MAI Capital Management

Introduction MAI is an investment adviser registered with the SEC and headquartered in Cleveland, Ohio. The Firm was initially established as Investment Advisors International, Inc. ("IAI") in 1973 and was an affiliate of International Management Group ("IMG"). In 2000, McCormack Advisors International, LLC ("McCormack") was formed to succeed IAI's business as a joint venture between IAI and a major integrated financial institution. In 2002, the joint venture was dissolved, and the Firm returned to its roots as a provider of independent financial advice to clients. McCormack became fully independent of IMG in 2004. In January 2007, BC Investment Partners, LLC acquired McCormack and renamed the merged firm MAI Wealth Advisors, LLC. In October 2014, the Firm was renamed MAI Capital Management, LLC. Until September 30, 2021, MAI was controlled by its Managing Partner, Richard J. Buoncore. On September 30, 2021, MAI became an indirect subsidiary of MAI Capital Management Holdings LLC (“MAI Holdings”). MAI Holdings was, until June 4, 2026, a majority-owned indirect subsidiary of Galway Series 2 Aggregator LP. Effective June 4, 2026, The Carlyle Group Inc. (“Carlyle”), together with its affiliated entities, acquired a majority equity stake in MAI indirectly through Runway Holdings Topco, L.P. In connection with this transaction, Galway Series 2 Aggregator LP ceased holding any interest in MAI Holdings. Mr. Buoncore continues to serve as Chief Executive Officer of MAI and as a board member of the general partner of Runway Holdings Topco, L.P.

Advisory and Related Services Investment Management Services MAI provides discretionary and non-discretionary investment management to individuals, high-net-worth and ultra-high-net-worth individuals and families, and institutions. Services include:

assisting the client with the establishment of their investment objectives and investment policy statement;

buying and selling securities such as stocks, bonds, mutual funds, exchange-traded funds, and private and public limited partnerships, and

reporting holdings, transactions, and performance on the client's investment portfolio.

MAI also assists clients with developing their asset allocation strategy, portfolio manager selection, managed account programs, and advice concerning outside holdings. We discuss our discretionary authority below under Item 16 - Investment Discretion. For information about the restrictions clients can put on their accounts, see Tailored Services and Client-Imposed Restrictions in this item below. We describe the fees charged for investment management services below under Item 5 - Fees and Compensation. Client portfolio management is customized, subject to the client's experience and comfort with particular investment strategies, classes, and products, as well as the discretion that portfolio and wealth managers are given to manage client portfolios, their experience, and their investment background. Clients, as applicable, can also access selected investment management services through certain

unaffiliated third parties under a sub-advisory relationship. These services are offered on unified managed account platforms or as separately managed accounts, as described below under Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss. The fees MAI receives under these arrangements are described below under Item 5 - Fees and Compensation.

Wrap Fee Programs MAI also manages a limited number of accounts in wrap fee programs sponsored by other financial services firms. MAI is involved in wrap fee accounts through dual contract arrangements with Stifel, Nicolaus & Company, Inc., and NBC Securities. The client signs an agreement with an unaffiliated brokerdealer and MAI in a dual contract arrangement. The client pays the MAI management fee and the "wrap fees" the sponsor charges. MAI does not receive a portion of the wrap fees the client pays to the wrap sponsor. Payment of advisory fees to MAI and wrap fees to the sponsor will increase overall costs. Therefore, performance will differ in these "wrap fee" arrangement portfolios compared to other managed portfolios. MAI chooses investments and manages clients' accounts in the wrap fee program similarly to other client accounts that we manage using similar strategies. However, because wrap fee programs are often offered by or connected to a broker-dealer, we will use that broker-dealer when placing trades for those accounts. If we used a different broker, that broker might charge the client additional transaction costs, which they already pay under the wrap fee. Our trading practices, described below under Item 12 - Brokerage Practices, will also affect wrap fee clients.

Unified Managed Account (“UMA”) Programs MAI provides non-discretionary advice in unified managed account programs ("UMA Programs"). MAI offers model portfolios for a fee to UMA Program sponsors. Those sponsors use MAI's model portfolios as one input in developing their investment recommendations and managing their clients' accounts. MAI's recommendations to UMA Programs sometimes differ from those to other client accounts. MAI provides the UMA Program sponsor with recommendations on the securities to be purchased, sold, and held in the model portfolio and the percentage of the model portfolio that would be invested in each security. MAI provides this information to the UMA Program sponsor per procedures described in "Trade Rotation" under Item 12 - Brokerage Practices. UMA Program sponsors typically have sole discretion over their clients' accounts. The UMA Program sponsor decides whether to implement MAI’s recommendations.

Adviser to Mutual Fund MAI is also the investment adviser to the MAI Managed Volatility Fund (MAIPX/DIVPX), an open-end mutual fund that is part of the Forum Family of Funds. The fund is registered under the Investment Company Act of 1940. MAI is not affiliated with Forum Funds.

Adviser to Private Funds MAI is also an investment adviser to private funds. See Item 6 - Performance-Based Fees and Sideby-Side Management for a list of funds for which MAI charges a performance-based fee and Item 10 Other Financial Industry Activities and Affiliations for a list of private funds for which MAI is an investment manager and for which MAI owns the general partner.

Investor terms may vary and, where applicable, are disclosed in the relevant Limited Partner’s Fund Documents. Generally, MAI avoids investor-specific terms and conditions, including side letters. Any request for special terms must be reviewed and approved by MAI’s Chief Investment Officer, General Counsel, and Chief Compliance Officer before such terms are granted.

Wealth Management Services In addition to providing investment advice and advisory services, MAI provides wealth management services and certain non-advisory services to clients. In addition to investment management, these services can include estate and financial planning, advice on tax strategies, use of margin or securitiesbased loans, insurance, and wealth transfer planning. MAI also prepares United States federal, state, and local tax returns, record keeping, administration of partnership interests and private investments, household management, budgeting and forecasting, and coordination of bill-pay and payroll services for household or client corporation employees. We describe fees for wealth management services below under Item 5 - Fees and Compensation.

Tailored Services and Client-Imposed Restrictions MAI manages accounts based on the client's circumstances, financial situation, investment objectives, and goals, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. If the client has a discretionary account, we make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our recommendations depend on the current, accurate, and complete information the client provides. The client is responsible for informing MAI of any changes to their investment objectives or restrictions and client information. Clients can request other restrictions on the account, such as when they need to keep a minimum level of cash in the account or want MAI to avoid buying or selling particular securities or security types. MAI reserves the right not to accept and terminate management of a client's account if we feel that the clientimposed restrictions would limit or prevent us from meeting or maintaining the client's investment strategy. MAI manages pooled investment vehicles according to the fund's investment objectives. Investors in a pooled investment vehicle cannot place restrictions on the fund.

Retirement Account Advice - Individuals MAI provides investment advice to clients regarding their retirement plan account or individual retirement accounts (“IRAs”). When MAI manages investments in an IRA on an ongoing basis, MAI acts as a fiduciary under the Internal Revenue Code (“IRC”) and is subject to the prohibited transaction rules of IRC Section 4975. When MAI recommends a rollover of retirement plan assets to an IRA, MAI acts as a fiduciary under ERISA and/or the IRC only where: (1) MAI already serves the plan as an investment fiduciary under ERISA Section 3(21) or 3(38) and recommends that a participant roll over assets to an MAI-managed IRA; or (2) MAI already provides individualized investment advice to a participant regarding their plan balance and MAI’s compensation would increase as a result of the rollover. Where neither circumstance applies, MAI does not act as a fiduciary under ERISA or the IRC to the extent the Department of Labor’s

1975 five-part test is not satisfied, and such recommendations are governed by MAI’s fiduciary duties under the Investment Advisers Act of 1940 and applicable SEC guidance. In all cases, MAI will disclose in writing when it is acting as an ERISA or IRC fiduciary in connection with a specific rollover recommendation. Recommending a rollover to an MAI-managed IRA creates a potential conflict of interest, as it may increase the total advisory fees paid to MAI. No client is under any obligation to roll over retirement plan assets to an account managed by MAI. When MAI acts as a fiduciary with respect to a rollover recommendation, and where needed, MAI relies on U.S. Department of Labor Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) or other available exemptions to receive compensation. The way we make money creates conflicts with your interests. Therefore, where PTE 2020-02 applies, MAI adheres to its conditions. Specifically, we must:

meet a professional standard of care when making investment recommendations (give prudent advice);

never put our financial interests ahead of yours when making recommendations (give loyal advice);

avoid misleading statements about conflicts of interest, fees, and investments;

follow policies and procedures designed to ensure that we give advice that is in your best interest;

charge no more than is reasonable for our services, and

give you basic information about conflicts of interest.

MAI Retirement - Plan Level MAI Retirement, a division of MAI, provides retirement plan consulting and services to corporate retirement plans. MAI Retirement serves either as the plan's investment adviser under §3(21) of ERISA (we recommend investment decisions for approval by the plan's named fiduciaries) or as the plan's investment manager under §3(38) of ERISA (we manage the plan's investment decisions on a discretionary basis). Regardless of the capacity in which MAI serves as the adviser, the plan's named fiduciaries or the plan sponsor may impose restrictions on the types of investments held by or offered through the plan. In addition, MAI Retirement does not generally provide advice concerning shares of employee stock held in the plan.

Non-Advisory Services MAI Trust Administrative Services MAI provides trust administrative services and corporate trustee services to our clients through MAI Trust Company, LLC, a wholly owned subsidiary of MAI and a South Dakota limited liability company. MAI Trust Company is a South Dakota chartered trust company.

MAI Family Office Services MAI also provides family office services including consulting, philanthropy and private foundation administration, tax preparation, risk management oversight and client accounting and bill-pay services. These services can be integrated with a combination of other services or provided independently, without wealth management services.

Insurance Administration Affiliated and unaffiliated insurance brokers provide insurance administration services to MAI clients. MAI Insurance Solutions, LLC (“MAI Insurance”) is a wholly owned subsidiary of MAI that provides insurance administration services. This is further described in Item 10 - Other Financial Industry Activities and Affiliations.

Unmanaged Assets MAI does not perform any investment monitoring or have allocation responsibility for unmanaged assets and/or accounts. The client and/or their other investment professionals retain exclusive responsibility for the monitoring and performance of such assets and/or accounts. These assets are included solely for reporting purposes and are not treated as assets under management unless MAI provides continuous and regular supervisory or management services with respect to those assets. Non-managed assets, which can include securities held in a client’s account that is under management with MAI, include assets that were:

delivered into the account by the client;

purchased by the client or purchased by MAI at the request of the client as an accommodation; or

designated by the client to be non-managed securities by written notification.

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Fee Schedules MAI negotiates and charges different fees for certain accounts based on the client's needs, services, and circumstances. MAI clients obtained from acquisitions may be invoiced for a higher or lower fee than an existing MAI client. MAI also manages employee and related accounts for a reduced fee. Fee or billing arrangements are detailed in the client agreements, and any fee changes are reflected in a fee addendum. As a result, clients may pay different fees for similar services, and billing practices may differ based on negotiated arrangements, legacy arrangements, acquired relationships, or the scope and complexity of services provided.

Advisory Services Discretionary or Non-Discretionary Portfolio Management Fees Fees for portfolio management services are negotiable and outlined in your advisory agreement and fee schedule. They may be structured as a percentage of assets, a flat fee, a retainer, or another arrangement. For asset-based fees, rates are client-specific and can be tiered. Cash holdings may be included in the fee calculation, as specified in your agreement. Clients may pay advisory fees on cash even when cash earns a lower return than other investments or when cash is held for liquidity, allocation, or accommodation purposes. This creates a conflict because MAI earns more advisory fees when cash is retained in a fee-billed account than when cash is distributed or excluded. Unless a client agreement states otherwise, assets that MAI treats as non-managed or reporting-only are excluded from MAI's advisory fee calculation. If a client agreement includes any non-managed or reporting-only asset in the fee base, the agreement or invoice will identify that treatment. Customized arrangements with clients can include negotiated fees for clients with a service package, including investment advice, wealth management, and other non-advisory services such as bill-pay or income tax preparation. Generally, MAI's policy is to round account and fee values to the nearest dollar when invoicing clients. A limited number of clients are parties to "wrap fee" arrangements that they have arranged with brokers. The client pays MAI our investment management fee and the "wrap fees" charged by the wrap program sponsor. Paying investment management fees to MAI and wrap fees to the sponsor will increase overall costs. Therefore, performance will differ in these "wrap fee" arrangement portfolios compared to other managed portfolios. MAI charges UMA Program sponsors an annual fee, typically calculated and payable quarterly (in advance or in arrears per the sponsor's standard provisions), based on the assets using a particular investment strategy. However, the fee amount varies depending on the sponsor's total assets under management. In some instances, MAI uses the services of third-party investment managers (sub-advisers) to manage MAI client assets. When appropriate and in the client's best interest, MAI will allocate a portion of the

client's portfolio to the sub-adviser for management. While the client's portfolio is invested with another manager, MAI has a committee to monitor the sub-adviser's performance and assess external organizational and product-level changes. The client will pay fees associated with client portfolios managed in whole or in part by a sub-adviser. In some cases, the fees charged under a sub-adviser arrangement are greater than those charged if a sub-adviser is not managing the account. MAI allocates assets to private investments where it is not the fund sponsor. In many cases, the valuations received by MAI will be estimated valuations. The estimated valuation is adjusted to the actual value when it is received by MAI, which can change the information reported. MAI will use the estimated valuation provided by the fund sponsor to calculate the quarterly management fee. If the current valuation is unavailable to the extent applicable, the previous quarter-end valuation will generally be used to calculate the fee. Such valuations are subject to adjustment in the next quarter based on available valuation information if the adjusted fee amount (whether higher or lower) is greater than five percent of the estimate. Typically, adjustments are not made to reflect new valuation information that becomes available to MAI at a date later than as described above. However, MAI will make such adjustments in its sole discretion. Private investment valuations involve judgment and uncertainty and may not reflect the price at which an arm’s-length buyer or seller would transact. Because these values may be used to calculate advisory fees, valuation practices present a conflict of interest. MAI seeks to address this conflict by relying on valuations from fund sponsors, managers, administrators, custodians, or other third-party sources when available and through its review processes. For MAI-sponsored or MAI-managed Funds, MAI or its affiliates may have responsibility for or influence over valuation inputs, review, or approval. Because valuations may affect management fees, performance-based fees or carried interest, reported performance, and investor communications, MAI has a conflict of interest. MAI addresses this conflict through valuation governance, including the valuation committee, the fund administrator, the auditor, and a written valuation policy, as applicable to each Fund.

MAI as Sub-Adviser MAI is a sub-adviser to third-party advisers and is compensated for these services. The annual fees MAI receives for our services through third-party sub-advisory relationships vary based on the program, minimum investment requirements, and asset levels and will typically be at or lower than our standard fee rate. The fees we receive for providing investment management services do not include other fees charged by the third-party adviser to the client. Fees under these programs are billed in arrears or in advance, and MAI is paid by the third-party adviser or directly by the client, depending on the program. Clients using MAI as a sub-adviser through third-party advisers can terminate our management services per the terms in the agreement, which vary by program.

MAI Trust Administrative Services If you utilize our Trust Administrative Services, you will be charged a separate fee for these services by MAI Trust Company, LLC. These fees include a setup fee and an ongoing fee, which can be a flat fee or AUM-based fee.

Limited Liability Company and Limited Partnership Fees MAI serves as an investment manager to certain investment-related limited liability companies and limited partnerships (each a “Fund”). Where the Fund has an investment management fee, all assets invested in the Funds by MAI clients are excluded from the value of the client's account to calculate MAI's discretionary or non-discretionary investment management fees. MAI receives investment management fees from most of the Funds we advise. The Fund pays these fees, but they are borne by its members or limited partners. Each Fund's operating agreements and related documents set the applicable investment advisory fees. As noted in each Fund’s private placement memorandum (“PPM”), MAI receives an annual asset-based management fee from the Funds. These fees are typically capped at 1.5 percent. For many of the Funds, MAI charges performance fees as further described in Item 6 - Performance-Based Fees and Side-by-Side Management.

Billing Method Fees for discretionary or non-discretionary investment management are billed directly to client accounts when clients authorize MAI to receive payment directly from their custodians. Clients can designate one or more accounts from which they instruct the custodian to deduct the fee. Clients will receive statements from the custodian no less frequently than quarterly but often monthly. The custodian statement will show the advisory fee deduction for clients who authorize the advisory fees to be withdrawn directly from their custodian account. MAI will send an invoice to all clients who choose not to have advisory fees withdrawn directly from their custodian account and for any annual retainer fees or fees associated with other services. The invoice is payable upon receipt and will include the fee calculation and amount due. Under certain circumstances, an invoice is sent to the client notifying them of the direct debit related to their planning fees. In these cases, clients authorize their financial institution to remit payment for the invoice amount. MAI’s investment management fees are payable quarterly in arrears or in advance at the beginning of each calendar quarter. Generally, we charge one-fourth of the annual fee rate each quarter based on the market value of the client's portfolio on the last day of the prior calendar quarter. MAI pro-rates investment management fees for partial quarters. For a limited number of clients, MAI will charge on the number of days in a period as opposed to one-fourth of the annual rate. If you utilize a margin account, MAI will include the entire market value (total assets long) of the margin asset when computing its advisory fee. For accounts with long-short SMAs, MAI will calculate fees on the net exposure. For accounts terminating, MAI will calculate the fees due at termination and either debit the account for the fees due or send an invoice, depending on the payment method for accounts paying in arrears. For those terminating and utilizing the advance billing method, MAI will refund the balance paid pro-rata based on the number of days MAI investment management services were billed in advance but were not provided.

While the fees vary, the established fee for investment management services is charged based on a percentage of the client's assets under management ("AUM") per the following schedule: Investment Management Blended Asset Allocation

AUM

Annual Fee Rate

First $5MM Next $5MM

1.00% 0.90%

Over $10MM

0.80%

MAI negotiates fees at its discretion, resulting in clients under different fee schedules. The billing methods for the MAI private funds are outlined in each fund’s PPM.

Adviser to Mutual Fund The fees MAI receives for providing investment management services to the MAI Managed Volatility Fund (MAIPX/DIVPX) are outlined in the written advisory agreement for the Fund. The fees are disclosed and described in the Fund’s prospectus. When MAI allocates shares of the MAI Managed Volatility Fund to our clients, MAI will exclude those shares from being billed in the client’s investment account. MAI will only receive compensation as an investment adviser to the Fund.

Wealth Management Services For our integrated wealth management services, MAI fees are determined client-by-client. Our fees depend on several factors, including the number and range of wealth management and related services we provide and the complexity of the client's financial situation. Depending on the client’s needs, MAI offers an annual retainer for financial planning, tax, bill-pay, and other wealth management services. Annual retainers are negotiable based on the scope, complexity, staffing needs, and services provided. Retainers are billed as stated in the client agreement. For investment management, we charge a fee based on assets under management. We work with each client to set the specific fees and payment schedule.

Other Fees and Expenses MAI's fees for investment management do not include custodian fees. Clients pay all brokerage commissions, stock transfer fees, margin interest and fees, and other similar charges incurred in connection with account transactions from the assets in the account. These charges are in addition to the client fees paid to MAI. See Item 12 - Brokerage Practices below for more information. Note, however, that clients using MAI investment management services as part of a Wrap Fee Program pay a comprehensive “wrap fee” that includes custodial fees, brokerage commissions, stock transfer fees, margin interest and fees, and other similar charges incurred. When MAI Insurance, a wholly owned subsidiary of MAI, provides insurance administration services, clients will not incur additional fees. MAI Insurance earns commissions on insurance products separate from and in addition to the fees you pay to MAI.

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Equities - primarily utilizes fundamental analysis, principally with respect to management record, financial condition, profitability levels, growth prospects, and market price relative to historical valuation ranges, as well as total return (current yield plus anticipated capital appreciation). Technical analysis is sometimes used as a secondary valuation tool.

Exchange-Traded Funds - reviews index methodology, tracking error, trading liquidity, and expenses.

Fixed Income Investments - considers the issuer's financial strength, interest rate risk, call provisions, liquidity factors, M&A risk, and bond insurance when selecting bonds for purchase.

Mutual Funds - reviews key characteristics such as historical performance, consistency of returns and style characteristics, risk level, and fund size. Expense ratio and other costs are also significant factors in fund selection.

Options - utilizes various strategies (covered options, uncovered options, or option spreads) that meet the needs of our investor base.

Private Investments - Direct and Private Funds - considers the quality of the leadership/management team, the fundamental strength of the thesis, including risk and return potential, and the advantages/disadvantages of the structure, including management fees, carried interest, liquidity, time horizon, and other investment/fund expenses.

Structured Notes - considers the financial strength of the issuer, the risk and return parameters of the note, liquidity, and costs, as well as the characteristics of the underlying index or indices.

Methods of Analysis - Separate Account Managers

Separate Account Managers - reviews critical characteristics such as historical performance, consistency of returns and style characteristics, trading costs, tax efficiency, management fees, legal and operational quality, and management team tenure.

Methods of Analysis - Financial Planning The financial planning tool MAI uses to create financial plans for clients relies on various assumptions, such as inflation estimates, risk, economic conditions, and rates of return on security asset classes. All return assumptions use asset class returns, not returns of actual investments, and do not include fees or expenses that clients would pay if they invested in specific products. The asset classes are represented by broad-based indices selected because they are well-known and easily recognizable by investors. Indices have limitations because they have volatility and other material characteristics that can differ from an actual portfolio. The financial planning tool is used as a guide to help MAI and the client develop an appropriate plan, and

we cannot guarantee that clients will achieve the results shown in the plan. Results will vary based on the information provided by the client regarding the client's assets, risk tolerance, and personal information. Changes to underlying assumptions or differences in actual personal, economic, or market outcomes can result in materially different results for the client. Clients should carefully consider the assumptions and limitations of financial planning tools. They should discuss the results of the plan with a qualified investment professional or a financial planning professional before making any changes in their investment or financial planning program.

Sources of Information MAI analyzes securities using information obtained from various sources, including annual reports and Forms 10-K and other public filings, financial periodicals, financial rating services, management interviews, corporate news releases, industry participants, government statistical information, prospectuses and research information of major brokerage houses and independent firms, and investment software programs. MAI subscribes to Morningstar and Zephyr Analytics to stay current on fund information and data. Conference calls, manager updates, and in-person meetings with the sub-adviser provide insights into our due diligence process. MAI uses credit rating agencies such as Standard & Poor’s and Moody’s to help determine the financial strength of issuing creditors and subscribes to independent research. Prospectuses, financial statements, and other relevant information from bond underwriters are used to analyze and select fixed-income securities.

General Investment Strategies MAI strives to treat each client account uniquely, seeking real () capital growth proportionate to the level of risk suitable to the client. MAI uses an investor identification and profile questionnaire to document the client's investment objectives, time horizon, risk tolerance, tax considerations, and any special considerations and restrictions the client chooses to place on managing the account. MAI will then make recommendations that are consistent with the client's investment objectives. MAI selects suitable categories of investments based on the client's attitudes about risk and their need for capital appreciation or income. Different instruments involve different levels of risk exposure. Within each investment category, MAI selects securities with characteristics most consistent with the client's objectives. We deal with any client restrictions on an account-by-account basis. Client portfolios with similar investment objectives and asset allocation goals have different securities with similar characteristics. Timing and tax factors also influence MAI's investment decisions. Clients who buy or sell securities on the same day may receive different prices. Additionally, the timing of securities purchases and sales can differ depending on the timing of each portfolio/wealth manager's decision to implement changes in the portfolio. MAI primarily seeks to hold securities for the longer term, especially in taxable accounts. MAI uses shortterm trades and options less frequently and only when, in MAI's judgment, they are appropriate for a particular account or given market condition. Different option strategies include covered options, uncovered options, or option spreads, based on the account's needs. Option strategies may involve

leverage. Frequent trading can result in higher taxes and transaction costs, and there is a risk of principal loss associated with option strategies. Some MAI clients maintain margin accounts. Accordingly, margin is occasionally used to implement investment advice given by MAI to these clients. Clients are responsible for any brokerage or margin charges. Additionally, MAI can recommend third-party investment advisers to manage all or a portion of the client's portfolio, depending on the client's investment objectives and financial situation. MAI can also recommend private funds and private placements for clients who meet net worth or other accreditation requirements and have a sufficiently high-risk tolerance.

Specific Investment Strategies MAI invests client assets using one or a combination of distinct investment strategies, which we detail here:

Defensive Income Portfolio - seeks to build an actively managed portfolio of predominantly large capitalization U.S. equities seeking to provide a higher yield, and lower volatility vs. equity markets overall, as measured by the S&P 500 Index. Investments are primarily selected based on their yields, investment-grade balance sheets, and their defensiveness in down markets. It is a concentrated portfolio of 25-35 U.S. equities that feature a high degree of overlap with other proprietary MAI strategies.

Core Growth Strategy - attempts to maximize long-term total returns by investing in businesses that exhibit economic, structural, or competitive advantages. The strategy focuses on companies that demonstrate strong capital management and have produced high returns on invested capital (ROIC), profitability, and returns on equity. The strategy is diversified across sectors, industries, and end markets. The portfolio has the flexibility to invest in foreign companies trading on U.S. exchanges including through ADRs.

Dividend Strategy - we select securities for our Dividend Strategy from a global universe of dividend-paying stocks trading in the U.S. We screen for desired dividend characteristics that indicate management's commitment to increase dividends over time. We review those securities for factors such as return on equity and relative valuation, as well as factors that will affect their ability to increase their dividend in the future, such as revenue, earnings, cash flow expectations, and balance sheet strength. The portfolio is diversified across thirty to fifty stocks with no more than thirty percent invested in any one industry, no more than forty percent invested in foreign companies through ADRs and is expected to hold less than ten percent cash except under extraordinary economic or market conditions.

Diversified Dividend Strategy - this strategy looks to invest in equities in a diversified manner based on MAI's outlook on the various segments of the market. The strategy will typically hold a combination of U.S. and foreign stocks and stock funds in the mid-cap, small-cap, international developed, and emerging market sectors. The individual stock component of the portfolio will be primarily invested in the Dividend Strategy.

Diversified Focused Equity Strategy - this strategy invests in diversified equities based on MAI's

outlook on the various market segments. The strategy will typically hold a combination of U.S. and foreign stocks and stock funds in the mid-cap, small-cap, international developed, and emerging market sectors. The individual stock component of the portfolio will be primarily invested in the Focused Equity Strategy.

Diversified Select Equity Strategy - this strategy looks to invest in diversified equities based on MAI's outlook on the various market segments. The strategy will typically hold a combination of U.S. and foreign stocks and stock funds in the mid-cap, small-cap, international developed, and emerging market sectors. The individual stock component of the portfolio will be primarily invested in the Select Equity Strategy.

Focused Equity Strategy - this strategy seeks to identify companies that can sustain high returns on invested capital. It is designed to deploy capital in these investments at discounted entry prices to reduce risk and increase long-term returns. The strategy's investment criteria limit the number of potential investments, resulting in a concentrated portfolio of fifteen to thirty investments.

Fixed Income - Tax Exempt - we focus on building a portfolio of investment-grade securities, such as municipal bonds, with a laddered maturity schedule. The portfolio can be customized to emphasize state of residence but will maintain national diversification. The goal of the strategy is capital preservation and predictable, tax-exempt income streams.

Fixed Income Taxable - we purchase a portfolio of taxable investment-grade bonds with a laddered maturity schedule. The portfolio can include corporate bonds, taxable municipals, or other taxable securities. MAI seeks to diversify corporate issues by sector/industry to mitigate credit risk. The goal of the strategy is capital preservation and predictable income streams.

ETF Strategies - we offer these strategies to implement Equity, Growth, Total Return, Conservative, and Income asset allocations in liquid, diversified, cost- and tax-efficient portfolios. This approach combines the MAI Investment Committee's tactical asset allocation framework with low-cost implementation, primarily using ETFs. The strategies are rebalanced regularly to ensure consistency with their respective objectives.

High Income Equity Strategy - this strategy seeks to balance three goals: safety, income, and capital appreciation. We strive to accomplish this by investing in high-quality dividend stocks that have durable competitive advantages and can support returns above the firm’s cost of capital. Additionally, we will invest in fixed-income securities to both augment the income of the portfolio as well as potentially lower its volatility. We believe this approach can produce a portfolio with low volatility, above average income, and the potential for capital appreciation over time. The portfolio is diversified across sectors and typically holds twenty-five to thirty-five securities with an average holding period of two to three years.

Select Equity Strategy - an actively managed portfolio of large capitalization U.S. equities seeking low tracking error vs. the S&P 500. Investments are selected based on their S&P 500 subsector classification, earnings growth potential over the next three to five years, and current valuation. The portfolio is diversified across the twenty-four S&P 500 subsectors and typically owns forty to fifty U.S. issuer equities.

Investment Funds MAI serves as the investment manager for the funds listed under Item 6 - Performance-Based Fees and Side-by-Side Management and as the investment manager or GP to certain investment-related limited liability companies as listed in Private Funds in Item 10 - Other Financial Industry Activities and Affiliations.

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Types of Clients MAI provides investment, advisory, and wealth management services to several client groups (as described in Item 4 - Advisory Business), including:

individuals, high-net-worth (“HNW”) and ultra-HNW individuals (“UHNW”);

families and family offices;

sports professionals; trusts, and

institutions, including pension and profit-sharing plans, employee benefit plans, endowments, foundations, trusts, and other entities such as corporations (primarily S corporations), and investment-related limited liability companies and limited partnerships managed by MAI.

Account Suggested Minimums MAI suggests a minimum of $500,000 to establish an investment management account. MAI will accept accounts below the suggested minimum for wealth management clients who establish a managed account. In our composite construction criteria for reporting the performance of individual investment strategies, MAI will set a lower minimum. For full-service wealth management and investment management services, MAI suggests a net worth of at least $1,000,000 and a current income of at least $150,000. Investors should refer to the subscription documents for minimum amounts related to the LLCs and the private partnerships because net worth requirements and minimums will vary and may be higher based on regulatory requirements.

MAI charges a performance-based fee for the following funds:

MAI Wealth Private Equity Fund, LP;

MAI Opportunity Fund, LP;

MAI Diversified Real Estate Income Fund, LP;

MAI Diversified Real Estate Income Fund II, LP;

MAI Diversified Real Estate Income Fund III, LP;

MAI Lending Fund, LP;

MAI Wealth Income & Growth Fund, LP;

MAI Capital Income and Growth Fund II, LP;

MAI Capital Income and Growth Fund IV, LP;

MAI Capital Income and Growth Fund V QC, LP;

MAI Capital Income and Growth Fund V QP, LP;

MAI Capital Income & Growth Fund VI QP, LP;

MAI Capital Income & Growth Fund VI QC, LP;

MAI Capital Income & Growth Fund VII, LP;

MAI Glade Brook Venture Fund, LP;

MAI Solamere Private Equity Fund, LP;

MAI Capital GP Staking Fund, LP;

MAI Capital GP Staking Fund Feeder, LP;

MAI Capital Secondaries Infrastructure Solution, LP;

MAI Capital Sports & Entertainment Seeding Fund, LP;

MAI Avenue Sports Fund, LP;

MAI Capital Otro Sports Fund, LP;

MAI Solamere Leaders IV Fund;

MAI Affordable Housing;

MAI Capital Stargate Access Fund, LP;

Intersect Ventures II, LLC;

Intersect Ventures III, LLC;

Intersect Ventures IV, LLC;

Intersect Ventures V, LLC;

Intersect Ventures VII, LLC;

Intersect Ventures VIII, LLC;

Intersect Ventures IX, LLC;

Intersect Ventures X, LLC; and

Intersect Ventures XIV, LLC.

In certain circumstances, at MAI’s discretion, performance fees are waived. MAI does not charge performance-based fees for any other account or strategy. Managing accounts under different fee arrangements creates a conflict of interest. Performance-based fee arrangements can create conflicts of interest for portfolio managers. Fee waivers, reduced fees, or different performance-fee terms create conflicts because MAI may have an incentive to favor accounts or investors that pay higher fees or participate in vehicles that generate carried interest or performance-based compensation. MAI addresses these conflicts through allocation policies, supervisory review, and documentation of investment allocations and fee arrangements. Performance-based fee arrangements may also create incentives for portfolio managers to:

allocate investment opportunities that they believe might be the most profitable to performancebased fee accounts, and

make investments with more risk or that are more speculative than those they might recommend under a different fee arrangement.

MAI has adopted policies and procedures reasonably designed to address these conflicts. Specifically, the policies and procedures are designed to allocate investment opportunities between accounts fairly and equitably over time and prevent unsuitable investments and overconcentration of investments in client accounts.

Ownership and Carlyle Affiliation Effective June 4, 2026, certain investment funds managed by affiliates of Carlyle acquired a majority equity stake in MAI indirectly through Runway Holdings Topco, L.P. As a result of this ownership structure, MAI is affiliated with Carlyle and its affiliates. If MAI recommends or makes available products, services, or investment opportunities involving Carlyle or its affiliates, MAI has a conflict of interest because MAI has an incentive to favor affiliated opportunities over unaffiliated alternatives. MAI addresses these conflicts through disclosure, policies and procedures, supervisory review. If MAI recommends, allocates to, or makes available any Carlyle-related product or opportunity, Carlyle and/or its affiliates may receive management fees, performance allocations, carried interest, transaction fees, monitoring fees, financing fees, administrative fees, or other compensation. MAI has an incentive to recommend those affiliated opportunities, and MAI's owners may indirectly benefit from the revenues or enterprise value generated by the Carlyle affiliation. MAI will evaluate any such recommendation under its fiduciary obligations and provide additional product-specific disclosure where applicable.

Management Company Effective January 1, 2010, a management company named MAI Wealth Management, Inc. ("MAIW") was created. The company was formed to house all employees and to pay their salaries and benefits. A management agreement exists between MAIW and MAI in which MAI pays MAIW for the various services the employees provide. MAI is a registered investment adviser.

Adviser to Mutual Fund MAI Capital Management, LLC is the investment adviser to the MAI Managed Volatility Fund (MAIPX/DIVPX). This open-end mutual fund is part of the Forum Family of Funds (“Forum”) and is registered under the Investment Company Act of 1940. MAI is not affiliated with Forum. MAI may allocate shares of the MAI Managed Volatility Fund to clients. In this case, MAI will exclude those shares from being billed on the portion of the investment account invested in the Fund and will only receive compensation as an adviser to the Fund.

Registered Investment Adviser Evoke is an SEC-registered investment adviser and a wholly owned indirect subsidiary of MAI Capital Management, LLC. Evoke provides holistic and personalized financial planning and discretionary and non-discretionary investment advisory services to individuals, including high-net-worth and ultra-high-networth individuals, and entities, including, but not limited to, family offices, trusts, and estates. Evoke also offers consulting and advisory services to pension and retirement/profit-sharing plans, pooled investment vehicles, foundations, endowments, charitable organizations, guilds, and health plans, investment companies, family offices, corporations, and other business entities. Some of Evoke’s employees are dually registered with MAI because they will advise on investment advisory business for MAI. Evoke is affiliated with various entities that serve as sponsors or index providers for proprietary ETFs and private funds. MAI serves as the fund sponsor to RPAR Risk Parity ETF and UPAR Ultra Risk Parity ETF.

Each of these ETFs is listed on the NYSE. MAI and its affiliates receive compensation from these entities, which creates a conflict of interest when recommending affiliated products. MAI has adopted policies and procedures to mitigate these conflicts, including disclosure and periodic review.

Trust Company MAI Trust Company, LLC, is a wholly owned subsidiary of MAI and a South Dakota limited liability company that provides trust administrative services to our clients. MAI Trust Company is a South Dakota chartered trust company.

Insurance Agency Affiliated As part of MAI's overall investment and wealth management services, your MAI adviser may use MAI Insurance to conduct and facilitate insurance reviews. MAI Insurance is a wholly owned subsidiary of MAI. MAI Insurance earns commissions on insurance products separate from and in addition to the fees you pay to MAI. The ownership relationship between MAI and MAI Insurance presents a potential conflict of interest; however, obtaining services from MAI Insurance will not result, directly or indirectly, in the payment of any greater or lesser investment advisory fees or expenses assessed by MAI to its investment advisory clients. MAI is aware of this conflict and will always put your interests ahead of its own. You are never required to purchase any product recommended through the affiliated services.

Unaffiliated MAI may also look to the services of other unaffiliated insurance brokers to conduct reviews and make recommendations. When using other insurance brokers, MAI receives no commission or other remuneration from the sale of any insurance product other than MAI Insurance.

Private Funds MAI is an investment manager and/or GP to certain investment-related limited liability companies and limited partnerships listed below:

MAI Wealth Private Equity GP, LLC, a Delaware limited liability company, is the GP of MAI Wealth Private Equity Fund, LP. The GP is managed by Richard J. Buoncore of MAI and the principals of Cerity Partners LLC.

MAI Wealth Opportunity GP, LLC, a Delaware limited liability company, is the GP of MAI Opportunity Fund, LP, and is managed by Richard J. Buoncore of MAI.

