GENERAL INFORMATION M Securities is an SEC Registered Investment Adviser (“RIA”) with its principal place of business located in Portland, Oregon. M Securities began conducting business as an investment advisory firm in 2000. We are a wholly owned subsidiary of M Financial Holdings Incorporated, doing business as M Financial Group. We provide services through a nationwide network of Investment Advisor Representatives (“Financial Professionals”) operating within independently operated businesses (“Member Firms”) associated with, and typically stockholders of, M Financial Group. Financial Professionals serve as the primary point of contact between M Securities and our Clients. Our Financial Professionals operate under their own Member Firm trade name and logo, which they use for marketing purposes. Clients should understand that even though Financial Professionals often operate under their own name or Member Firm name, when Financial Professionals offer or provide investment advisory services, including through our wrap fee Account programs, as discussed further below in this brochure, they are doing so through, and under the supervision of, M Securities. The Member Firm relationship is further disclosed in Item 9 of this brochure. M Securities is structured as an independent contractor financial services broker-dealer (“BD”) and RIA for Financial Professionals of Member Firms of M Financial Group. This structure allows our Financial Professionals to have the liberty to evaluate and recommend products and services that they believe will best help their Clients meet their financial goals and needs. Clients are also encouraged to carefully consider the differences between brokerage and advisory services including our obligations, your costs, and the need for the services provided. For additional information, please review the M Securities Form Client Relationship Summary (“Form CRS”), available at https://adviserinfo.sec.gov/firm/summary/43285, which provides information about the differences between brokerage accounts and advisory accounts. M Securities and our Financial Professionals serve as a fiduciary to Clients with respect to our adviser services, including our Wrap Programs, as defined under applicable laws and regulations. As fiduciaries, M Securities and our Financial Professionals uphold a duty of loyalty, fairness and good faith toward each Client and seek to disclose and mitigate conflicts of interest. OUR ROLE AS YOUR FIDUCIARY When providing advisory services, we require our Financial Professionals to act in your best interest. We are registered under the Investment Advisers Act of 1940 (“Advisers Act”), which places a fiduciary obligation on us in terms of the way that we provide services to you. As a fiduciary, we will work to ensure that your best interests come first. We endeavor to provide you full disclosure of all material facts relating to our advisory relationship with you. Our advisory programs are designed to avoid conflicts of interest. In situations where the appearance of, or potential for, such a conflict is unavoidable, we will clearly disclose the details of this to you. For most Clients, we provide ongoing advice and monitor your investments to ensure that they remain consistent with your objectives and risk tolerance. We will not engage in principal trading without your informed consent. We will always attempt to obtain the most favorable terms for any transaction that we make in your accounts. This practice is often referred to as “best execution” in the industry. We will supervise our Financial Professionals and other professionals to ensure that they are providing the services within appropriate guidelines, and we will monitor our employees to ensure that they meet prevailing ethical standards. In some cases those ethics standards may include disclosures beyond what is required by our regulator. When we provide investment advice to a retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of ERISA 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. For example, M Securities will Part 2A Appendix 1 of Form ADV 5 March 31, 2024 make more money when a Client increases their assets with us, including through rollovers from retirement plans or IRAs at other financial services companies into IRAs that we provide services to. If a Client decides to roll assets out of a retirement plan, and into an individual retirement account (“IRA”), we have a financial incentive to recommend that a Client invest those assets with us, because we, and the Financial Professional, will be paid fees on those assets through charging advisory fees on the assets. Clients should be aware that such fees likely will be higher than those paid through the plan, and there can be custodial and other maintenance fees. Securities held in other IRA accounts or at in a plan at different financial firms, may not be transferable to an IRA. In this situation, commissions and sales charges may be charged when liquidating such securities prior to the transfer, in addition to commissions and sales charges that may have been previously paid. The assets in your employer's retirement plan may by the largest sum of money you have ever accumulated. A recommendation to rollover plan assets to an IRA rather than keeping assets in a previous employer's plan or rolling over to a new employer's plan should reflect consideration of various factors, the importance of which will depend on your individual needs and circumstances. Depending upon your particular circumstance (and the terms of your plan), you may have the following options available with respect to the assets in your workplace retirement plan account: 1. Leave assets in your existing plan; 2. Move the plan assets to another plan, such as a new employer's plan; 3. Move your plan assets to an IRA held at a financial institution, such as M Securities or another financial firm; or, 4. Receive a taxable distribution from the plan (which may also be subject to penalties). You should have a discussion with your Financial Professional and review the services to be provided within the Agreement to ensure you understand and desire the services we are offering. Investment Advisory Services – Wrap Fee Account Programs M Securities is the Sponsor of the