Marketing Services & Regulatory Disclaimer
MAJORWIN ADVISORSLEGAL DISCLAIMER & SCOPE OF SERVICES Effective Date: 8/16/2026. 1. Nature and Purpose of MajorWin Advisors MajorWin Advisors (“MajorWin”) is an independent marketing, communications, and business-development company.MajorWin provides marketing and business-development services to investment advisers, wealth management firms, asset managers, financial professionals, and other businesses operating in or serving the financial-services industry.MajorWin’s role is limited to providing marketing, branding, communications, business-development, prospect-development, and related non-investment-advisory services.MajorWin is not an investment adviser, investment adviser representative, broker-dealer, registered representative, securities dealer, financial planner, tax adviser, attorney, accountant, or other provider of regulated financial or professional advice.2. No Investment Advisory ServicesMajorWin does not provide investment advice or individualized financial advice to any person.MajorWin does not:Recommend, select, or determine which securities or investments any person should purchase, sell, hold, or otherwise transact in;Provide individualized investment recommendations;Manage, supervise, or exercise discretionary authority over investment accounts or client assets;Determine asset allocations or investment strategies for investors;Execute or arrange securities transactions;Receive or take custody of client or investor funds or securities;Provide financial planning or tax advice;Determine whether an investment is suitable or appropriate for a particular investor;Act as a fiduciary with respect to investment decisions; orMake investment decisions on behalf of any client, prospective client, investor, or other third party.Nothing contained in any MajorWin communication, website, presentation, marketing material, social-media communication, or other content should be interpreted as personalized investment advice or a recommendation to purchase, sell, or hold any security or investment product.3. Scope of Marketing ServicesMajorWin’s services may include, depending upon the written agreement with a client:Marketing strategy and planning;Brand development and positioning;Business-development strategy;Identification and development of prospective target audiences;Marketing research;Prospect and audience research;Development of marketing campaigns;Digital marketing;Website and content strategy;Advertising and promotional strategy;Communications strategy;Preparation and editing of marketing materials;Presentation and messaging development;Public-relations and media strategy;Database and marketing-system development;Lead-generation strategy;Relationship-development strategy;Business-development consulting; andOther marketing-related services agreed upon in writing.MajorWin does not guarantee that any marketing or business-development activity will result in new clients, assets under management, investment performance, revenue, or any other particular business outcome.4. Separation From Client’s Regulated ActivitiesWhen MajorWin provides services to an investment adviser, broker-dealer, wealth manager, asset manager, or other regulated financial-services firm, the client remains solely responsible for its own regulated activities.The client is solely responsible for:Investment recommendations;Investment decisions;Portfolio management;Client suitability and/or fiduciary obligations;Regulatory filings;Regulatory disclosures;Advertising compliance;Marketing compliance;Performance reporting;Testimonials and endorsements;Supervision of registered personnel;Compliance policies and procedures; andCompliance with applicable federal and state securities laws, regulations, and self-regulatory organization requirements.MajorWin does not assume responsibility for the client’s regulatory or compliance obligations merely because MajorWin assists with marketing, communications, or business development.5. Client Review and ApprovalAll marketing materials, advertisements, presentations, websites, social-media content, investor communications, performance information, testimonials, endorsements, and other materials relating to a client’s regulated financial-services business should be reviewed and approved by the client before publication or distribution.The client is responsible for determining whether any proposed communication complies with the laws, regulations, rules, and regulatory guidance applicable to the client’s business.MajorWin may assist with the preparation or development of marketing materials; however, such assistance does not constitute legal, compliance, investment, or regulatory advice.The SEC’s investment-adviser marketing rules impose requirements concerning, among other things, misleading statements, testimonials, endorsements, third-party ratings, and performance information. (SEC)6. No Representation as a Financial AdviserMajorWin and its personnel shall not represent themselves as investment advisers, financial advisers, investment adviser representatives, broker-dealers, securities representatives, or other regulated