Founded by Thomas McDonald in 2005, McDonald Partners LLC (“McDonald Partners” or the “Firm”) is a dually registered investment adviser and broker-dealer headquartered in Cleveland, Ohio with offices throughout Northern Ohio and Michigan. McDonald Partners provides a variety of investment management services through its Financial Advisors to individual and institutional clients, including banks, pension and profit-sharing plans, trusts, estates, charitable organizations, and business entities. These services are provided on a personalized basis with investment programs tailored to reflect each client’s specific circumstances. These tailored services may include restrictions of industry (i.e., gambling, tobacco, etc.), income needs, and tax planning, to name a few. We work with you to design an investment portfolio and style that will meet your personal goals. McDonald Partners has four wealth management groups: CapTrust Financial Advisors, Mansour Wealth Management, MRT Asset Management, and Goodman Financial Group/Goodman Wealth Advisors. The first three groups are separate legal entities. The financial advisors in all of these groups are investment adviser representatives and registered representatives of McDonald Partners. Goodman Financial Group/Goodman Wealth Advisors is used as a “doing business as” by that team. Throughout this brochure, we refer to McDonald Partner’s investment adviser representatives as Financial Advisors. McDonald Partners charges a single fee based on the value of the Client’s assets under management. The single fee includes portfolio management, trading commissions, and custody services. Clients are required to establish brokerage accounts at a qualified custodian, RBC Correspondent Services (“RBC CS”), our clearing broker-dealer. RBC CS is not affiliated with McDonald Partners. McDonald Partners provides various types of advisory programs including wrap programs, financial planning, retirement plan consulting services, and participant education, and other customized portfolio management services. This brochure describes McDonald Partners’ Flex Program (“Flex Program”). For more information about McDonald Partner’s advisory services and programs other than the Flex Program, please contact your investment advisor representative (“Financial Advisor”) for a copy of a similar brochure that describes such service or program or go to www.adviserinfo.sec.gov. You should have a conversation with your Financial Advisor and read this and similar brochures carefully, as they explain our services in detail. Regardless of which program you select, our advisory process begins with a data collection process to help our Financial Advisors understand, among other things, your short- and long-term financial objectives, risk tolerance, tax status, current investment holdings, and asset allocation. Our Financial Advisors will analyze current investment holdings as to their potential place in your McDonald Partners LLC – WRAP Program Brochure – Page 5 investment strategy and make several recommendations for potential improvements to align the current portfolio with the proposed investment strategy. Business Continuity Plan Our Firm’s business continuity plan (“the Plan”) is designed to meet the needs of our clients and minimize potential disruption in services during an emergency or disaster. The protocols and capabilities within the plan include:
• Sufficient technical infrastructure and network capacity to support employees working from home in specific areas, or companywide
• Secure, remote access for employees
• Videoconference capabilities in place for employees
• Redundancy capabilities within each of our business units Flex Account We offer the McDonald Partners Flex Account. Our Flex accounts can be non-discretionary (you work alongside your Financial Advisor) as well as discretionary (your Financial Advisor has your permission to manage your account without your consent as to what/when/how much or what price to buy or sell securities in your account). The Flex account offers advisory services along with transaction, clearing, and custodial services for one fee based on the assets under management, and is considered a wrap-fee program. This is different from non-wrap-fee management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. Based upon information from you during an initial interview, your Financial Advisor will construct a portfolio of securities based on your specific individual needs, risk tolerance and investment objectives. Your portfolio can include some or all of the following investment vehicles: load or no-load mutual funds, exchange-traded fund (ETFs), stocks, bonds, cash, cash equivalents, closed-end funds, and other securities as appropriate for your individual needs. The Flex Account program includes access to an assigned Financial Advisor. Financial Advisors are available during business hours and may be reached via telephone, email or in person at the Firm’s offices. Client assets are held at RBC CS, which is not affiliated with McDonald Partners. In determining whether to establish a Flex account, a Client should be aware that the overall cost to the Client of McDonald Partners’ Flex Account may be higher or lower than the Client might incur by purchasing separately the types of securities available through the Flex Account Program. To compare the cost of the Flex Account with unbundled services, the Client should consider the