McAdam offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to McAdam rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with McAdam setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). McAdam was formed in 2014 and is wholly owned by Michael McAdam. As of December 31, 2023, McAdam had $1,737,778,764 of assets under management on a discretionary basis and $1,273,709 of assets under management on a non-discretionary basis. While this brochure generally describes the business of McAdam, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on McAdam’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services McAdam offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions (The scope of the services to be provided depends upon the needs of the client and the terms of the engagement):
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence In performing these services, McAdam is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. McAdam may recommend clients engage the Firm for additional related services, its Supervised Persons in their individual capacities (which may include registration as insurance agents or registered representatives of a broker-dealer) and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage McAdam or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by McAdam under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising McAdam’s recommendations and/or services. RetireUS Subscription Service McAdam also offers tiered financial planning services for a weekly subscription fee. Available service tiers include Basic Planning, Tax Mastery and Wealth Mastery. Basic Planning is the base subscription service package. Tax Mastery builds upon the services offered at the Basic Planning level, but also includes tax planning and review services. Wealth Mastery includes the services offered as part of the Tax Mastery service level and will also include tax liability and estate plan audit services. Clients who choose to engage McAdam through its RetireUS Subscription service will select a service level when they execute the ReitreUS Financial Planning Agreement. A detailed list of services included within each service level appears on Schedule A of the subscription agreement. Investment Management Services McAdam generally manages client investment portfolios on a discretionary basis. McAdam primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. In addition, McAdam may also recommend that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage McAdam to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, McAdam directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. McAdam tailors its advisory services to meet the needs of its individual clients and seeks to manage client portfolios in a manner consistent with those needs and objectives. McAdam remains available to consult with clients on an ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify McAdam if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if McAdam determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, McAdam may provide financial planning and related consulting services. Neither McAdam nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. McAdam does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with McAdam, if desired. McAdam does not serve as an attorney or accountant, and no portion of McAdam’s services should be construed as same. Accordingly, McAdam does not prepare estate planning legal documents or tax returns. To the extent requested by a client, McAdam may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.), including representatives of McAdam in their separate individual capacities as representatives of Purshe Kaplan Sterling Investments (“PKS”), an SEC registered and FINRA member broker-dealer, and as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from McAdam and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not McAdam, shall be responsible for the quality and competency of the services provided. Retirement Plan Services - John Hancock Life Insurance Company (“John Hancock”): McAdam and its related persons may recommend John Hancock to certain retirement plans for retirement plan consulting services. Should a retirement plan choose to engage John Hancock for these services, McAdam and/or the investment adviser representative will be named as the investment adviser associated with the John Hancock account. Therefore, McAdam and certain investment adviser representatives may receive a fee of up to 1.00% for investment advisory services rendered in such situations. Conflict of Interest: The recommendation by McAdam and its related persons that a client engage John Hancock to provide retirement plan services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend John Hancock based on compensation to be received, rather than on a particular client’s need. No client is under any obligation to engage John Hancock. Retirement Rollovers-Potential for 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 McAdam recommends that a client roll over their retirement plan assets into an account to be managed by McAdam, such a recommendation creates a conflict of interest if McAdam will earn new (or increase its current) compensation as a result of the rollover. If McAdam provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), McAdam is acting as 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. No client is under any obligation to roll over retirement plan assets to an account managed by McAdam, whether it is from an employer’s plan or an existing IRA. Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by McAdam independent of engaging McAdam as an investment advisor. However, if a prospective client determines to do so, he/she will not receive McAdam’s initial and ongoing investment advisory services. In addition to McAdam’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Portfolio Activity. McAdam has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, McAdam will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when McAdam determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Unaffiliated Private Investment Funds. McAdam also provides investment advice regarding private investment funds. McAdam, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. McAdam’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of McAdam calculating its investment advisory fee. McAdam’s fee shall be in addition to the fund’s fees. McAdam’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation. In the event that McAdam references private investment funds owned by the client on any supplemental account reports prepared by McAdam, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, McAdam shall calculate its fee based upon the latest value provided by the fund sponsor. Structured Notes. McAdam may purchase Structured Notes for client accounts. A Structured Note is a financial instrument that combines two elements, a debt security and exposure to an underlying asset or assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that makes structured products unique, as the payout can be used to provide some degree of principal protection, leveraged returns

(but usually with some cap on the maximum return), and be tailored to a specific market or economic view. Structured Notes will generally be subject to liquidity constraints, such that the sale thereof before maturity will be limited, and any sale before the maturity date could result in a substantial loss. There can be no assurance that the Structured Notes investment will be profitable, equal any historical performance level(s), or prove successful. If the issuer of the Structured Note defaults, the entire value of the investment could be lost. Interval Funds/Risks and Limitations: Where appropriate, McAdam may utilize interval funds (and other types of securities that could pose additional risks, including lack of liquidity and restrictions on withdrawals). An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Therefore, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct McAdam, in writing, not to purchase interval funds for the client’s account. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by McAdam), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. McAdam does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, McAdam shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Cash Positions. McAdam continues to treat cash as an asset class. As such, unless determined to the contrary by McAdam, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating McAdam’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), McAdam may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, McAdam’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion McAdam shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless McAdam reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a McAdam actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any McAdam unmanaged accounts. Direct Indexing. Direct indexing involves constructing a portfolio by purchasing individual securities intended to replicate an intended index or benchmark (e.g., S&P, Dow Jones, Russell 2000). Direct indexing allows for customization of an individual client’s portfolio based upon the client’s personal preferences and investment objectives. Additional benefits also include the potential to implement more effective tax-loss harvesting strategies. For those clients who implement direct indexing as a part of their investment portfolio, their investment adviser will work with them to determine what portion of their portfolio should be allocated to track an index or a blend of indices. McAdam would then invest that portion of the client’s portfolio into individual equities, ETFs and mutual funds with the goal of tracking the desired index or benchmark. Independent Managers. McAdam may allocate a portion of a client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. McAdam shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which McAdam shall consider in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, McAdam’s advisory fee as set forth in the fee schedule at Item 5 below. Non-Discretionary Service Limitations. Clients that determine to engage McAdam on a non- discretionary investment advisory basis must be willing to accept that McAdam cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Therefore, in the event that McAdam would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, McAdam will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, McAdam, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, McAdam will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. McAdam does not recommend or advocate the purchase of, or investment in, cryptocurrencies. McAdam considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. ByAllAccounts and eMoney Advisor Platform. McAdam, in conjunction with the services provided by ByAllAccounts, Inc. and/or eMoney, may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by McAdam (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not McAdam, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, McAdam’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if McAdam is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), McAdam does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If McAdam were asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and McAdam shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that McAdam provide investment management services for the Excluded Assets, the client may engage McAdam to do so pursuant to the terms and conditions of the Investment Advisory Agreement between McAdam and the client. Additionally, the eMoney platform also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by McAdam. Finally, McAdam shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without McAdam’s assistance or oversight. Client Obligations. In performing its services, McAdam shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify McAdam if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising McAdam’s previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that McAdam and its third-party service providers use to provide services to McAdam’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in McAdam’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and McAdam are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although McAdam has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that McAdam does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions.