A. Description of Our Firm. MCA is a Michigan limited liability company that was formed in 2003 and has been in business continuously since then. Our office is located at 630 Kenmoor Ave. SE, Suite 206, Grand Rapids, Michigan 49546. MCA is owned by Henry G. Swain, Michael D. DeSmyter, Jack N. Tunge, Mark R. Satkoski and Jeffrey A. Gietzen. Michael DeSmyter, Mark R. Satkoski, and Jack N. Tunge are principal owners. B. Description of Investment Advisory Services We Offer. General. We provide consulting and investment management services to our clients. We do this through investment adviser representatives. Only our investment adviser representatives are authorized to give investment advice to clients. Information about our investment adviser representatives can be found in the Supplements that are included at the end of this MCA GPS Brochure. MCA GPS Program-Specific. We offer an automated investment program (the “Program”) thorough which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. A client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co.”). We use the Institutional Intelligent Portfolios® platform (“Platform”) offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with or sponsored or supervised by SPT, CS&Co. or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program (including a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis) for clients. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire (“Investor Profile Questionnaire” or “IPQ”) that helps determine the client’s investment objectives and risk tolerance and essentially selects an appropriate investment strategy and portfolio. The Investor Profile Questionnaire will be used to recommend an investment portfolio for clients’ account using the portfolios we constructed within the IIP Program. Initially and at any time when clients have updated their IPQ, the IIP Program will recommend an investment portfolio for their account. Clients will be asked to confirm the recommended investment portfolio. Clients must acknowledge that after they have confirmed the recommended investment portfolio, we, as their adviser, will have the discretion to select a final investment portfolio that is different from the investment portfolio they confirmed. However, we will not exercise that discretion unless (i) you are a wealth management or financial planning client of ours, (ii) an adjustment is necessary or recommended in light of your overall household portfolio allocation, the assets of which are subject to our management, and (iii) we have notified you of any changes we make to the investment portfolio you confirmed. The IIP Program will promptly notify the client of the selection, modification or replacement of the investment portfolio in which their account is invested. Our services are limited to facilitating access to the IIP Program, constructing and maintaining portfolios within the IIP system and recommending an investment portfolio based on your responses to the Investor Profile Questionnaire. Clients may indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio. Typically any such changes are approved, but we make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge our clients a fee for our services as described below under Item 5 - Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does, however, receive other revenues in connection with the Program, including: fund fees; the profit earned by Schwab on the cash portion (the Platform currently requires that be 4% of the total) of each account enrolled in the Program; fees received by Schwab from third-party ETFs that are available under the Program; and market centers where Schwab routes ETF trade orders for execution. We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. Amounts we pay to SPT do not increase the amount of fees we charge to clients enrolled in the Program. We do not receive a portion of a wrap fee for our services to clients through the Program. Unlike non-Program clients, we do not provide financial planning or related services to clients as part of the investment management services that are offered through the Program. Such services, if any, are provided for an additional fee pursuant to the terms of a separate written agreement. Individuals. We assist individuals with the management of their retirement (e.g., IRAs) and non-retirement investment assets. The Investor Profile Questionnaire (“IPQ”) that each client is required to complete (initially as part of the account set-up process and later as and when a client’s circumstances, objectives, time horizons or risk tolerance change) provides assistance and tools that will enable them to formulate an appropriate risk-balanced

allocation that fits their indicated needs, resources and risk tolerance. The IPQ is the primary Program planning tool. The client’s responses to the IPQ result in a recommended portfolio that Program algorithms indicate are most suitable for the client. Each such portfolio is one of an MCA- created risk-managed model allocations, which are combination of equity (e.g., stock investments) and fixed income (e.g., bond investments, cash) ranging from very conservative (substantially all fixed income) to very aggressive (substantially all equity). Tailoring Advisory Services to Client Needs. Before entering into an investment management relationship with a client, we will explain the System and our then-current investment philosophies and strategies, and we encourage each prospective client and client to ask questions. We may change our investment strategies. While we generally advise our clients when these changes are made, we reserve the right to make and implement changes without prior notice or client approval. Each client is required to sign an investment management, financial planning or other agreement that governs the terms of our relationship. Investment management agreements generally give us broad discretionary management authority. See Item 16 - Investment Discretion below for more information on our discretionary authority. Investment management agreements remain in effect until terminated by either us or the client. Either we or the client may terminate the investment management agreement upon fifteen (15) days’ prior written notice to the other. In the event of a termination we will charge a prorated fee based on the number of days that services were rendered during the partial billing period based on the value of the account at the normal month-end closest to the termination date. Upon termination we will have no further responsibilities with respect to the client’s investments. If clients choose to change custodians they will be responsible for paying any transfer fees and charges imposed by the client’s custodian. Each client will open an investment management account by depositing cash (or, if and when permitted by the Program, securities) into a brokerage or other custodial account with CS&Co. Cash (including proceeds of the sale of any permitted securities) will be invested in the recommended portfolio. We are not responsible for any investment losses or tax consequences incurred with respect to the sale of any securities that clients place into their accounts. Clients enrolled in the Program are generally not able to place limitations on what kinds of securities (for example, excluding a specific company’s securities) that may be held in a Program account. Making sure that a strategy is appropriate for and agreed to by a client is a requirement of opening and maintaining an investment account with us. Clients must update their Investor Profile Questionnaire as and when their circumstances change because we and the System do not have any other way of knowing this information. This is important because we and the System need to be able to evaluate if and to what extent the current strategy is still appropriate. We and the System will rely solely upon the information clients provide in the initial and any updated Investor Profile Questionnaire; we will not independently verify the accuracy or completeness of information clients provide. It is the client’s responsibility to complete and submit a new IPQ if and when their financial needs, circumstances or objectives change. Clients will be notified by email of certain changes made to their account, including (a) completion of the portfolio review and selection process for a new account; (b) completion of the portfolio review and selection process in response to a client updating his or her answers to the IPQ; and (c) any changes we make to a client’s existing portfolio. Each client’s portfolio will represent a balance of risk and potential return and have an appropriate amount of asset diversification that is consistent with the client’s objectives and ability to tolerate risk. The Program periodically re-allocates and “re-balances” investment portfolios in light of our then-current investment strategies, market conditions and other factors. A Program client’s portfolio will not necessarily follow the same investment strategy or be made up of the same investments as other clients. There will also be differences between the portfolios of Program clients with similar circumstances and investment objectives due to availability of some investments, when a client becomes a client, when purchases and sales are made and the size of the portfolio. Our investment decisions are driven largely by our applicable strategies rather than the timing of a client’s particular investment or how long a client has held a particular investment. While there are can be exceptions, we generally will purchase, sell and hold securities in a client’s portfolio without specifically considering a client’s other investments and without regard to the specific tax consequences to the client resulting from the sale of an investment. C. Description of Financial Planning Services We Offer. There are no separate financial planning services offered under the MCA GPS Program. Additional financial planning services, if any, are provided and charged for pursuant to the terms of a separate financial planning and consulting agreement that has been signed by the client. The specific nature, extent, timing and other terms of such services and the fees we charge for them are agreed to by each client and are specifically set forth in that agreement. See Item 5 – Fees and Compensation below for more information on fees for financial planning services. Only our investment adviser representatives are authorized to provide financial planning services to clients. D. Wrap Fee Programs. We do not currently participate in any so-called “wrap fee programs.” More information about our practices with respect to brokerages can be found in Item 12 - Brokerage Practices below. E. Discretionary Assets Managed. As of December 31, 2023, the amount of client assets we manage was approximately $778,827,245 on a discretionary basis and approximately $168,476,821 on a non-discretionary basis, for a total of approximately $947,304,066. The amount of client assets we managed under the MCA GPS Program was approximately $ 7,064,814.