turnover rate in his or her selected investment strategies, trading activity in the account, standard advisory fees, and brokerage commissions that would be charged at other broker- dealers and investment advisers. McDonald Partners LLC – WRAP Program Brochure – Page 6 Hegarty Asset Management One of the investment options offered in the Flex Account is a proprietary asset management program, Hegarty Asset Management, operating as a division of McDonald Partners. This option is called “Core.” It is a large capitalization discipline investing in a blend of both growth and value companies. The portfolio typically owns between 40-50 companies diversified among the eleven major sectors of the Standard & Poor’s 500 Index. This index also represents the performance benchmark. Key “Core” portfolio characteristics include discounted valuation on a price-book, price-sales, and price-earnings basis. Companies in the portfolio have projected 3-5 year earnings, revenue and dividend growth well above that projected for the market. The risk and volatility profile is moderate with a beta below that of the S&P 500 Index. “Core” is available to both McDonald Partners Financial Advisors and other investment advisory firms. The fee to Hegarty Asset Management is competitive with other third-party managers. Although the Flex program requires a minimum initial investment amount of $25,000, the minimum account size required to invest in Hegarty Asset Management is $250,000. Exceptions may be granted in the discretion of Bill Hegarty, the portfolio manager. Bill Hegarty, Chief Investment Officer of McDonald Partners, is the portfolio manager. He has over 35 years of investment research and portfolio management experience. Details regarding Mr. Hegarty experience are outlined in his Form ADV Part 2B Supplement. Conflict of Interest: Because McDonald Partners earns compensation from Hegarty Asset Management for assets placed, this constitutes a conflict of interest. Individual representatives of the Firm do not earn additional compensation for referring accounts to Hegarty Asset Management; however, from a business aspect, the additional compensation presents a conflict of interest for which you end up paying more or less for those same services. Please discuss all fee arrangements with your Financial Advisor or if you have any questions regarding this conflict of interest, please contact our compliance department. Fees and Compensation The Firm charges a single fee based on the value of the Client’s assets under management. The single fee includes portfolio management, trading commissions, and custody services. The Client authorizes McDonald Partners to debit the advisory fee directly from the Client’s investment account. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. Listed below are the maximum fees charged for McDonald Partners Flex Accounts: Fixed Income Only Accounts: On the first $500,000 1.75% annually On the next $550,000 1.25% annually On the next $1,000,000 1.00% annually Asset above $2,000,000 0.75% annually McDonald Partners LLC – WRAP Program Brochure – Page 7 Equity/Balanced Accounts: On the first $500,000 3.00% annually On the next $500,000 2.50% annually On the next $1,000,000 2.00% annually On the next $2,000,000 1.50% annually Option Trades $ 9.00 per trade + $0.50 per option contract (minimum $3.00) ACCESS Accounts $ 9.00 per trade transaction fee + 0.04% ($40 minimum) fee for performance reporting Depending on specific circumstances, fees may be subject to negotiation. McDonald Partners will not change any fees without prior written notice and acceptance of the client. The Financial Advisor’s Fee is included in the total investment management fee charged by the Firm and is paid by the Firm to the Financial Advisor. For Clients of the Goodman Financial Group/Goodman Wealth Advisors, the advisory fee on client assets invested in IPOs and secondaries is waived for a period of one year. The Financial Advisors that purchase IPOs and secondaries on behalf of client accounts receive a selling concession in their role as registered representative of McDonald Partners as broker-dealer. For Clients of CapTrust Financial Advisors that are invested in Michigan municipal tax-free bonds, CapTrust Financial Advisors have determined that it is cheaper for the Client to purchase these securities in a brokerage account, where the Financial Advisor receives a commission on the trade, as opposed to placing the asset in the Client’s advisory account and charging a fee based on the Client’s assets under management. In the event the Client does not have a brokerage account with McDonald Partners, Michigan municipal tax-free bonds can be purchased in the Client’s advisory account and the advisory fee is not charged on those assets. The Financial Advisor will still receive a commission for the purchase or sale of the bonds. The Firm provides advisory services to seven private funds that are managed by an affiliate of the Firm. These private funds include MP127 LLC, MP DPI LLC, MPCF LLC, MPCF II LLC, MPCF III LLC, Eden Rock Montenegro LLC, and ERM Resort LLC (the “Funds”). The account-level advisory fee on Client assets invested in the Funds is waived until such time that the total dollar amount of advisory fees waived equals or exceeds the placement fee charged for those Funds where McDonald Partners received a placement fee. The fees to be charged on these assets are based on the estimated fair value of the Funds and will not exceed the maximum advisory fees set forth in Item 5 Fees and Compensation. In most cases, the assets in the Funds are not publicly traded and are valued by McDonald Partners or an independent

