MPMG is a value-based investment management firm that endeavors to create wealth for their clients over meaningful periods of time, while also seeking less volatile results than more aggressive methods of equity investing. MPMG is an all-capitalization manager, looking at small-, mid- and large-cap companies, both domestic and abroad. MPMG was founded in 2004 and is owned by Harrison T. Grodnick and Phillip W. Grodnick, both of whom are the Principals of MPMG. In 2021, Robert A. Britton, Jr. became a partner at MPMG. MPMG specializes in designing equity portfolios or balanced portfolios consisting of equity securities as well as fixed income instruments. These portfolios are managed on a discretionary basis in accordance with MPMG’s “All-Cap Value” strategy. In limited situations, MPMG also manages client portfolios on a non- discretionary basis. Further information regarding the All-Cap Value strategy may be found in Item 8. Clients have the right to place any type of limitation or restriction on their portfolios. Among other things, a client can request that MPMG execute transactions to address tax issues, add to, reduce, or eliminate a particular security position, omit an industry or sector, or specify the percentage or amount of cash held at any time. MPMG also provides investment advisory services pursuant to wrap programs sponsored by various third parties and to model-based managed account programs. With regard to MPMG’s wrap programs, MPMG uses the All-Cap Value strategy and manages such accounts no differently than it manages other accounts. MPMG receives a portion of the wrap fee for its services. With regard to its model-based managed account programs, MPMG similarly provides advisory services using the All-Cap Value strategy through programs (“programs”) sponsored by certain financial intermediaries (“program sponsors”). In these programs, MPMG provides the program sponsors non- discretionary investment advice through model portfolios and has no relationship with the program sponsor’s clients. The program sponsors are responsible for making investment decisions, determining suitability, and performing many other services and functions typically handled by MPMG in a traditional discretionary managed account program. Additional information concerning MPMG’s trading practices with respect to wrap programs and model-based managed account programs is contained in Item 12. When MPMG provides investment advice to clients regarding their retirement plan account or individual retirement account, MPMG is a fiduciary 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 MPMG makes money creates some conflicts of interest, so MPMG operates under a special rule that requires it to act in the clients’ best interest and not put MPMG’s interest ahead of its clients’ interests. Under this special rule’s provisions, MPMG must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of its clients’ interests when making recommendations (give loyal advice);
• Provide basic information about conflicts of interest;
• Avoid misleading statements about conflicts of interest, fees, or investments;
• Follow policies and procedures designed to ensure that MPMG’s advice is in its clients’ best interest. To the extent that this brochure is delivered to program clients with whom MPMG has no advisory relationship or under circumstances where it is not legally required to be delivered, it is provided for informational purposes only. Furthermore, because a model-based managed account program sponsor generally exercises investment discretion and, in many cases, brokerage discretion, performance and other information relating to MPMG’s services for which it exercises investment and/or brokerage discretion is generally provided for informational purposes only and will not be representative of model-based managed account program client results or experience. MPMG’s advisory agreements with its clients typically contain provisions that may act as a waiver, release or limitation of certain rights clients may have against MPMG arising from its services. In substance, the agreements usually state that MPMG and its employees are not liable for any loss arising out of MPMG’s advice or for acts or omissions taken with respect to its services, except for bad faith, intentional misconduct, or negligence in the performance of its duties. Notwithstanding the liability limiting nature of these provisions, clients should be aware that federal and state securities laws may impose liabilities on MPMG under certain circumstances. Accordingly, nothing in those or any other provisions in the agreements will have the effect of waiving, releasing, or limiting any rights a client may have under those laws or under any other laws that are not permitted to be waived, released, or limited by contract. As of December 31, 2023, MPMG had $824,873,779 in regulatory assets under management in discretionary accounts and $64,086,630 in regulatory assets under management in non-discretionary accounts. MPMG had $224,597,880 in model-based managed accounts, which are not included in MPMG’s regulatory assets under management.