MAI Diversified Real Estate Income GP, LLC, a Delaware limited liability company, serves as the GP of MAI Diversified Real Estate Income Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Diversified Real Estate Income II GP, LLC, a Delaware limited liability company, serves as the GP of MAI Diversified Real Estate Income Fund II, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Diversified Real Estate Income III GP, LLC, a Delaware limited liability company, serves as the GP of MAI Diversified Real Estate Income Fund III, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Income & Growth GP, LLC, a Delaware limited liability company, serves as the GP of MAI Capital Income and Growth Fund II, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Income & Growth GP IV, LLC, a Delaware limited liability company, serves as the GP of MAI Capital Income and Growth Fund IV, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Income & Growth GP V QC, LLC, a Delaware limited liability company, is the GP of MAI Capital Income & Growth Fund V QC, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Income & Growth GP V QP, LLC, a Delaware limited liability company, is the GP of MAI Capital Income & Growth Fund V QP, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Income & Growth VI GP, LLC, a Delaware limited liability company, is the GP of MAI Capital Income & Growth Fund VI QP, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Income & Growth VI GP, LLC, a Delaware limited liability company, is the GP of MAI Capital Income & Growth Fund VI QC, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Lending Fund GP, LLC, a Delaware limited liability company, is the GP of MAI Lending Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Solamere Fund GP, LLC, a Delaware limited liability company, is the GP of MAI Solamere Private Equity Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Glade Brook Fund GP, LLC, a Delaware limited liability company, is the GP of MAI Glade Brook Venture Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital GP Staking Fund GP, LLC, a Delaware limited liability company, serves as the GP of MAI Capital GP Staking Fund and MAI Capital GP Staking Fund Feeder, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Sports and Entertainment Seeding Fund GP, LLC, a Delaware limited liability company, serves as the GP of MAI Capital Sports and Entertainment Seeding Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Otro Sports Fund GP, LLC, a Delaware limited liability company, serves as the GP of MAI Capital Otro Sports Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Capital Secondaries Infrastructure Solution GP, LLC, a Delaware limited liability company, is the GP of the MAI Capital Secondaries Infrastructure Solution, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Avenue Sports Fund GP, LLC, a Delaware limited liability company, is the GP of the MAI

Capital Avenue Sports Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Affordable Housing Fund GP, LLC, a Delaware limited liability company, is the GP of the MAI Affordable Housing Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI Solamere Series IV Leaders Fund GP, LLC, a Delaware limited liability company, is the GP of the MAI Solamere Series IV Leaders Fund, LP. The GP is managed by Richard J. Buoncore of MAI.

MAI also has an indirect interest in MAI Oak Street GP, LLC. This Delaware limited liability company is the GP of MAI Wealth Income & Growth Fund, LP, a Delaware limited partnership ("Income and Growth Fund") that began operations in September 2013. The GP is controlled by MAI Wealth Capital Partners, LLC, a Delaware limited liability company owned by MAI, with Richard J. Buoncore serving as its President, and Oak Street Income and Growth, LLC. Pursuant to an investment advisory agreement, the investment manager of the Income and Growth Fund is Oak Street Real Estate Capital, LLC (SEC #80177141), a Delaware limited liability company. Oak Street Real Estate Capital, LLC, controls Oak Street Income and Growth, LLC. In addition to the Funds, MAI expects to continue to manage other client accounts, some of which have objectives similar to those of the Funds, including other collective investment vehicles that are managed by the same GP in which both the GP and MAI have an equity interest. Neither the GP nor MAI is obligated to devote any specific amount of time to the Funds' affairs, and neither is required to accord exclusivity or priority to the Funds in cases of limited investment opportunities. When MAI determines that it would be appropriate for the Funds and one or more other investment accounts to participate in an investment opportunity, MAI will seek to allocate investment opportunities to all investment accounts equitably. If MAI determines to invest at the same time in more than one of the investment accounts, MAI will place combined orders for all such accounts simultaneously. If an order on behalf of more than one account cannot be fully executed under prevailing market conditions, MAI will allocate the trade among the different accounts on a basis that we consider equitable. Situations may occur in which the Funds could be disadvantaged because of the investment activities conducted by MAI for other investment accounts.

MAI Code of Ethics MAI seeks to secure our reputation for integrity and professionalism, maintain the trust of our clients, and ensure that our employees do not benefit personally from the short-term effects of their service to clients. MAI has adopted the MAI Code of Ethics (the "Code of Ethics") to achieve these goals. All directors, officers, and employees of MAI, as well as any other person who provides investment advice on behalf of MAI and is subject to MAI's supervision and control, must abide by the Code of Ethics. The Code of Ethics prohibits the misuse of material nonpublic information. It seeks to uphold general business ethics by prohibiting and/or limiting certain activities, such as engaging in outside activities and giving or receiving gifts, other than nominal gifts, to or from any person or other entity that does business, or proposes to do business, with MAI or our affiliates without prior approval by the MAI Compliance Department. The Code also requires personnel to comply with MAI's information-barrier, restricted-list, and Material Non-Public Information (“MNPI”) controls applicable to interactions with affiliates and related persons, including Carlyle and its affiliates. Additionally, the Code of Ethics also governs certain political contribution activities. MAI provides a copy of the Code of Ethics to clients or prospective clients upon request.

Personal Trading Practices Personal trading activity includes the purchase or sale of securities that we also recommend to clients. This includes related securities (e.g., warrants, options, or futures). This presents a potential conflict of interest as we have an incentive to take investment opportunities from clients for our benefit, favor our personal trades over client transactions when allocating trades, or use the information about the transactions we intend to make for clients to our personal benefit by trading ahead of clients. To address these conflicts of interest, MAI's Code of Ethics imposes transaction restrictions on personal accounts. These restrictions include prohibitions on trading on insider information, trading excessively, acting on investment opportunities before offering appropriate opportunities first to clients, investing in initial public offerings or private placements without prior approval of the MAI Compliance Department, and investing in securities on the restricted stock list maintained by MAI. The Code of Ethics requires certain MAI personnel to adhere to its pre-clearance policy regarding personal securities transactions and to report their securities transactions and holdings to the Compliance Department. The Code requires heightened review for investments by certain MAI personnel in affiliated or Carlyle-related private placements, co-investments, limited offerings, or similar opportunities.

Participation or Interest in Client Transactions MAI acts as an investment adviser to numerous client accounts. MAI gives advice and acts with respect to any accounts we manage or for our own account that may differ from actions taken by MAI on behalf of other accounts. MAI is not obligated to recommend, buy, or sell, or refrain from recommending, buying, or selling, any security that MAI, or employees, may buy or sell for our own or their own account or the

accounts of any other client. MAI is not obligated to refrain from investing in securities held by accounts we manage except to the extent that such investment violates policies adopted by MAI. In a limited number of instances, MAI employees act as trustees at a client's request and with written permission of MAI. See Item 15 - Custody for more information on MAI employees acting as trustees for client trusts. The following items represent situations in which a conflict of interest exists between the client and MAI and our personnel and discuss our policies for addressing those conflicts.

Recommendations Involving Financial Interest MAI and/or our personnel have financial interests in securities or investment products we recommend. Client portfolios could include the securities of companies in which MAI or our personnel have positions. MAI may manage the securities portfolios of our employees’ pension plans and those of related companies on a discretionary basis following the same principles as other tax-exempt accounts. In addition, because certain investment funds managed by affiliates of Carlyle hold a majority ownership interest in MAI, conflicts of interest may arise if MAI recommends or makes available products, services, or investment opportunities involving Carlyle or its affiliates. MAI addresses these conflicts through disclosure, policies and procedures, and supervisory review.

Interest in Investment Funds MAI is the investment manager, GP, or managing member of, or has other economic interests in, certain investment-related limited liability companies and limited partnerships (the "Funds"). MAI may suggest or recommend that clients purchase or sell the Funds managed by MAI. For more information on the Funds, see Items 4, 8, and 10. MAI recommends such securities to clients who meet the requisite income and net worth requirements and when MAI believes that the investment is appropriate for the client based on the client's ability to accept the risk. MAI earns or shares in the management fees for these Funds. MAI also earns a carried interest or a performance fee for the funds listed in Item 6. Clients also pay MAI management fees on the assets MAI manages in their accounts. To avoid the conflict of clients paying MAI dual fees, all assets invested in these funds by MAI clients are excluded from the value of the client's account to calculate MAI's discretionary or non-discretionary management fees. The investment advisory fees that MAI receives from each of the MAI Funds are paid by the MAI Funds but are borne by fund members. Clients will receive the offering memorandum and full disclosure of all known risks before investing. In addition, MAI will disclose any proprietary interest in the company to the client.

Cross Trades While we typically do not engage in cross transactions, sometimes it is advantageous to clients to execute one client's sale transaction by matching it with another client's purchase transaction. For example, such a cross transaction can save brokerage commissions and related transaction costs. We will only do this when the proposed transaction is in the best interest of both clients. We do not "dump" a security into a client's portfolio just because another client needs to sell, nor do we decide to sell a security from one client's account just because another client wishes to purchase a similar security. Usually, this situation occurs with fixed-income securities, where we can receive more advantageous pricing for both clients by crossing the security instead of going into the open market to execute separate transactions.

MAI will execute cross-transactions through an independent broker-dealer acting as an agent. An independent broker-dealer will determine the price for a cross-transaction and is usually the midpoint between the best bid and offer prices available for the size of the transaction. We will also consider any additional fees charged to cross the security to ensure that the transaction is still appropriate for both clients. MAI does not act as the broker for any client cross-transactions. It does not receive commissions or compensation for these trades (other than an advisory fee for managing the account). Portfolio and wealth managers are to provide written details of a proposed cross-transaction to our Chief Investment Officer, who will provide written authorization for the transaction if approved. MAI will maintain documentation of cross-transactions in our books and records.