Wrap Fee Programs ("Program" or “Wrap Program”). There are six Programs available, each of which offer a money management style, specialty focus, or philosophy that are described further below in this brochure. A wrap fee program is a type of investment advisory program that provides Clients with asset management and brokerage services for one inclusive fee. Wrap fee programs are not the same as transaction-oriented brokerage accounts or investment advisory accounts in which separate fees and charges for investment advice and trade execution costs, including charges on a trade-by-trade basis, depending upon the advisory services. If Client chooses to participate in one of our Wrap Programs, Client will pay a single wrap fee (the “Program Fee”) that covers certain costs of the Program, including investment advice, platform fees, execution and clearing of transaction costs, and record-keeping services associated with the particular Program. The Program Fee will vary based on, but not limited to, the Program chosen, the amount of assets being managed, and the agreed upon rate negotiated with your Financial Professional. If there is little or no trading activity in the account, it is possible that a Client may pay more in advisory fees than in a non-Wrap Program. Your Financial Professional will help you understand whether a Wrap Program is appropriate for you. Certain other costs are not covered by the Program Fee and are described later in this brochure, as are schedules regarding the Program Fee associated with each Program. Please note that additional third-party assessed fees typically are charged in addition to the Program Fee – see ADDITIONAL FEES, CHARGES, AND OTHER CONSIDERATIONS, below. Prior to participating in one of our Programs, a Client will consult with his or her Financial Professional, who will obtain certain information from the Client including with respect to the Client’s assets and liabilities, investment objectives, earnings, financial needs, time horizon, risk tolerance, marginal federal and state tax rates, and any other pertinent information (together “Client Information”). Based upon the Client Information, the Financial Professional will make investment recommendations to the Client based on suitability of the Programs, and Client will select the desired Program or elect to participate in more than one Program. While we do not provide legal or tax advice, we use this information to help craft recommendations to benefit our Clients. In all of our Programs, prior to opening an Account, Client must Part 2A Appendix 1 of Form ADV 6 March 31, 2024 complete required documentation, which includes a Client Service Agreement (“Agreement”) and a Client Account Form (“CAF”). In addition, Clients will also be required to complete a risk questionnaire and statement of investment selection for participation in all of our Programs except the WealthPursuit™ Classic Program. The Agreement will detail the Program’s services, fees, and allow the Client to request reasonable restrictions on the management of Client’s Program Account (“Account”). Upon receipt of Client’s signature on all Program documentation, our Financial Professional will take appropriate actions to establish an Account. As described further below in this brochure, different Programs offer different approaches to managing a Client’s Account assets. For example, in the WealthPursuit™ Classic and Custom Programs, Client appoints his or her Financial Professional to serve as the discretionary Portfolio Manager for the management of Client’s Account, including investing Client’s Account assets. In the WealthPursuit™ Custom UMA, Custom SMA, Envoy, and Strategist Programs, the Client’s Financial Professional will select third party RIAs to serve as discretionary money manager or model strategist for the management of trading in Client’s Account. All of our Programs are managed on a discretionary basis, which means that the Client will authorize the applicable Portfolio Manager to manage the investment of Account assets on Client’s behalf without the need to seek prior consent from the Client. For all Programs, the Client directly owns the securities (e.g., mutual funds or exchange-traded funds (“ETFs”) purchased within each of the Program’s investment strategies for the Client’s Account). Mutual funds, ETFs, closed-end funds, unit investment trusts and real estate investment trusts and ETFs are collectively referred to throughout this document generally as “Funds." Clients are allowed access to their Account for the purpose of making withdrawals and deposits at any time. Client’s Financial Professional and/or Portfolio Manager, as applicable, will provide ongoing monitoring of the Account in an effort to manage the Account according to the Client’s investment objectives. Client’s Financial Professional relies on the Client to notify him or her of any changes in the Client’s investment objectives and/or Client Information. Changes to Client Information can prompt changes relative to the management of, and investment strategy for, the Account. On at least an annual basis, Financial Professional will review the Account with the Client to determine whether there have been any changes in Client Information and/or changes to restrictions the Client has requested to impose on the Account. Quarterly Performance reporting is offered and will be calculated according to industry standards and can be applied to each Account or combination of several related Accounts for a household’s or family’s assets. The Program Fee for all Programs is subject to negotiation between the Client and the Financial Professional, and is limited to a maximum of 3% of Account assets under management. See information below regarding Program Fee Information and Minimum Annual Platform Fees. M Securities has contracted with Envestnet Portfolio Solutions, Inc. (“Envestnet” or “Platform Provider”), an RIA and provider of wealth management software and services, to provide the operational and system support for the Programs. DESCRIPTION OF PROGRAMS WealthPursuitTM Classic In the WealthPursuit™ Classic Wrap Fee Program (“Classic”), Client appoints his or her Financial Professional to act as the Portfolio Manager to direct the investment of assets in