Moisand Fitzgerald Tamayo, LLC (“MFT” or the “firm”) was founded in 1998 under a different name. The firm’s owners are Ronald Tamayo, Charles Fitzgerald III, Daniel Moisand, Derrick Chandler, and Michael Salmon, all Certified Financial Planner (CFP®) professionals. The firm is based in Orlando, Florida, with a second office in Melbourne, Florida and a third office in Tampa, FL. Our firm seeks to eliminate or mitigate rather than merely disclose, conflicts of interest facing people who receive financial advice. We are independent, we receive no commission income or income from third parties, and we do not create or distribute products of our own. We are held to the fiduciary standard of care and duty of loyalty under the Investment Advisers Act of 1940, as amended. As of December 31, 2023, MFT managed $1,028,555,365 in client assets on a discretionary basis. To help avoid or mitigate conflicts of interest, we have structured our firm around the following core philosophy:
• We are independent fiduciaries. We work for no one but our clients, and our legal obligations are to our clients’ interests first and foremost. We never take off our fiduciary “hats” to become product salespeople.
• We are objective. We receive no compensation based upon the sale or purchase of any particular products. All products are evaluated based solely upon their merits or lack thereof and not on any compensation incentives.
• We are disciplined. We evaluate financial products, investment opportunities, and strategies with a healthy dose of skepticism that has often helped our clients improve their prospects for success by avoiding overlooked risks and unnecessary costs.
• We are investors, not speculators. We manage our clients' investment portfolios, but we do not “play the market,” try to time the market, or otherwise gamble with our client’s money.
• We are proactive. We scour the economic, tax, and market environments to identify opportunities to shore up financial weaknesses without lessening strengths.
• We are realistic. We do not believe in following investment gurus. We consider the mainstream financial media as mostly a source of entertainment and not a meaningful aid to sound decision-making.
• We are well-qualified. Our team has eight CFP® professionals working for you, and the resumes of our principals are among the best you will see. Our minimum standards for education, business experience and professional licenses for our advisors are: Education: Bachelor’s degree Experience: Five (5) years investment or finance Licenses: Certified Financial Planner (CFP®) Practitioner Associations: Member of the Financial Planning Association (National and Central Florida) Form ADV Part 2 Brochure Page 5 of 57
• We are experienced. We have helped guide our clients through bubbles and busts, bull markets and bear markets, hype, and hysteria, and helped them make sound decisions regarding their retirement plans, taxes, education expenses, estate plans, trust management, risk management, stock options, health care needs and whatever else has arisen. In addition, MFT hereby affirms that we have voluntarily subscribed to the “Real Fiduciary™ Practices” published by The Institute for the Fiduciary Standard. Real Fiduciary ™ Practices offer a simple code of conduct and outline a commitment to clients of subscribing financial advisors. They seek to clearly articulate what a client can expect to receive from a subscribing financial advisor. These Real Fiduciary™ Practices do not replace our regulatory compliance obligations or duties to clients under relevant laws, rules, or regulations. The Institute for the Fiduciary Standard’s role is limited to publishing the practices as well as maintaining a corresponding register of subscribing financial advisors. You can verify our affirmation of Real Fiduciary™ Practices on our website or at the Institute for the Fiduciary Standard website at www.thefiduciaryinstitute.org. The practices can be found at https://thefiduciaryinstitute.org/wp- content/uploads/2019/03/Real-Fiduciary-Practices-2019-02-22.pdf Description of Services Provided Wealth Management Services MFT offers fee-only wealth management and advisory services for individuals, trusts, estates, and qualified retirement plans. We manage assets based upon written policies we establish in collaboration with clients. To develop an investment plan, MFT will rely on information supplied by the client pertaining to the client's financial situation, objectives, time horizon, and risk tolerance. This information becomes the basis for formulating a written Investment Policy Statement (“IPS”) and strategic asset allocation plan, which the advisor believes best meets the client’s long-term, stated goals. Clients may impose restrictions on investing in certain securities or types of securities through their IPS or in another written document. Once the IPS is developed, MFT will implement the plan and provide ongoing discretionary investment management and ongoing planning support in related financial areas. Each client account is managed independently and according to the IPS of the client. The firm offers wealth management and financial planning advice to many of its clients in five principal financial planning areas: (1) risk management, (2) investments, (3) taxes, (4) retirement, and (5) estate planning. Data gathering and discussions with the client guide the advisor in the investment process and the client in their overall wealth strategy and goals. Financial Planning and Financial Consulting Services When the firm accepts a planning-only engagement (no management of investments), either a fixed project fee or an hourly fee will apply. MFT will typically provide a variety of financial planning services, pursuant to a written agreement, to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of their current situation, goals, and objectives. Generally, such financial planning services will involve rendering a financial consultation that may include recommendations to improve any of the following five Form ADV Part 2 Brochure Page 6 of 57 principal financial planning areas: (1) risk management, (2) investments, (3) taxes, (4) retirement, and (5) estate planning and the interaction between these areas. The financial consultation will usually include general recommendations for a course of activity to be taken by the client. Consultations are typically completed within one (1) month of contract date and receipt of all information and documents requested, assuming clients make themselves available to receive such consultation. Our advice includes specific recommendations regarding long and short-term financial planning. Services are limited to an examination of only those areas described in the client agreement and only for the duration specified. Because each client's financial situation and goals change, clients may wish to have follow-up reviews and analyses performed by MFT after receiving our initial financial planning services. Such follow-up reviews are performed, and reports provided, as frequently as we mutually