Aggregation with Client Orders Transactions for each client’s portfolio will generally be effected independently unless MAI determines to purchase or sell securities for several clients at approximately the same time. MAI may buy or sell securities in a batch transaction and allocate the batch to clients, funds, and employees. This presents a potential conflict of interest as we have an incentive to allocate more favorable executions to our accounts or the accounts of our personnel. MAI only aggregates transactions for clients with funds and employees, provided the allocation is done without favoring any one party. When aggregating orders, no client is to be favored over any other client; each client participating in the aggregated order will participate at the average share price for all the transactions executed at each custodian in that security by the block on a given business day, with transaction costs shared pro-rata based on each client's participation in the transaction. There may be more than one block of aggregated orders in a particular security on a business day. Securities purchased or sold in a batched transaction are allocated pro-rata, when possible, to the participating client accounts in proportion to the size of the order placed for each account. MAI may, however, increase or decrease the amount of securities allocated to each account if necessary to avoid holding odd-lot or small numbers of shares for clients. Additionally, if MAI is unable to execute a batched transaction fully and MAI determines that it would be impractical to allocate a small number of securities among the accounts participating in the transaction pro-rata, MAI will allocate such securities in a manner determined in good faith to be a fair allocation.

Adviser to Mutual Fund MAI is an investment adviser to the MAI Managed Volatility Fund (MAIPX/DIVPX), a proprietary mutual fund. We purchase interests in this fund for our advisory clients on a discretionary basis. MAI receives fees for managing the mutual fund and fees for investment advisory services provided to clients, which could give us an incentive to invest advisory clients in these mutual funds so that we receive dual fees. We recognize this conflict of interest, and to address it, we exclude this mutual fund from the assets we manage when calculating the advisory fee so that we will not receive dual management fees.

Clients Having an Ownership Interest Some MAI clients have or could acquire a non-controlling, passive ownership interest in MAI. In the performance of our investment advisory and management services, MAI makes no distinction between clients who have such an ownership interest and any other clients. Nevertheless, because of a non-

controlling ownership interest, a particular client may have the opportunity to access MAI, our investment professionals, and staff to a degree different from that available to other clients. In these circumstances, such a client may be advantaged in support and administrative services compared to clients having no ownership position. Such an advantage, however, is unrelated to the performance of investment advisory and management services by MAI for all MAI clients.

Introduction MAI will recommend that our clients consider establishing brokerage accounts with Fidelity Brokerage Services, Inc. (“Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”), among other custodians, all FINRAregistered broker-dealers, to maintain custody of clients’ assets and to effect trades for their accounts. Although MAI recommends that clients establish accounts at a particular custodian, the client decides where to custody their assets. MAI is not affiliated with any custodian. Factors considered by MAI in the recommendation of a custodian include the reasonableness of its product availability, research, and other services available to both the client and MAI.

Factors Considered in Selecting Broker-Dealers for Client Transactions In selecting securities brokerage firms, dealers, or banks ("investment firms"), MAI will consider the investment firm's execution capabilities, speed and efficiency, and quality of services, among other factors. In selecting an investment firm, MAI will seek competitive bids and negotiate rates where possible. Clients may pay commissions over those that another brokerage firm might charge for the same transactions. MAI generally trades at market and, on occasion, will use market limit orders. When buying or selling securities in dealer markets, primarily fixed-income securities, MAI prefers to deal directly with market makers in the securities who act for their own account as principal in the transaction. MAI may effect trades on a "net" basis on these transactions. MAI will not pay the market maker any commission, commission equivalent, or markup/markdown other than the "spread," that is, the difference between the price paid (or received) by MAI and the price received (or paid) by the market maker in trades with other broker-dealers or other customers. Securities may also be purchased from underwriters at prices that include underwriting fees.

Commission Rates or Equivalents Policy For any portfolio transaction, MAI will not select broker-dealers based on commission rates or seek competitive bids in advance for the most favorable commission rate. Although MAI seeks competitive commission rates on transactions where the client has not directed the broker-dealer selection, the account will not necessarily pay the lowest commission or commission equivalent. The reasonableness of commissions is based on the broker's ability to provide professional services, competitive commission rates, research, and other services that will help MAI provide investment management services to clients. MAI may, therefore, use a broker who offers research, custody, and securities transaction services even though a lower commission is charged by a broker who offers no research services and minimal custody or securities transaction assistance. Orders for discretionary accounts will be placed before orders for non-discretionary accounts since it usually takes time for non-discretionary account clients to respond to MAI’s recommendations.

Best Execution MAI seeks to obtain "best execution" of our clients' securities transactions. Best execution is achieved by well-informed trade execution decisions to maximize client portfolios. This responsibility relates to the

asset management process and the management of direct and indirect costs associated with using intermediaries such as broker-dealers and Electronic Communications Networks (ECNs). MAI strives to execute each transaction so that the client's total costs or proceeds in each transaction are the most favorable under the circumstances, including securities transactions executed by a specified brokerdealer. MAI considers pricing, speed of execution, and execution consistency. MAI periodically and systematically evaluates the performance of brokers and dealers executing our clients' transactions.

Limitation by Custodian Prime brokerage arrangements are only available to accounts that meet the minimum net equity requirements established by the SEC and when prime brokerage agreements are executed. Custodian brokers may impose net equity requirements higher than those established by the SEC. Accounts held at custodians that fall below the minimum required will not be able to participate in prime brokerage agreements, and therefore, all trades for those accounts will be placed with the accounts' custodian. Custodian brokers may charge the client additional fees or higher trading costs for securities purchased from another broker-dealer and transferred to the client's account. MAI will consider this additional cost in relation to our duty to seek the best execution for clients when we trade for these accounts. MAI receives research benefits when executing trades with other broker-dealers through prime brokerage arrangements.

Trading Errors MAI has procedures to prevent trading errors. Nevertheless, trade errors will still occur occasionally. Trading errors must be corrected promptly and in a manner that ensures the client does not suffer a loss from the error. However, in calculating the amount of any loss to a client, MAI may consider any tax savings or other monetary benefits the client may have received, so long as this practice and any resulting direct or indirect benefit to MAI is fully disclosed to the client in writing. If a gain (or loss) occurs, MAI will recognize it in an error account. Depending on the custodian, the gain is either used to offset future errors or donated to charity. Retention of such gain constitutes a benefit for MAI derived from managing client accounts and, as such, represents a conflict of interest.

Trade Rotation MAI's fiduciary responsibility is to ensure that accounts are traded fairly and impartially. No account will receive preferential treatment over any other. For clients in a strategy, accounts will be traded per the following trade rotation procedure:

When trading a strategy or discretionary accounts within a strategy for multiple client accounts, MAI will follow a rotation process grouped by the custodian or executing broker. When aggregating orders (block trades), each participating client must participate at the average share price (per custodian) for all transactions in that security in that block unless changes in allocation are required by special circumstances such as odd-lot considerations and small numbers of securities.

When executing trades with "manual" or "non-electronic" custodians, the custodian will be placed in the trade rotation; however, MAI will not wait for the order confirmation before moving on to the

next custodian in the rotation. MAI may aggregate orders for accounts within a strategy and for accounts managed outside of a model or MAI strategy when MAI determines aggregation is consistent with each participating account's objectives, restrictions, available cash, tax considerations, and other relevant circumstances. Aggregated orders may include client accounts, MAI-managed funds, and employee or related accounts. Participating accounts generally receive the average execution price for the relevant block at the applicable custodian or executing broker, and transaction costs are allocated pro rata, subject to adjustments for odd lots, minimum trade sizes, client restrictions, cash, tax considerations, or other operational factors. Because trades may be executed in more than one block, by different custodians, or at different times, clients may receive different execution prices.

Research and Other Soft Dollar Benefits MAI directs brokerage transactions to securities broker-dealers with which we have arranged to receive research that we use in providing investment management services to our clients. Such arrangements are referred to as “soft dollar” arrangements and enable MAI to obtain valuable proprietary or third-party research to supplement our research in exchange for directed brokerage and the payment of brokerage commissions. In all cases, MAI has determined that the commission charged by a broker-dealer with which we have such an arrangement is reasonable in relation to the value of the brokerage and research services provided and the benefit to MAI clients. Under such arrangements, clients may pay a higher brokerage commission than they might otherwise pay in executing transactions through a broker-dealer with which MAI has no arrangement for research services. Research services obtained by MAI directly or indirectly benefit clients and may be used in connection with clients other than those paying commissions. MAI does not attempt to assign or separately allocate relative costs or benefits of obtaining valuable research among clients. Using client brokerage commissions to obtain research and brokerage services creates a conflict of interest because MAI receives a benefit from products or services that assist MAI in providing investment advice. Where a product or service has both research and non-research uses, MAI allocates the cost between eligible and non-eligible uses in good faith and pays the non-eligible portion in cash. To the extent that MAI can acquire these products and services without expending our resources (including management fees paid by the Funds), MAI's use of "soft dollars" would tend to increase MAI's profitability. In addition, the availability of these non-monetary benefits may influence us to select one broker rather than another to perform services. MAI is a party to "soft dollar" arrangements with various brokerage firms, under which the cost of specific research and other services and products used by MAI or our affiliates are paid for with commissions generated by direct securities transactions for client accounts. MAI has entered into arrangements with brokers to: (1) have "soft dollar" credits rebated to the client accounts or to have commissions recaptured by the client accounts from which the credits or commissions were generated or (2) use "soft dollars" to pay expenses otherwise payable by client accounts. Either of such uses of "soft dollars" would enhance the returns associated with such client accounts from the returns that would exist absent such uses. MAI reserves the right to change our soft dollar practices as provided herein. In addition to research services, MAI has been offered other monetary or non-monetary benefits by