the Client’s Account. The Financial Professional, as Portfolio Manager, will control all investment decisions, trading, rebalancing, and day-to-day operation and servicing of the Account. The Financial Professional, acting as Portfolio Manager, is responsible for performing careful review on each security purchased and ensuring that selected securities are suitable for the Account based upon the Client’s investment objectives, financial situation and any restrictions imposed by the Client. The Financial Professional, as Portfolio Manager, will invest Account assets among individual stocks, options, bonds, Funds, other securities and cash or money market funds. The minimum amount of assets required to establish a Program Account is $50,000. Part 2A Appendix 1 of Form ADV 7 March 31, 2024 WealthPursuitTM Custom Program The WealthPursuit™ Custom Wrap Fee Program (“Custom”) provides M Securities’ Clients with access to individual stocks, options, bonds, fixed-income products, Funds and other securities that are managed by the Client’s Financial Professional, as Portfolio Manager. In the Custom Program, the Client appoints their Financial Professional to act as the Portfolio Manager to direct the investment of assets in the Accounts(s). The Custom Program allows the Financial Professional to utilize Platform Provider investment model management services to assist the Financial Professional in managing and offering investment models for use with Client Accounts. The Financial Professional, acting as Portfolio Manager, is responsible for performing careful review on each security purchased and ensuring that selected securities are suitable for the Account based upon the Client’s investment objectives, financial situation and any restrictions imposed by the Client. The Financial Professional can recommend and trade on a wide array of investment products and securities, chosen directly by the Financial Professional. Model portfolios are constructed and rebalanced at the direction of the Financial Professional using a web-based interface provided and supported by the Platform Provider, who additionally provides overlay management services to implement changes to a Client’s Account at the direction of the Portfolio Manager. The minimum amount of assets required to establish a Custom Account is $50,000. WealthPursuitTM Custom UMA Program In the WealthPursuitTM Custom UMA Wrap Fee Program (“Custom UMA”) the Client’s Financial Professional constructs a single portfolio by selecting the specific, underlying investment vehicles and asset allocations. The UMA enables the Financial Professional to combine the investment expertise of third-party money managers, ETFs and mutual funds into a single portfolio for the Account. A wide variety of investments are available to money managers for managing their portion of the Account’s assets, including equities, bonds, exchange traded notes and Funds. The Financial Professional can also act as a Portfolio Manager for a portion of Account assets in this Program through use of “sleeve” portfolios. The Financial Professional can use individual stocks or bonds in addition to Funds in the management of the “sleeve” portfolio. The Financial Professional is responsible for ensuring that selected securities and investment strategies used by third-party money managers are suitable for the Account based upon the Client Information and any restrictions imposed by the Client. Portfolio trading services are provided by Platform Provider, additionally Clients can choose to add Additional Overlay Services offered. Currently, an overlay to screen for control of large unrealized tax gains that are embedded in portfolios, and an overlay to screen for investing within a Client’s personal values are offered. The minimum amount of assets required to establish a Custom UMA Account is $150,000; however, certain third-party money managers will establish their own minimums. WealthPursuitTM Custom SMA Program WealthPursuitTM Custom SMA Wrap Fee Program ("Custom SMA"), provides Clients access to multiple third-party money managers with different investment styles. The Financial Professional has the discretion to direct Client assets to the SMA with different money managers, who will act as Portfolio Manager and direct the investment of assets allocated to their respective management. Clients have direct ownership of the securities in the SMA, which can allow for greater flexibility, and more control as compared with investing in mutual funds and ETFs or other pooled investment vehicles. Financial Professionals can also direct Client assets into established model portfolios and receive consultation regarding money managers from Platform Provider consulting team. The minimum amount of assets required to establish a Custom SMA Account is $50,000; however, certain third-party money managers may establish higher minimums. WealthPursuitTM Envoy Program Part 2A Appendix 1 of Form ADV 8 March 31, 2024 WealthPursuitTM Envoy Wrap Fee Program ("Envoy") provides Clients with access to fully allocated, actively managed portfolios created by two selected money managers. Financial Professionals guide Clients in the selection of either the PMC Liquid Endowment Portfolios or the Blackrock/Envestnet Guided portfolios.
•The PMC Liquid Endowment Portfolios are a series of multi-manager accounts that, depending on the assets in the account, may include mutual funds, ETFs, independent money managers’ models, and separately managed accounts. Envestnet chooses the different asset allocations, investment strategies and Funds for each of the Liquid Endowment Models. The models managed for the smaller asset accounts may only consist of mutual funds and ETFs while models for larger asset accounts will generally include mutual funds, ETFs, independent money managers’ models, and separately managed accounts. The minimum account size for the PMC Liquid Endowment Portfolio is $35,000.

•Blackrock / Envestnet Guided portfolios combines the investment expertise of two asset managers into a single portfolio. This investment strategy delivers the benefit of traditional separately managed account in a single fully diversified portfolio. The minimum account size for the Blackrock / Envestnet Guided portfolio is $10,000.