valuation service provider in accordance with the Firm’s valuation policy. McDonald Partners LLC – WRAP Program Brochure – Page 8 In the event of account termination of our services, you will only be charged for the days your account was under management. You may terminate this agreement with us at any time by written notice to us. Account termination notices should be sent to McDonald Partners LLC, 1301 East 9th Street, Suite 3700, Cleveland, OH 44114 or by email to your Financial Advisor at his or her respective email address. The client can also terminate the Investment Management Agreement within five days of execution and receive a full refund of any fees charged under the program. However, in such case, the client will be responsible for fees and/or commissions charged on trades executed prior to the receipt of such notice by McDonald Partners. Fees are computed and payable quarterly or monthly in arrears (unless you have negotiated a different payment arrangement) on the valuation of your assets under management on the last day of the quarter, depending on the agreement between the Client and McDonald Partners. The value on the final day of the quarter, or month, as the case may be, is multiplied by the portion of your annual fee attributable to that month or quarter (calculated by dividing the annual fee by 365 days (or 366 days in a leap year) then multiplying the quotient by the number of days in the given month or quarter). Fees will automatically be deducted from your account on or about the 15th day following the end of each quarter or month, as the case may be, unless you have arranged for an alternative method of payment. The fee does not include certain dealer markups or markdowns, odd lot differentials, transfer taxes, exchange fees (among which SEC fees are included), and any other fees required by law. The valuation used to calculate the fee is provided by RBC CS for publicly traded securities. Valuation Policy When determining market value of an account for the purpose of calculating advisory fees, McDonald Partner’s policy is as follows: For all publicly traded securities held in client accounts, the Firm relies on the daily prices received from the clients’ custodians. For investments in private funds or other illiquid assets that are not managed by McDonald Partners or its affiliates, the Firm relies on the valuations provided by the issuer of the asset. Depending on the type of asset or the underlying investment, valuations may be reflected at cost until such time as the issuer provides an updated valuation. For the Funds, McDonald Partners values any non-publicly traded assets pursuant to its valuation policy Information about Compensation related to the Funds As noted above, McDonald Partners serves, through an affiliated entity, as manager to seven private funds. McDonald Management LLC, a wholly owned subsidiary of McDonald Partners, is the manager of these private funds. For the Funds, McDonald Management LLC receives no compensation for its advisory services aside from reimbursement of its reasonable expenses. Please see the discussion of fees paid by MPCF III LLC below. This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. Persons reviewing this Brochure should not construe this as an offer to sell or solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only using a confidential private placement memorandum. With respect to MP127 LLC, MPCF LLC, MPCF II LLC, MP DPI LLC, Eden Rock Montenegro LLC and McDonald Partners LLC – WRAP Program Brochure – Page 9 ERM Resort LLC, McDonald Partners served as placement agent and received placement fees ranging from 3% to 5% of the gross proceeds of the offerings, as more fully described in the private placement memorandum for each fund. With respect to MP DPI LLC, McDonald Partners paid the Fund’s organizational, legal, and accounting costs and other expenses and fees related to the Underlying Investment and the Fund’s operation out of the placement agent fees it received for acting as the placement agent for the Underlying Offering, including the proceeds of the Fund Offering. McDonald Partners received compensation in the form of warrants to purchase common stock of Diasome Pharmaceuticals Inc, the portfolio company of MP DPI LLC, as consideration for its financial advisory services. With respect to Eden Rock Montenegro LLC, McDonald Management LLC can receive a carried interest as owner of Class B Units, if such units are issued. This interest will only be distributed after each Class A Member has been paid a preferred return and all of its capital contributions have been repaid. With respect to ERM Resort LLC, McDonald Management LLC can receive a carried interest as owner of Class B Units, if such units are issued. This interest will only be distributed after each Class A Member has been paid a preferred return and all of its capital contributions have been repaid. With respect to MPCF III LLC, McDonald Management LLC, as fund manager, can receive a 20% carried interest following the full return of capital to the members of the fund. Additionally, once certain conditions are satisfied, the fund will pay to McDonald Partners a fee for management and administrative services