Customer Relationship Summary

BROKERAGE ACCOUNT

Our BROKERAGE ACCOUNT services include buying and selling securities

If you open a brokerage account, you will pay us a transaction-based fee, generally referred to as a commission, every time you buy or sell an investment.

You may select investments, or we may recommend investments for your account. You make the ultimate decision regarding the purchase or sale of investments.

We can offer you additional services to assist you in developing and executing your investment strategy and measuring the quarterly performance of your account, but you might pay more. We will deliver account statements to you at least quarterly in paper or electronically.

We limit the selection of investment products to those preapproved by the firm. Other firms may offer a wider range of choices, some of which might have lower costs.

INVESTMENT ADVISORY ACCOUNT

Our INVESTMENT ADVISORY account services include portfolio construction and allocation

If you open an advisory account, you will pay an on-going asset-based fee for our services. We will offer you bespoke advice on a regular basis. We will discuss your investment goals and design with you a strategy to achieve your investment goals. And we regularly monitor your account. Your management fee includes investment advice, asset allocation, daily portfolio management, quarterly performance measurement and reporting, and CPA ready tax-lot accounting. We will be available to you by phone or e-mail to discuss your portfolio at
any time.

You can choose an account that allows us to buy and sell investments in your account without asking you in advance ( a “discretionary account”) or we may give you advice and you decide what investments to buy and sell (a “non-discretionary account”)

Our investment advice will cover a limited selection of investments. Other firms could provide advice on a wider range of choices, some of which might have lower costs.

BROKERAGE ACCOUNT

We must act in your best interest and not place our interests ahead of yours when we recommend an investment or an investment strategy involving securities. When we provide any service to you, we must treat you fairly and comply with a number of specific obligations. Unless we agree otherwise, we are not required to monitor your portfolio or investments on an ongoing basis.

INVESTMENT ADVISORY ACCOUNT

We are held to a fiduciary standard that covers our entire investment advisory relationship with you, see Our Fiduciary Pledge. We are required to monitor your portfolio, investment strategy and investments on an ongoing basis. Our interests can conflict with your interests. We must eliminate these conflicts or tell you about them in a way you can understand, so that you can decide whether or not to agree to them.

BROKERAGE ACCOUNT

Transaction-based fees. You will pay us a fee every time you buy or sell an investment. This fee, commonly referred to as a commission, is based on the specific transaction and not the value of your account.

With stocks or exchange traded funds, this fee is usually a separate commission. With other investments, such as bonds, this fee might be part of the price you pay for the investment called a “mark-up” or “mark-down”. With mutual funds, this fee or “load” reduces the value of your investment.

Some investments (such as mutual funds and variable annuities) impose additional fees that will reduce the value of your investment over time. Also, with certain investments such as variable annuities, you may have to pay fees such as “surrender charges” to sell the investment.

Our fees vary and are negotiable. The amount you pay will depend on how much you buy or sell, what type of investment you buy or sell, and what kind of account you have with us.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

We charge you additional sundry fees, such as custodian fees, account maintenance fees, and account inactivity fees. The more transactions in your account, the more fees we charge you. We therefore have an incentive to encourage you to engage in transactions.

From a cost perspective, you may prefer a transaction-based fee if you do not trade often or if you plan to buy and hold investments for longer periods of time.

INVESTMENT ADVISORY ACCOUNT

Asset-based fees. You will pay an on-going fee at the end of each quarter based on the value of the cash and investments in your advisory account.

The amount paid to our firm and your financial professional generally does not vary based on the type of investments we select on your behalf. The asset-based fee reduces the value of your account and will be deducted from your account.

For wrap fee programs, the asset-based fee includes transaction costs and custody services, and as a result wrap fees are typically higher than non-wrap advisory fees.

The firm’s representatives may solicit customers on behalf of outside investment managers. Clients of third party managers receive their respective Part II form ADV and their Customer Relationship Summary in which their fees and services are disclosed. Fees and services of outside managers may differ from those of McClurg Capital Corporation.

Some investments (such as mutual funds and variable annuities) impose additional fees that will reduce the value of your investment over time. Also, with certain investments such as variable annuities, you may have to pay fees such as “surrender charges” to sell the investment.

Our fees vary and are negotiable. The amount you pay will depend on the services you receive and the amount of assets in your account. The more assets you have in the advisory account, including cash, the more you will pay us. We therefore have an incentive to increase the assets in your account in order to increase our fees. You pay our fee quarterly even if you do not buy or sell.

For accounts not part of a wrap fee program, you will pay a transaction fee when we buy and sell an investment for you. The financial institution that holds your assets charges “custody” fees.

BROKERAGE ACCOUNT

We can receive extra compensation by selling you certain investments offered by third party vendors such as mutual funds and insurance companies. Your financial professional may receive additional compensation if you buy these invest-ments.

We may have an incentive to offer or recommend certain investments of outside sponsors or managers because they may share with us revenues they earn on those investments. The revenues earned by third party sponsors or managers are generally disclosed in the issuer’s prospectus.

We can buy investments from you and sell investments to you from our own accounts (called “acting as principal”). We can earn a profit on these trades, so we have an incentive to encourage you to trade with us.

INVESTMENT ADVISORY ACCOUNT

We can make extra money by advising you to invest in certain investments from third parties such as wrap account vendors because they are managed or sponsored by someone related to our firm. The fees and expenses charged by third party manag-ers may be more or less than the fees that are otherwise charged to McClurg Capital internally managed portfolios.

We can buy investments from you and sell investments to you from our own accounts (called “acting as principal”), but only with full disclosure, your written approval and subject to maxi-mum mark-up limitations. Please visit McClurg Capital’s Code of Ethics in our 2020 Disclosures for Clients brochure for further details.