Clients can choose to add Additional Overlay Services offered by Platform Provider. Currently, an Additional Overlay to screen for control of large unrealized tax gains that are imbedded in portfolios, and an Additional Overlay to screen for investing within a Client’s personal values are offered. WealthPursuitTM Strategist WealthPursuitTM Strategist (“Strategist”) provides access to asset allocation strategies of a variety of mutual fund and ETF third-party money managers. Each portfolio will consist of mutual funds or ETFs or a combination of both types of Funds to pursue different investment strategies and asset class exposures. Platform Provider makes these money managers available, provides the overlay management of the portfolios, performs administrative, and trade order placement duties pursuant to the direction of the asset manager. The money managers provide and construct the models and asset allocations and select the underlying investment for each portfolio. In this program, the Client and Financial Professional will select how to allocate assets between the money managers offered within the Program. The Platform Provider will replace money managers from time to time and cannot guarantee the continued availably of a particular model. The minimum amount of assets required to establish a Strategist Account is $25,000; however, certain models and third-party money managers are permitted to establish higher minimums. See Item 5, Account Requirements for additional information. PROGRAM SERVICES AND FEES Program Fee Information Clients pay a single annualized Program Fee for participation in a Program, and that fee will not exceed 3%. The Program Fee is a Wrap Account fee that is used to pay service providers, to include the Client’s Custodian for their respective services and certain transaction execution costs, Platform Provider, the Financial Professional, and other money manager(s) for their respective services, and indirectly the Retention Fee assessed by M Securities to Member Firms. Clients within a Program will pay the Program Fee as one quarter of the annual fee, based on the value of the assets in the Account on a calendar quarter basis. Certain components of the Program Fee are negotiable between the Client with their Financial Professional. Prior to establishing an Account, Program Fees will be detailed in writing in the Client’s Agreement. Program Fees are collected from the Client’s Account by Platform Provider and distributed to M Securities and the appropriate Program service providers. Part 2A Appendix 1 of Form ADV 9 March 31, 2024 M Securities believes that each of our Clients has unique investment management and desired service needs from their Financial Professionals. Given the independent Financial Professional business structure of our network, we also believe that our Financial Professionals are best positioned to understand the unique needs of their respective client bases. As such, our Programs afford Clients and their Financial Professionals freedom of choice to work directly with one another to build the individualized level of service Clients seek, including to negotiate Program Fees up to 3% to accommodate each Client’s service needs and objectives. Clients should note, however, that SEC regulatory guidance provides that the SEC considers investment adviser fees greater than 2% of total assets under management as excessive and/or higher than is normally charged in the industry. As such, because our Programs permit Clients and Financial Professionals to individually negotiate the Program Fee potentially up to 3%, our Program Fees can be, and depending upon the individual Client fee arrangement, will be, higher than is normally charged in the industry by other wrap program providers. Before accepting a Program Fee proposal from a Financial Professional, Clients should carefully consider the proposed Program Fee, including its variable components subject to negotiation, primarily the Financial Professional Fee and the Execution Fee. While every Client’s portfolio management needs and objectives are different, Clients should in particular strongly scrutinize a proposed Program Fee that would be in excess of 2% of Account assets under management to ensure that it is appropriate for their needs in light of the Client’s expected level of and complexity of services and investment strategies they seek for their Accounts. When considering a potential Program Fee proposal, Clients should carefully consider and negotiate with their Financial Professional relative to a range of factors, including but not limited to:
•the level of assets the Client intends to maintain under management in the Program;
•whether the Client’s Account is part of a household Billing Group and is eligible for a Billing Group discount;
•the overall business relationship and level of business the Client maintains with M Securities and the Financial Professional for investment advisory, brokerage, or other services, both as part of and outside of the Program;
•the complexity of assets, investment management styles and strategies the Client desires the Financial Professional to provide in managing the Account;
•the desired level of interaction the Client expects to have with the Financial Professional with respect to the Account as higher levels of interaction may cause a Financial Professional to seek to increase the Financial Professional Fee component; and
•any other factors or considerations the Client considers important or unique to the Client in determining a Program Fee which the Client would deem acceptable and appropriate for the Client’s needs and investment objectives.
The Program Fee may cost the Client more or less than the cost of purchasing each service included separately, if available. Other RIAs may charge a higher or lower fee for giving advice concerning securities, and may or may not offer the other services available in the Programs. In addition, depending upon the frequency of trading in an Account, brokerage and/or clearing fees could be higher or lower if purchased separately. A Client could direct their investments on their own without our services, could elect a non-wrap program, or could elect to obtain investment advice without monitoring via an agreement with us and then direct their own investments. However, the Client would not receive the full wrap services provided by M Securities and our Financial Professionals, which are designed, among other things, to both assist the Client in determining which asset allocations are most appropriate to the Client's financial condition and objectives, provide a wrap program, and provide ongoing monitoring of Client’s Account. Client should discuss these options with their Financial Professional and in all cases, the Client should review the fees charged by M Securities to fully understand the total amount of fees to be paid, and thereby evaluate the advisory services being provided. M Securities offers a wide variety of advisory services aside from Wrap Fee Programs and Clients should discuss services with their Financial Professional prior to engaging M Securities for services. Clients can find additional information within the M Securities Form ADV 2A. Part 2A Appendix 1 of Form ADV 10 March 31, 2024 Minimum Annual Platform Fees: While the Platform Fee is normally included within the Program Fee, the following Programs apply a minimum annual Platform Fee (“Minimum Platform Fee”) for Accounts in the event that an Account’s assets under management fall below certain levels. Only Programs listed below require a minimum fee.
•Classic

= $24 Minimum Platform Fee, with a maximum of $300. Accounts with assets below $184,615 will be charged the negotiated Program Fee, minus the .013%, plus $24 annually. Accounts with assets above $2,308,000 will experience a decrease to the Program Fee by .013% annually, as the Platform Fee is limited to $300.