agree, subject to the terms and conditions of a written financial planning and consulting agreement. That agreement describes the scope of the services to be provided, and the terms of payment. We may recommend the services of other professionals such as attorneys or tax preparers. Clients are under no obligation to engage the services of any such recommended professionals, who are responsible for the quality and competency of the services they provide. Clients retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation made by MFT. Retirement Plan Services: MFT offers retirement plan consulting services to sponsors of self-directed retirement plans organized under the Employee Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement between MFT and the plan sponsor will be set forth in a written agreement. If MFT performs these services in an ERISA Section 3(21) capacity, it will assist the plan sponsor with the development of investment policy statements, and then the selection and monitoring of investment alternatives from which plan participants may choose in self-directing the investments for their individual plan retirement accounts. In this capacity, MFT may also assist with provider searches, benchmarking, asset allocation and other

fiduciary services Upon request by the plan sponsor, MFT may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. If the plan sponsor chooses to engage MFT in an ERISA Section 3(38) capacity, MFT may provide the same services as described above, but may also: create specific asset allocation models that MFT manages on a discretionary basis, which plan participants may choose in managing their individual retirement account; and/or modify the investment options made available to plan participants on a discretionary basis. Form ADV Part 2 Brochure Page 7 of 57 Tax Return Preparation and Planning As a convenience to its wealth management clients, MFT offers individual tax return preparation for a separate flat fee, which ranges based upon the complexity and scope of the engagement. There is no requirement that clients use MFT to prepare their returns. MFT is not a certified public accounting firm. MFT is happy to work with existing tax preparers or recommend tax preparers not affiliated with MFT. Time devoted to this activity represents a small portion of the firm’s time because only a few firm personnel, primarily Kevin McDermott, CPA, Ron Tamayo, and Mike Salmon, are involved and most of the work is accomplished during the tax season (primarily February 15 to April 15). Miscellaneous Retirement Plan Rollovers – No Obligation / Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If MFT recommends that a client roll over their retirement plan assets into an account to be managed by MFT, such a recommendation creates a conflict of interest if MFT 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 MFT. ERISA / IRC Fiduciary Acknowledgment: When MFT provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way MFT makes money creates some conflicts with client interests, MFT operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, MFT must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that MFT gives advice that is in the client’s best interest; charge no more than is reasonable for MFT’s services; and give the client basic information about conflicts of interest. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: MFT does not serve as a law firm or insurance agency and no portion of its services should be construed as legal or insurance implementation services. Accordingly, MFT and its representatives do not prepare estate planning documents or sell insurance products. Unless specifically agreed in writing, neither MFT nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with MFT, if desired. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from MFT and its representatives in that respect. MFT’s financial planning and consulting services are completed upon communicating its recommendations to the Form ADV Part 2 Brochure Page 8 of 57 client, upon delivery of the written financial plan, or upon termination of the applicable agreement. To the extent requested by a client, MFT may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). MFT may also offer to provide tax preparation services. Clients are under no obligation to engage the services of any recommended professional, including MFT, who are responsible for the quality and competency of the services they provide. Limitations of 401(k) Management: MFT will assist with the management of clients’ 401(k) accounts upon client request. When doing so, MFT is limited to making recommendations regarding the allocation of the assets among the investment alternatives available through the applicable plan. MFT will not receive any communications from the plan sponsor or custodian, and the client will remain exclusively obligated to notify MFT of any changes in investment alternatives, restrictions, and similar changes related to the 401(k) account. Insurance Consulting: In our work with clients, we never become salespeople of insurance or any other products. When more than fundamental insurance needs analysis is required, Mr. Fitzgerald and Mr. Lucas are Florida licensed fee-only insurance advisors (aka “unaffiliated insurance agent”) under Florida Statutes 626.015 (18). For Life, Health, and Annuity products, they are licensed to analyze or abstract insurance policies, provide insurance advice or counseling, or make specific recommendations or comparisons of insurance products for a fee established in advance with the client. By Florida law, they are prohibited from receiving any ‘third party’ compensation or commissions from an insurer, insurer-appointed insurance agent, or insurance agency. These services are provided at no additional cost to wealth management clients. Portfolio Trading Activity / Inactivity: As part of its investment advisory services, MFT will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when MFT determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Client Obligations: When performing its services, MFT is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify MFT if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending MFT’s services or previous recommendations, or if they are not receiving at least quarterly statements from their account custodian. Asset Aggregation / Reporting Services: MFT may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged MFT to manage (the “Excluded Assets”). MFT’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because MFT does not have trading authority for the Excluded Assets, the client (and/or another investment professional designated by the client), and not MFT, will be exclusively responsible for directly implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party Form ADV Part 2 Brochure Page 9 of 57 aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by MFT. Accordingly, MFT will not accept responsibility for adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without MFT’s participation or oversight.