brokers to execute direct securities transactions on behalf of our clients. These benefits include special execution, clearance, and settlement capabilities. Further, if a product or service obtained by MAI provides both research and non-research benefits, MAI will treat it as a "mixed-use" item and pay for the nonresearch portion with cash. In the use of soft dollars with regard to obtaining "mixed use" items or services, that is, items or services that MAI may directly use for its purposes in addition to use for the benefit of clients, MAI makes an allocation in the payment for such items or services between soft dollars and hard dollars it pays. Although the allocation between soft dollars and hard dollars paid by MAI is made in good faith based on a reasonable assessment of how such mixed-use items or services will be applied, MAI has a conflict of interest in making that determination to the extent there is an economic benefit in allocating a greater percentage of payment to soft dollars. When engaging in direct securities transactions, MAI pays broker commissions higher than another broker might have charged for the same transaction in recognition of MAI's assessment of the value of the research and other services provided to MAI by the broker. However, MAI believes that commission costs borne by client accounts are reasonable for the overall services offered. The client account that bears the cost of such a commission for a particular trade will not necessarily be the sole beneficiary of such research. Subject to being satisfied that we are obtaining the best execution, MAI considers referrals of investors in selecting among brokers that otherwise satisfy MAI's selection criteria. Generally, these research services are broad and benefit all clients. All soft dollar arrangements are reviewed and approved by MAI before MAI enters into them. MAI monitors its soft dollar practices and any third-party arrangements to ensure consistency with the Firm’s policy.

Other Benefits MAI has arrangements with National Financial Services LLC and Fidelity, and Charles Schwab & Co., Inc. and Schwab Adviser Services (collectively “Schwab”) through which Fidelity and Schwab (individually “Custodian”) provide MAI with platform services. The platform services include, among others, brokerage, custodial, administrative support, recordkeeping, and related services that are intended to support intermediaries like MAI in conducting business and in serving the best interests of their clients but also benefit MAI. Custodians charge brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, and commissions are charged for individual equity and debt securities transactions). The Custodian enables MAI to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Custodian's commission rates are considered discounted from customary retail commission rates. However, commissions and transaction fees may be higher or lower than those charged by other custodians and broker-dealers. As part of the arrangement, Custodian also makes certain research and brokerage services available to MAI at no additional charge to MAI, including research services obtained by Custodian directly from independent research companies, as selected by MAI (within specified parameters). These research and

brokerage services presently include services we use to manage accounts for which MAI has investment discretion, such as:

provide access to client account data (such as trade confirmations and account statements);

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Referral Arrangements MAI enters into agreements with affiliates and non-affiliates to solicit clients for MAI. If an unaffiliated person introduces a client to MAI, MAI typically compensates that promoter, directly or indirectly, with a portion of MAI’s advisory fees or other professional fees in accordance with Rule 206(4)-1 under the Advisers Act, and applicable state law. Any such compensation is paid by MAI from its advisory fees and does not result in additional charges to the client. At the time of a solicitation or endorsement, promoters are required to disclose, as applicable, whether they are or are not a current client of MAI, that they receive direct or indirect cash or non-cash compensation for the referral, the material terms of such compensation, and the material conflicts of interest created by the compensation arrangement. Where required by Rule 206(4)-1, MAI enters into written agreements with promoters, has a reasonable basis for believing required disclosures are provided to clients at the time of the endorsement or referral, conducts oversight of promoter activities, and performs disqualification screening in accordance with the rule.

Fidelity WAS Program MAI participates in the Fidelity WAS Program, through which MAI receives referrals from Strategic Advisers LLC (“Strategic Advisers”), a registered investment adviser and Fidelity Investments Company. MAI is independent and not affiliated with Strategic Advisers or any Fidelity Investments Company. Strategic Advisers does not supervise or control MAI, and Strategic Advisers has no responsibility or oversight for MAI’s provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a promoter for MAI, and MAI pays referral fees to Strategic Advisers for each referral received based on MAI’s assets under management attributable to each client referred by Strategic Advisers or members of each client’s household. The WAS Program is designed to help investors find an independent investment adviser, and any referral from Strategic Advisers to MAI does not constitute a recommendation by Strategic Advisers of MAI’s particular investment management services or strategies. More specifically, MAI pays the following amounts to Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets by Strategic Advisers and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, MAI has agreed to pay Strategic Advisers an annual program fee to participate in the WAS Program. These referral fees are paid by MAI and not by the client. To receive referrals from the WAS Program, MAI must meet certain minimum participation criteria, but MAI has been selected for participation in the WAS Program because of its other business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, MAI has a conflict of interest with respect to its decision to use certain affiliates of Strategic Advisers, including FBS, for execution, custody, and clearing for certain client accounts, and MAI could have an incentive to suggest the use of FBS and its affiliates to its advisory

clients, whether or not those clients were referred to MAI as part of the WAS Program. Under an agreement with Strategic Advisers, MAI has agreed that it will not charge clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Pursuant to these arrangements, MAI has agreed not to solicit clients to transfer their brokerage accounts from affiliates of Strategic Advisers or establish brokerage accounts at other custodians for referred clients other than when MAI’s fiduciary duties would so require, and MAI has agreed to pay Strategic Advisers a one-time fee equal to 0.75% of the assets in a client account that is transferred from Strategic Advisers’ affiliates to another custodian; therefore, MAI has an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of Strategic Advisers. However, participation in the WAS Program does not limit MAI’s duty to select brokers on the basis of best execution.

Schwab Advisor Network® Program MAI receives client referrals from Schwab through MAI's participation in the SAN Program. Schwab is a broker-dealer independent of and unaffiliated with MAI. Schwab does not supervise MAI and has no responsibility for MAI’s management of client portfolios or MAI’s other advice or services. MAI pays Schwab fees to receive client referrals through the SAN Program. MAI's participation in the SAN Program raises potential conflicts of interest, as described below. The participation fee paid by MAI is a percentage of the fees the client owes to MAI, or a percentage of the value of the assets in the client's account, subject to a minimum participation fee. MAI pays Schwab the participation fee for so long as the referred client's account remains in custody at Schwab. The participation fee is billed to MAI quarterly and may increase, decrease, or be waived by Schwab. The participation fee is paid by MAI and not by the client. For the accounts referred to us through the SAN Program, MAI has agreed not to charge clients fees or costs greater than the fees or costs MAI charges clients with similar portfolios who were not referred through the SAN Program. MAI pays Schwab a Non-Schwab Custody Fee if custody of a referred client's account is not maintained or assets in the account are transferred from Schwab. This fee does not apply if the client was solely responsible for the decision not to maintain custody at Schwab. The Non-Schwab Custody Fee is a onetime payment equal to a percentage of the assets placed with a custodian other than Schwab. The NonSchwab Custody Fee is higher than the Participation Fees MAI would pay in a single year. Thus, MAI has an incentive to recommend holding client accounts in custody at Schwab. The participation and Non-Schwab Custody Fees will be based on assets in accounts of MAI’s clients who were referred by Schwab and those referred clients’ family members living in the same household. Thus, MAI will have incentives to encourage household members of clients referred through the SAN Program to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit MAI’s fees directly from the accounts. For accounts of MAI's clients maintained in custody at Schwab, Schwab will not charge the client separately for custody but will receive compensation from MAI's clients in the form of commissions or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab's fees for trades executed at other

broker-dealers are in addition to the other broker-dealer's fees. Thus, MAI has an incentive to cause trades to be executed through Schwab rather than another broker-dealer. MAI, nevertheless, acknowledges its duty to seek the best execution of trades for client accounts. Trades for client accounts held in custody at Schwab may be executed through a different broker-dealer than trades for MAI's other clients. Thus, trades for accounts custodied at Schwab may be executed at various times and at prices different from trades for other accounts that are executed at other brokerdealers.

MAI and our personnel seek to maintain the highest level of business professionalism, integrity, and ethics. MAI and management persons do not have any disciplinary information to disclose.

Wealth Managers ("WMs") are primarily responsible for obtaining information about the client's income needs, investment time horizons, legal constraints, and other relevant investment factors. The assigned WMs are responsible for identifying the client's investment objective and communicating those objectives to the Portfolio Managers ("PMs"). Within the confines of MAI's investment philosophy, individual client portfolios are structured to meet each client's objectives. When a client does not have wealth management services and therefore no WM, the PM is responsible for obtaining the client's information and identifying the client's investment objective. All client portfolios under management are to be reviewed at least annually by a WM or PM, and clients typically receive a performance report quarterly. However, they may ask to receive reports semi-annually, annually, or upon request. New investment, tax, or other developments may result in new or revised recommendations. New circumstances, or changes in client objectives, can trigger a portfolio review. The review of client portfolios is to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, factor exposure, asset class or style drift, account additions/withdrawals, and a change in the client's investment objective, financial position, or tax situation. Based on these factors, it is common that an extended period will pass where changes to a client's portfolio are neither necessary nor prudent. Clients remain subject to the fees described herein during these periods. In addition to reports and other reviews, PMs are available to clients through phone contacts or client meetings to assist in developing an investment plan and to receive, request, or consider specific investment recommendations. WMs are available to wealth management clients through phone contacts or client meetings to help develop a financial plan. WMs have primary responsibility for the annual review of the client's financial plan report and updates as needed.