•Custom = $125 Minimum Platform Fee. Accounts with assets below $113,636 will be charge the negotiated Program fee, minus .11%, plus $125 annually.

•Custom SMA = $150 Minimum Platform Fee. Accounts with assets below $115,385 will be charged the negotiated Program Fee, minus .13%, plus $150 annually.

•Strategist = $50 Minimum Platform Fee. Accounts with assets below $45,455 will be charged the negotiated Program fee, minus .11%, plus $50 annually.
Should the Minimum Platform Fee apply, it will be charged as 25% of the minimum fee at each calendar quarter for the number of calendar days in the quarter. In such event, the total Program Fee expressed as a percentage of Account assets under management would be greater than the percentage agreed to between the Client and Financial Professional, and could potentially cause the total Program Fee to be greater than 3%. Please note that with Classic, Custom and Strategist, the amount of assets subject to the Minimum Platform Fee is greater than the minimum requirement to open and maintain an Account, as detailed in Item 5 below. M Securities addresses this issue by reviewing Accounts and negotiated Program Fees and by requiring justification from our Financial Professionals for Accounts with higher Program Fees to ensure that the Program Account is appropriate for the Client. Billing in Advance and in Arrears: Certain Programs also allow Clients to choose to have Program Fees billed in advance or arrears. Program Fees are applied at 25% of the agreed upon rate for the number of days within the quarter using the Custodians fair market value of assets. The Client will make a choice of Advance or Arrears billing when executing the Agreement. In Advance: This Program fee is payable in the beginning of each quarter in advance based on the prior quarter’s ending balance and prorated for the number of calendar days in the quarter. A new Account will have a start date to initiate the Program Fee determined by the latter of the date the Client executes the Agreement, or the date Client assets are deposited to the Account. The initial Program Fee will be prorated for the number of calendar days in the quarter, with the start date equal to one day. The initial Program Fee is billed one month following the Account start date based on the value of assets deposited to the Account. Contributions and withdrawals in excess of $10,000 will be billed on a prorated basis for the number of days in the quarter with the contribution or withdrawal date equal to one day. The Classic Program offers billing in Advance. In Arrears: The Program Fee will be payable quarterly in arrears at the end of the first quarter we started to provide services. The Program Fee will be based on the average daily fair market value of assets in the Program Account for the number of calendar days in the quarter. Subsequent payments are then due and assessed each calendar quarter based on the preceding quarter’s average daily balance of Program assets. Classic, Custom, Custom UMA, Custom SMA, Strategist, and Envoy offer billing in Arrears. Payment of Program Fee: Billing for Accounts opened or terminated during the quarter will be calculated pro-rata based on the number of days services were provided. The Client will authorize the Custodian to pay the Program Fee out of assets in the Account. Upon receipt of instructions from Platform Provider, the Custodian will withdraw the appropriate amount from the Account. The Program Fee is generally debited directly from the money market balance in the Account(s) and M Securities will sell shares of securities held in the Account in order to raise cash for the Program Fee if the money Part 2A Appendix 1 of Form ADV 11 March 31, 2024 market balance is inadequate to cover the amount of the Program Fee. The sale of securities in taxable Accounts can create reportable gains or losses. All assets in Client’s Account, including cash not invested into a security, will be included in the calculation of the Program Fee, unless agreed upon in writing with the Financial Professional. Household Billing Group: If a Client and Client’s family or household members have more than one Program Account (a household “Billing Group”), Client may be able to lower the Program Fees based on the cumulative assets that members of the household Billing Group maintain in their Accounts relative to tiered fee component schedules. M Securities is not responsible for identifying Accounts eligible for combined fee calculation purposes. Accounts will be combined for Program Fee calculation only on the written request of Account holder or Financial Professional. Additionally, M Securities does not combine fee calculations for advisory accounts outside of the Program in other wrap fee programs or other assets under advisement. This creates a conflict for M Securities and the Financial Professional because we have incentive to recommend different account types to different Client family or household members to avoid a Billing Group. We mitigate this conflict through this disclosure to you and encourage you to discuss Billing Group Programs with your Financial Professional. General Program Services Information As part of the Program Fee for a Wrap account, except as noted in the section titled “Additional fees, charges and other considerations,” the costs associated for various services is included. We provide further information regarding those services, below. Custodial Services: M Securities is also an introducing broker/dealer that provides brokerage services for advisory accounts. During the Account opening process, a Client requests and selects M Securities to open a custodial account for the Client with Pershing, LLC (“Pershing”) or will complete additional paperwork to open an account at Charles Schwab & Co. (“Schwab”). The factors that we consider in selecting or recommending a custodian for transactions in order to provide these advisory services will depend largely on the type of program that Client selects. Each custodian is registered with the SEC, is a member of FINRA and SIPC, and will maintain custody of Clients’ assets and effect trades for Client Accounts. We believe the custodians we have contracted with offer Clients financial strength and stability, economies of scale, and reliable technology. However, the custodians do have differential pricing based on the transaction and security and differences in technology or reporting that may be relevant, depending on the anticipated use of securities or trading, or client preferences. For further information with respect to brokerage and custodial services and costs, Clients should request such information from the Financial Professional and discuss the best custodian for Client. The custodian will maintain custody of Program Account assets and will execute transactions and perform the clearance for such transactions. The custodian will perform custodial functions, among other things, including: (i) crediting of interest and dividends on Account assets; (ii) crediting of principal on called or matured securities in the Account; (iii) debiting the Program Fee from the Accounts; (iv) processing, pursuant to M Securities’ instructions, of deposits to and withdrawals from Accounts; and (v) other custodial functions customarily performed with respect to securities brokerage accounts. Clients authorize the custodian to execute orders from the Portfolio Manager on a discretionary basis. The custodian will also forward confirmation of each purchase and sale to Client and to M Securities in accordance with applicable law. Execution fees are included in the total Program Fee, but differ at each custodian.