equal to 1% of the aggregate offering proceeds. McDonald Partners did not receive a placement fee for its services as placement agent for this fund. The account-level advisory fee on Client assets invested in the Funds is waived until such time that the total dollar amount of advisory fees waived equals or exceeds the placement fee charged for those Funds where McDonald Partners received a placement fee. The fees to be charged on these assets are based on the estimated fair value of the Funds and will not exceed the maximum advisory fees set forth in Item 5 Fees and Compensation. In most cases, the assets in the Funds are not publicly traded and are valued by McDonald Partners or an independent valuation service provider in accordance with the Firm’s valuation policy. Mutual fund managers charge certain fees for their services and products. Those fees are in addition to the investment management fees paid to the Firm and are separate and distinct from the investment management fees charged by the Firm. These fees and expenses are described in the prospectuses for each mutual fund. Some mutual funds charge front-end or back-end loads (also known as initial or deferred sales charges), investment management fees, other fund expenses and distribution fees (“12b-1 fees”). Mutual funds provide for the payment of certain Rule 12b-1 and other similar asset-based charges (“12b-1” fee). Typically, all or a portion of the 12b-1 fee is paid by a mutual fund company to the Firm, as outlined in the applicable prospectus, potentially creating an incentive, and thus a conflict of interest, for the Firm or your Financial Advisor to recommend a mutual fund that will McDonald Partners LLC – WRAP Program Brochure – Page 10 pay a 12b-1 fee as opposed to one that does not. We address this conflict of interest by (1) offering Advisor share class Mutual Fund positions for new purchases in Client accounts (when available), and (2) crediting any 12b-1 fees that we receive related to a mutual fund held in an advisory account back to the Client Account. Many mutual fund companies offer advisory, institutional, or other share classes that do not have a sales load or assess 12b-1 fees. Many mutual funds offer multiple classes of shares which are available based on various eligibility requirements as dictated by the fund company. RBC CS or the Firm will decide which share classes to offer in the Firm’s Clients based on such eligibility requirements, the availability of share classes under the distribution agreements available to the Firm through RBC CS, and other considerations. In most cases, we recommend the lowest expense ratio share class offered by the fund company and available through RBC CS, but in some cases, we can choose to recommend a higher-cost share class. It should be noted that, in certain instances, certain share classes are not available to us through RBC CS and there may be a cheaper alternative available to you should you qualify for it and purchase it elsewhere. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid and to thereby evaluate the Advisory services being provided. Cash balances in Client accounts are invested in money market mutual funds including, as permitted by law, those with which we have agreements to provide administrative, distribution, and other services and for which we receive compensation for the services rendered. Clients who participate in a program may pay more or less for the services described in this brochure and the RBC CS Brochure than if they purchased such services separately. McDonald Partners has a revenue sharing agreement with RBC CS whereby McDonald Partners receives a rebate based on McDonald Partners’ monthly average daily balance in RBC Insured Deposit Accounts. McDonald Partners also receives payments from RBC CS based on the Firm’s monthly average balance in the U.S. Government Money Market Fund. If, however, the U.S. Government Money Market Fund waives 50 basis points or more of its fees, then McDonald Partners will not receive any payments. The U.S. Government Money Market Fund is available for balances that exceed the FDIC insurance coverage limit. Both of these arrangements calculate the payments to McDonald Partners using the Federal Funds rate. When that rate is zero, the Firm does not receive any payments. As of the date of this Brochure, McDonald Partners receives less than 5% of its revenue from these arrangements. The RBC Insured Deposit Account and the U.S. Government Money Market Fund are cash sweep options for client accounts with assets of $5,000,000 or more. Clients can select from these and other sweep options when establishing their account at RBC CS. Rollovers to an IRA Effective February 1, 2022, for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you: McDonald Partners LLC – WRAP Program Brochure – Page 11
• When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts.
• The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: o Meet a professional standard of care when making investment recommendations (give prudent advice). o Never put our financial interests ahead of yours when making recommendations (give loyal advice). o Avoid misleading statements about conflicts of interest, fees, and investments. o Follow policies and procedures designed to ensure that we give advice that is in your best interest. o Charge no more than is reasonable for our services. o Give you basic information about conflicts of interest.