectively “Financial Institutions”). In order to participate in private offerings, clients generally open a new custodial account at Verabank. To participate in a private strategy with qualified money, clients generally open an account at Quest Trust Company. After an analysis of relevant information about the client, MaQro Advisors assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are generally managed on a discretionary or non-discretionary basis by MaQro Advisors’ investment adviser representatives. MaQro Advisors allocates clients’ assets among the various investment products available under the Program, as described further in Item 6 (below). Financial Planning and Consulting MaQro Advisors offers clients a broad range of financial planning and consulting services, which includes any or all of the following functions: Retirement Planning, Cash Flow Planning, Trust and Estate Planning, and Insurance Planning. These services are rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, MaQro Advisors 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. MaQro Advisors recommends certain clients engage MaQro Advisors for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for MaQro Advisors to recommend that clients engage MaQro Advisors or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by MaQro Advisors under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify MaQro Advisors of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising MaQro Advisors’ recommendations and/or services. Wealth Management Services MaQro Advisors provides clients with wealth management services which include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. MaQro Advisors primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, commodities, currencies, and alternative investments (including registered investment companies as well as privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds or private equity funds)). Where appropriate, MaQro Advisors also provides advice about legacy positions and/or other investments held in client portfolios which may be held away from the client’s primary custodian. Clients can engage MaQro Advisors to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, MaQro Advisors may direct or recommend the allocation of client assets among the various investment options available within the particular investment product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Recommendation of Affiliated Private Fund Principals of MaQro Advisors serve as the general partner of affiliated private investment funds including:
• MaQro Private Strategies Insurance Fund LP LLC
• MaQro 3.0 V(Go) GP LP
• MaQro 3.0 V(SI) GP LP
• MaQro Final Mile Pref-A Fund LP LLC
• MaQro Nex Gen 1st Payments Pref Equity GP LP (the “Funds”). Interests in the Funds are privately offered pursuant to Section 4(a)(2) of the Securities Act of 1933 or Regulation D under the Securities Act of 1933, as amended. Certain Funds currently rely on an exemption from registration under the Investment Company Act of 1940, as amended. Participation as an investor in the Fund is restricted to investors that are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended. The Funds invest substantially all their capital in one or more underlying funds employing various investment strategies. To the extent certain of MaQro’s individual advisory clients qualify, they will be eligible to participate as limited partners of the Funds. The Firm’s wealth management fee (described below in Item 5) will apply to any assets invested by clients in the Funds, but no other fees will be charged by MaQro or the General Partner to clients for management of such assets invested in the Fund. Investment in the Funds involves a significant degree of risk. All relevant information, terms and conditions relative to the Funds, suitability, risk factors, and potential conflicts of interest, are set forth in a Confidential Private Offering Memorandum (the “Memorandum”), Limited Partnership Agreement (the “Agreement”), and/or Subscription Agreement (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Funds. A conflict of interest exists as MaQro has an incentive to recommend an investment in the Funds to promote the success of the Funds. MaQro Advisors tailors its advisory services to meet the needs of individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. MaQro Advisors 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 MaQro Advisors if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if MaQro Advisors determines, in its sole discretion, that such conditions would not materially impact the performance of a management strategy or prove overly burdensome to MaQro Advisors’ management efforts. General Information Except as may otherwise be provided by law, we will not be liable to the client, heirs, or assignees for any loss an account may suffer by reason of an investment decision made or other action taken or omitted in good faith by MaQro with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from adherence to direction of the client or their attorney-in-fact may provide; any act or failure to act by a service provider maintaining an investment account. Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith and, therefore, nothing contained in this document shall constitute a waiver of any rights that you may have under federal and state securities laws. Fees for Participation in the Program MaQro Advisors offers services on a fee basis. MaQro Advisors charges a 1% annual asset-based fee. The annual asset-based fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by MaQro Advisors on the last day of the previous billing period. If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated on a pro rated basis, as described above. In the event a client’s advisory relationship with MaQro Advisors is terminated, the fee for the final billing period will be prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services MaQro Advisors provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), MaQro Advisors may negotiate a fee rate that differs from that set forth above. Fees for these assets will be billed either quarterly or annually in arrears and paid by direct invoicing via electronic payment processor. Fee Comparison As referenced above, a portion of the fees paid to MaQro Advisors are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction (or the asset-based brokerage fees charged by IB), determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Because the Firm pays for the brokerage fees, the Firm has an incentive to engage in fewer transactions, or transactions that cost less to the Firm, and choose Independent Managers whose fees fall outside of the Program Fee. Fee Discretion MaQro Advisors may, in its sole discretion, negotiate different fee structures with particular clients based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship status, account retention and/or pro bono activities. In certain circumstances, some clients and/or investors in private strategies and offering may receive a fee waiver at the discretion of MaQro Advisors. Some clients and/or investors in private strategies have successfully negotiated fee waivers. Other Charges In addition to the advisory fees paid to MaQro Advisors, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges include mark-ups or mark-downs attributable to fixed income transactions, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), certain expenses associated with alternative investments, margin and other borrowing costs, reporting charges, fees and commissions relating to assets not held with IB (such as 401(k) or 529 plan assets) or for trades executed away from IB, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees. Direct Fee Debit Clients generally provide MaQro Advisors with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to MaQro Advisors. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to MaQro Advisors’ right to terminate an account. Additions can be in cash or securities provided that MaQro Advisors reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to MaQro Advisors, subject to the usual and customary securities settlement procedures. However, MaQro Advisors designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. MaQro Advisors may consult with its clients about the options for and the implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Use of Margin Clients may also elect to authorize MaQro Advisors to use leverage in the management of the client’s investment portfolio. This may include the use of margin in the client’s brokerage account or assistance with securing non-purpose lending from financial institutions. Where MaQro Advisors uses leverage as part of its discretionary authority over an account, the advisory fee payable will be assessed net of leverage such that the market value of the client’s account and the corresponding advisory fee payable by the client to MaQro Advisors will not be increased solely as a result of such leverage. However, where MaQro Advisors makes a non-discretionary recommendation to purchase an investment that is not part of a discretionary portfolio managed by MaQro Advisors, the fee payable will be assessed gross of leverage such that the market value of the client’s account and the corresponding fee payable by the client to MaQro Advisors will be increased. Compensation for Recommending the Program MaQro Advisors has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation in the Program. A person recommending the Program will not earn more compensation than he or she would otherwise receive if a client elected a non-wrap relationship with MaQro Advisors.