•The execution fee for our program at Pershing can be up to 0.05% of total assets under management in the account and is included in and debited at the same time as the Program Fee. Pershing will reduce its asset-based fee when a security is traded that would otherwise trade for no commission, such as for Funds invested through Pershing’s FundVest Program, which is a no-transaction fee program in lieu of clearance charges. For Clients whose Accounts are Part 2A Appendix 1 of Form ADV 12 March 31, 2024 partially invested through the FundVest Program and partially through non-FundVest clearing channels, the Client’s Account will in practice yield a blended average rate.
•The execution fee in our Program at Schwab can be up to .10% of total assets under management in the account. This fee is included in the Program Fee shown above, but is debited from client accounts directly by Schwab on a monthly basis at a different time from the rest of the Program Fees. Schwab will debit from the client Account a minimum fee of $10 per month for execution services. This minimum fee will increase the total Program Fee paid for Accounts with low balances (less than $120,000).
In light of these differential custodial fees, we encourage you to discuss with your Financial Professional which custodian is the best for your account. In certain cases, the Financial Professional elects to pay for the Execution fees on Client’s behalf. The Financial Professional, in his or her discretion, may choose to pay for one Client’s Execution Fees while allowing another Client to bear the Execution fee included in the total Program Fee. Many factors can affect a Financial Professional’s determination whether to pay for Execution Fees or allow the Execution Fee to be part of the overall total Program Fee. These factors include the frequency of trading activity, the types of securities products purchased and sold, and the use of no-transaction fee mutual funds and the amount of assets under management. The choice of whether to pay for Execution Fees in one Client’s Account over another creates a conflict of interest because the Financial Professional has a financial incentive to trade less or trade mutual funds that have no transaction fees. The Financial Professional paying for transaction fees may benefit the client, if the Financial Professional determines that the number of transactions to maintain the Account may not warrant the client paying the percentage on total assets under management. In this scenario, the greater amount of assets under management, the more beneficial this option can be to Clients. Platform Provider Services: The services of the Platform Provider, Envestnet, are included in the total Program Fee. M Securities and Envestnet are not affiliated. M Securities monitors Envestnet’s provision of services to our Programs to ensure that the services contracted for are being provided. With the exception of the Classic Program, Envestnet will also provide Overlay management services for Client Accounts, and place trades for Client Accounts at the direction of the Client’s Financial Professional or third-party money manager appointed as Portfolio Manager for Client’s Account. Envestnet will determine on a discretionary basis the time and amount of the trade to be executed on behalf of the Client in accordance with instructions received from the Portfolio Manager. M Securities pays Envestnet for services related to the Programs that may range from .013% to .13% depending upon the Program and the market value of the assets within an Account. These costs below for program services are exclusive of fees for Additional Overlay Services) rendered for our Programs: Classic Custom Custom UMA Custom SMA Envoy Strategist 0.013% 0.11% to 0.025% 0.13% to 0.03% 0.13% to 0.03% 0.13% to 0.03% 0.11% to 0.035% Our Custom UMA and Envoy Programs, allows Clients the option of choosing to add specialized tax and impact “overlay” services (“Additional Overlay Services”) for their Accounts as described further below. Such fees will be included in the Program Fee, but can increase the amount of the total Program Fee as determined between the Client and Financial Professional when negotiating the Financial Professional Fee component of the total Program Fee. Envestnet will receive payment of .10% of assets under management for Clients that choose Additional Overlay Services. Additional Overlay Services will vary between Programs and may change from time to time. Currently, Envestnet offers within two Programs, an Additional Overlay to screen for control of large unrealized tax gains that are imbedded in portfolios, and an Additional Overlay to screen for investing within a Client’s personal values: Part 2A Appendix 1 of Form ADV 13 March 31, 2024
•Tax Overlay Services provides a holistic and customizable solution for Clients who want to control and customize their realization of large unrealized gains that are imbedded in their portfolios, or for Clients who have other unique circumstances that require an individualized strategy.

•Impact Overlay Services provides a customizable solution for Clients to direct multiple Impact screens intended to align with a comprehensive representation of a Client’s personal values.