MAI has custody of certain client assets in limited circumstances, including when MAI is authorized to deduct advisory fees directly from client accounts, when an MAI employee serves as trustee on a client account, when a client authorizes a standing letter of authorization that includes a related-party recipient, where MAI has a client’s password to an account (e.g., an employer 401k account, or when MAI is granted authority to move funds or securities in connection with bill-pay . MAI has put controls in place, in compliance with federal rules, to protect clients' assets over which we have custody. An independent qualified custodian (a broker-dealer, bank, trust company, or other financial institution) (“Qualified Custodian”) holds each client's assets — MAI does not act as custodian for any client. At least quarterly, the custodian sends account statements directly to the client or the client's independent representative. The statements will reflect the client's funds and securities held with the Qualified Custodian and any transactions in the account, including the deduction of MAI's fee. Clients should carefully review the account statements received from the Qualified Custodian. Clients who receive statements from MAI and the Qualified Custodian should compare these two reports carefully. Clients with any questions about their statements should contact us at the address or phone number on the cover of this brochure. Clients who do not receive their statement from the Qualified Custodian at least quarterly should also notify us. In addition, an independent accountant conducts annual surprise examinations of client accounts over which MAI or a related person of MAI can instruct asset movement out of the client account, other than instructions to deduct MAI's management fees or transfer to a same-registration account of the client. MAI is deemed to have custody of the assets of the Funds. As the managing member or GP and investment manager of the funds, MAI can request funds from the custodian of the accounts. MAI has put controls in place, in compliance with federal rules, to protect clients' assets in the funds. We rely on the "annual audit provision" allowed under the custody rule. Each Fund has an independent audit performed by a public accounting firm. These audited financial statements are distributed to Fund investors. A qualified custodian holds the Fund's assets. In addition, an independent accountant audits the accounts each year, and we send copies of the audited financial statements to all investors in the funds. An independent accountant will also audit the fund upon liquidation.

With respect to our discretionary clients, MAI is authorized to make the following determinations based on the client's specified investment objectives without consulting the client or obtaining the client's consent before effecting a transaction:

which securities to buy or sell;

the total amount of securities to buy or sell;

the broker or dealer through whom securities are bought or sold;

the commission rates at which to effect securities transactions for client accounts, and

the prices at which to buy or sell securities, which may include dealer spreads or mark-ups and transaction costs.

For discretionary accounts, members of the Investment Committee set investment guidelines, and the Portfolio Managers make the investment decision within these guidelines and in accordance with the client's investment objectives. They may consult with the client's Wealth Manager. There are exceptions to MAI's investment discretion. Clients may prohibit the purchase of certain specific securities or securities from a specific industry. Client guidelines may also limit the amount of securities to be bought or sold or prohibit the purchase of certain types of securities if the purchase would cause the holdings of such securities to exceed a designated percentage of the account's value. In connection with our Funds, MAI has complete discretion to make investments and manage the Funds generally.

Proxy Voting Although MAI does vote proxies for a limited number of clients, MAI's general policy is not to accept responsibility for voting proxies absent special circumstances. In cases where MAI does, however, accept responsibility for voting proxies for a particular client, MAI has adopted a Proxy Voting Policy that is designed to reflect MAI's commitment to voting proxies in the best interest of clients and as required by Rule 206(4)-6 under the Advisers Act. We will make proxy voting decisions for that security on a case-bycase basis, as described below. MAI generally votes with management; however, each proxy proposal should be individually reviewed to determine whether the proposal is in the best interests of our clients. MAI has developed procedures for voting proxies that require the review of proxy solicitation materials and voting of the proxies according to the voting guidelines outlined in the policy. MAI permits clients to direct our vote in a particular solicitation. To implement MAI's proxy voting policies, MAI has engaged Broadridge's ProxyEdge platform to vote and maintain records of all proxies. At any time, clients can contact us to request information about how we voted proxies for their securities or to obtain a copy of our Proxy Voting Policy. You can obtain this information by submitting a written request to us at: MAI Capital Management, LLC, Operations Department, 6050 Oak Street Blvd., Suite 500, Cleveland, OH 44131. For clients for whom MAI does not have the authority to vote for client securities, clients will receive their proxies or other solicitations directly from their custodian or a transfer agent. Clients can call us if they have questions about a particular solicitation. However, MAI will not be deemed to have proxy voting authority solely because it provides advice or information about a specific proxy vote to a client.

Class Actions MAI does not instruct or advise clients on whether to participate as a member of class action lawsuits and will not automatically file claims on the client's behalf. However, if a client wants MAI to determine whether the client should participate in a class action, the client can opt in to such service. MAI has engaged a third-party service provider to facilitate participation in class actions.

Registered investment advisers are required in this item to provide clients with certain financial information or disclosures about the firm's financial condition. MAI does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and does not foresee any financial condition reasonably likely to impair our ability to meet client contractual commitments.

APPENDIX

MAI PRIVACY NOTICE

Form ADV, Part 2A Brochure | June 26, 2026

MAI Capital Management, LLC (“MAI”) PRIVACY NOTICE What Does MAI Do with Your Personal Information? Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:      

Social Security number, driver’s license, or other government identifiers. Contact info (name, address, email, and phone) and demographic data provided to us. Account numbers, account balances, transaction history, and holdings. Login credentials and authentication data (user IDs, passwords, and security questions). Financial profile and planning information (assets, income, risk tolerance, and objectives). Sensitive customer information as defined under Regulation S-P (e.g., data that could result in substantial harm or inconvenience if misused).

When you are no longer our client, we may continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. Below we list the reasons financial companies can share their customers’ personal information; the reasons MAI chooses to share; and whether you can limit this sharing.

Reasons We Can Share Your Personal Information

Does MAI Share?

Can You Limit This Sharing?

For our everyday business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.

Yes

No

For our marketing purposes: to offer our products and services to you.

Yes

No

For joint marketing with other financial companies.

No

We don’t share

For our affiliates’ everyday business purpose: information about your transactions and experiences.

Yes

No

For our affiliates’ everyday business purposes: information about your creditworthiness.

No

We don’t share

For our affiliates to market to you.

No

We don’t share

For non-affiliates to market to you.

No

We don’t share

Questions?

Call: 1-216-920-5174

Form ADV, Part 2A Brochure | June 26, 2026

Who We Are Who is providing this notice?

What We Do How does MAI protect my personal information?



To protect your personal information from unauthorized access and use, we restrict access to your personal financial information to personnel who need that information to provide you with our products and services. We maintain and monitor our physical, electronic, and procedural safeguards, updating them as needed so that we may protect your personal information. We use security and encryption methods to help us identify and prevent potential data breaches and unauthorized disclosure of your personal financial information.



MAI maintains a written incident response program reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information, including procedures to assess, contain, and control incidents, and to notify affected individuals.



MAI oversees service providers with access to customer information. It requires them to notify MAI as soon as possible, and no later than 72 hours after becoming aware of an incident affecting customer information or systems they maintain on our behalf.

How does MAI collect my personal information?

We collect your personal information, for example, when you open an account or provide us with your income information, provide account information or your contact information, seek advice about your investments, or tell us about your investment or retirement portfolio. We may also collect your personal information from others, such as credit bureaus, affiliates, or other companies, including your retirement plan sponsor, where our services are available to you through your employer.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:   

sharing for affiliates’ everyday business purposes - information about your creditworthiness; affiliates from using your information to market to you, and sharing for non-affiliates to market to you.

State laws and individual companies may give you additional rights to limit sharing.

Definitions Affiliates

Companies related by common ownership or control. They can be financial and non-financial companies.  

MAI does not share with non-affiliates so they can market to you. MAI may share with affiliates for everyday business purposes (e.g., transactions and experiences), but not information about your creditworthiness.

Form ADV, Part 2A Brochure | June 26, 2026

Non-affiliates

Companies not related by common ownership or control. They can be financial and non-financial companies.

 Joint marketing

A formal agreement between non-affiliated financial companies that together market financial products or services to you. 

Breach Notification under Reg. S-P

MAI does not share with non-affiliates so they can market to you.

MAI doesn’t jointly market.

If MAI determines that unauthorized access to or use of sensitive customer information has happened or is reasonably likely to have happened, MAI will provide notice to each affected individual as soon as practicable and not later than 30 days after becoming aware of the incident, subject to limited law enforcement delay. Notices will include a general description of the incident, the types of information involved, MAI contact information, and steps you can take to protect yourself (e.g., fraud alerts, credit freezes, and identity monitoring where appropriate).

Other Important Information MAI complies with the SEC’s amended Regulation S-P, including notice requirements, maintaining an incident response program, overseeing service providers, properly disposing of customer information, and keeping records of our compliance. In addition to complying with federal requirements, MAI follows applicable state laws regarding data breach notification. If a breach of personal information occurs, we will notify affected individuals and, where required, state regulators or consumer reporting agencies, in accordance with the timing and content requirements of each state’s law. For example, certain states may require notification within a specific timeframe, notice to state authorities, or additional information in the notice. MAI is committed to providing prompt, transparent, and compliant notifications to all impacted individuals, regardless of their state of residence. To learn more about our privacy practices, please go to: https://mai.capital/privacy-policy/