Financial Professional Services: The services of your Financial Professional is included in the total Program Fee. When accounting for Platform and Custodial Fees, the maximum fee allowable to the Financial Professional is 3% Clients should carefully consider the services they require and negotiate their fee based on those services. M Securities addresses this conflict of interest by reviewing Program Accounts for suitability at opening, on a periodic basis for Account review as described further in Item 9 at Review of Accounts, by enforcing our Code of Ethics, through this disclosure to you, and by establishing a total Program Fee for Client Accounts that is limited to 3%. Third-Party Money Managers and Associated Services: Certain Programs such as the UMA, SMA, Envoy, and Strategist Programs allow Financial Professionals, depending on the Account asset levels requirements and the individual investment objective of the Client, to select from an Envestnet Platform roster of “Approved” third-party money managers, who’s services may not otherwise be accessible to Clients. Envestnet is responsible for conducting due diligence on each “Approved” money manager on its Platform. Envestnet also provides “Available” money managers for selection. “Available” money managers have not undergone selection, due diligence and oversight of program offerings by Envestnet. Should M Securities, a Financial Professional, and/or Client request a specific money manager from the Envestnet “Available” list, M Securities or Financial Professional will be responsible for conducting due diligence and M Securities maintains sole discretion in determining whether to allow a requested “Available” money manager to provide Account services in our Program. Clients should also carefully review the Form ADV Part 2A brochures for third-party money managers they are considering with their Financial Professional for the provision of money manager services for their Accounts. If selected, third-party money managers will provide portfolio management services for the Client’s Account that range from managing individual securities within a separately managed account according to a pre-set investment philosophy or style, to utilizing model portfolios that have been strategically created by the money manager.
•A separately managed account (“SMA”) is a portfolio of individually owned securities that can be tailored to fit a Client’s investing preferences. Envestnet will assist Financial Professionals in identifying individual money managers and investment vehicles that correspond to the proposed asset classes and styles, or Financial Professionals will independently identify money managers. Envestnet retains the money managers as third-party money managers for portfolio management services in connection with the SMA program through separate agreements.
•Some third-party money managers act as a model strategist provider, and construct and provide asset allocation models. These models often utilize the underlying Funds advised by the money manager. In such situations, the model provider or its affiliate(s) will receive fees from the Funds for serving as investment advisor or other service provider to the Fund (as detailed in the Fund’s prospectus). These fees will be in addition to the management fees that the money manager receives for its ongoing management of the models and creates a financial incentive for the money manager to utilize their Funds. Clients should discuss any questions with or request further information from their Financial Professional concerning the conflict of interest this creates.
Part 2A Appendix 1 of Form ADV 14 March 31, 2024 The Program Fee that Client negotiates with their Financial Professional will include fees paid to third-party money manager(s) providing investment management services for the Client’s Account, and will range depending upon the services provided and the money managers(s) selected. The range of fees varies from 0.02% to 0.60% based on the Program selected, and as indicated in the table below, and are included in your Total Program Fee. Custom UMA Custom SMA Envoy Strategist 0.25% to 0.60% 0.25% to 0.60% 0.02% to 0.45% 0.02% to 0.60% ADDITIONAL FEES, CHARGES, AND OTHER CONSIDERATIONS There will also be other fees and costs assessed to Clients that are not part of the Program Fee. These fees and costs are described below.
•Custodial Fees: Clients can incur certain charges imposed by custodians for Account maintenance that are in addition to the Program Fee. The Program Fee does not include fees or costs incurred for products or services that are not part of the Program Fee including, but not limited to: mark-ups, mark-downs; spreads paid to market makers; electronic fund transfer and wire fees; IRA and qualified retirement plan Account fees; statement and confirmation fees; termination fees; transfer fees; the costs of the operating expenses of the mutual funds, including exchange-traded funds and money market funds, as well as any applicable shareholder fees assessed by such funds or charges; and taxes currently imposed by governmental authorities, self-regulatory bodies, transfer agents and other outside entities with respect to securities transactions (including, but not limited to SEC Section 31 transaction fees, Depository Trust Company fees, redemption and transfer fees) (collectively, “Additional Costs”); and any brokerage commissions or other charges imposed by BDs or entities other than custodian (i.e., “step-out trading” costs) in the event the Portfolio Manager, Envestnet when it provides Overlay Management Services, or other third-party money managers with discretionary trading authority for a Client’s Account were to determine that it would be consistent with their duty of best execution to execute particular trades away from custodian. Clients will separately bear these Additional Costs.

•Mutual Fund and ETF Fees: All fees paid to M Securities for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each Fund's prospectus. These fees will generally include a management fee, other Fund expenses, and a possible distribution fee. If the Fund also imposes sales charges, these charges will be suppressed. However, if a Client transfers previously purchased mutual funds into a Program Account, and there is an applicable contingent deferred sales charge or redemption fee on the Fund, Client will pay that charge when the mutual fund is sold. In no case should the Financial Professional receive any ongoing commissions. However, M Securities may receive other fees (e.g., finders fees) associated with mutual fund transactions. Finder Fees are distributed to BDs in lieu of a load on A shares. If a Client purchases a load-waived A Share in an advisory Account, it is possible that M Securities would receive a finder’s fee. M Securities returns any such revenue received to the Client.
Part 2A Appendix 1 of Form ADV 15 March 31, 2024 In many instances, we make available mutual funds in our advisory programs that offer various share classes. Depending on the custodian, our agreement with the same, and mutual fund company, there may be available several versions of the same mutual fund with different levels of ongoing expense, charges, and distribution of 12-b1 fees, and associated transaction charges. Typically, when a mutual fund makes several share classes available, those with the higher transaction charges also have lower ongoing expenses. Not all mutual funds have the same share classes available. While each mutual fund prospectus indicates whether the share class invested charges a 12b-1 fee, some share classes typically charge 12b-1 fees while others do not. For illustrative purposes, Class A Shares typically charge a 12b-1 fee (to pay as servicing charges to the BD and Financial Professional) and Class I Shares do not charge a 12b-1 fee. As a result, it is typically more expensive for the client to own Class A Shares than Class I Shares (excluding any applicable advisory fee). In an effort to reduce the financial incentive to recommend a mutual fund share class that charges a 12b-1 fee, in most instances, M Securities reimburses the client’s account with the 12b-1 fee charged. In some instances, the 12b-1 fee or a portion of other mutual fund fees is retained by the qualified custodian that makes the mutual funds available to us or is used to waive or reduce client transaction charges. Whether the 12b-1 fee is reimbursed to the Client or retained by the qualified custodian is dependent upon which qualified custodian holds the Client’s assets. The availability of a lower-cost share class is fund specific and not all Class I Shares or other lower expense Shares may be available for investment due to investment minimums and other fund-specific requirements. In many cases it is beneficial to pay a higher transaction charge in lieu of higher ongoing expenses. Clients should discuss these preferences with their Financial Professional. M Securities Compensation: M Securities and our Financial Professionals receive compensation as a result of Client participation in the Program, as set forth in the Financial Professional Fee section above. Program Fees provide a financial incentive for M Securities and the Financial Professional to recommend the Program. The amount of compensation under the Program may be more or less than what the Financial Professional would receive if Client paid separately for investment advice, brokerage, and other services. M Securities and our Financial Professional have a financial incentive to recommend the Program over other programs or services offered by M Securities which would provide less remuneration. We address this conflict through this disclosure to you and initial review of the suitability of the Program for the Client. M Securities is compensated indirectly by assessing the Member Firms, and thus their Financial Professionals, a retention fee (“Retention Fee”) based on the quarterly amount of total investment advisory fee revenue generated by each Financial Professional within the Member Firm. M Securities calculates the total amount of each Member Firm’s Financial Professional quarterly fee revenue based on a combination of a sliding scale percentage of the Member Firm’s Financial Professional quarterly fee revenue (higher percentages at lower thresholds) and a set dollar amount increasing with tiered levels of revenue. M Securities retains an amount based on the Retention Fee schedule and pays the balance to the Financial Professional. As a result of the Retention Fee, M Securities has a conflict of interest as the Program Fee may result in greater fee revenue generation, and thus increase the amount of the Retention Fee assessed, based on the amount of the Financial Professional Fee that may be negotiated between a Client and their Financial Professional. The Financial Professional is incentivized to place additional Client assets into Programs to reduce M Securities’ overall retention percentage and to generate revenues for Financial Professional or Financial Professional’s Member Firm to qualify or remain affiliated with M Financial. Additionally, M Securities charges our Member Firms for our services associated with providing supervision, compliance, registration and professional insurance to Financial Professionals. We mitigate these conflicts through this disclosure to you. Because conflicts of interest and the way we earn money is inherent in our business, M Securities also addresses these conflicts of interest by reviewing Program Accounts for suitability at opening, on a periodic basis for Account review as described further in Item 9 at Review of Accounts, by enforcing our Code of Ethics, and by establishing a Total Program Fee for Client Accounts is limited to 3%. Additionally, both M Securities and all Financial Professionals must comply with applicable state investment adviser registration requirements and applicable state and federal securities laws and rules. Part 2A Appendix 1 of Form ADV 16 March 31, 2024 Termination of the Program Account: Either M Securities or the Client may terminate the Agreement upon written notice to each other, as detailed within the Agreement. At that time, any unearned Program Fees previously deducted will be returned to Client if Client paid fees in advance. If Client pays fees in arrears, the amount of the pro-rata Program Fee and any other fees and charges due through the effective date of termination are due and payable prior to any assets being transferred to another custodian or delivered to Client, including any applicable termination fees as provided for in the Client’s Agreement. Upon termination of the Program Account, Client must provide direction to M Securities on how to transfer Client’s assets upon termination of the Account, as we will not be under any obligation with regard to the assets in the Account. Absent such direction, M Securities retains the right, in its sole discretion, to transfer Client’s Account to a brokerage account with Client bearing all associated costs with the same. If Client’s Financial Professional should leave M Securities, we will notify Client and work to reassign Client’s Account to another Financial Professional, who could be associated with a different Member Firm. If we cannot find a Financial Professional to service Client’s Account, we can, in our sole discretion, terminate the Agreement as outlined in this section.