financial professionals unless separately authorized and appropriately registered or licensed to do so.MajorWin’s use of terms such as “marketing,” “business development,” “financial-services marketing,” “investment industry,” “wealth management,” or similar terminology is intended solely to describe the industries and businesses served by MajorWin and does not constitute a representation that MajorWin provides investment advice or other regulated financial services.7. No Securities RecommendationsAny discussion of securities, investment strategies, financial markets, asset classes, investment managers, investment products, or economic conditions appearing in MajorWin materials is provided, when applicable, solely for marketing, communications, educational, or business-development purposes.Such information should not be construed as a recommendation or endorsement that any particular person purchase, sell, hold, or otherwise transact in any security or investment product.Prospective investors should consult their own qualified financial, legal, tax, and investment professionals before making investment decisions.8. No Custody or Control of Investor AssetsMajorWin does not accept, hold, control, or have discretionary authority over investor funds or securities.MajorWin does not have authority to open, close, trade, transfer, or otherwise manage investment accounts on behalf of investors.Any investment account, transaction, investment decision, or transfer of funds is conducted directly through the applicable financial institution, investment adviser, broker-dealer, custodian, or other appropriately authorized entity.9. Marketing and CommunicationsMajorWin may develop, prepare, edit, coordinate, or distribute marketing and communications materials on behalf of its clients.Where MajorWin performs such services for a regulated financial-services client, the client remains responsible for ensuring that the final communication complies with applicable law and the client’s own regulatory and compliance requirements.MajorWin does not independently certify, approve, or guarantee the regulatory compliance of client materials.10. Testimonials, Endorsements and Third-Party InformationMajorWin may assist clients with the development or presentation of testimonials, endorsements, reviews, third-party ratings, or other promotional content.Any such materials involving an investment adviser or other regulated financial-services business must be reviewed and approved by the applicable client and handled in accordance with the regulatory requirements applicable to that client.The SEC Marketing Rule contains specific requirements concerning compensated testimonials and endorsements, including disclosure, oversight, and certain disqualification provisions. (SEC)11. No Guarantee of ResultsMarketing and business-development activities involve substantial uncertainty.MajorWin makes no representation, warranty, or guarantee concerning:The number or quality of prospective clients generated;Conversion rates;Assets under management;Revenue;Investment performance;Fundraising;Client retention;Investment results;Business valuation; orAny other specific financial or business result.Past marketing results do not guarantee future results.12. CompensationMajorWin’s compensation for its services will be established pursuant to a separate written agreement with each client.Unless specifically agreed in writing and legally permissible, MajorWin’s compensation is intended to constitute compensation for marketing and business-development services rather than compensation for recommending, effecting, or facilitating securities transactions or providing investment advice.Transaction-based or securities-related compensation arrangements should not be implemented without appropriate legal and regulatory review.The characterization of an arrangement as a “marketing fee,” “consulting fee,” “referral fee,” or similar label does not by itself determine whether the arrangement is subject to securities laws or broker-dealer regulation.13. No Solicitation or Brokerage ActivityMajorWin does not act as a broker-dealer or securities salesperson and does not effect securities transactions.MajorWin does not negotiate securities transactions, determine transaction terms, handle investor funds, or otherwise perform functions requiring registration as a broker-dealer.Nothing in this Disclaimer or in any MajorWin agreement should be interpreted as authorizing MajorWin to perform activities requiring registration or licensing under applicable securities laws.14. Prospective Investor CommunicationsWhere MajorWin assists a client with identifying or communicating with prospective customers or investors, MajorWin’s role is limited to marketing and business-development activities.MajorWin does not determine whether a prospective investor is suitable or appropriate for a particular investment, does not make investment recommendations, and does not make the ultimate decision regarding whether a prospective investor becomes a client.Those determinations remain the sole responsibility of the applicable investment adviser, broker-dealer, fund sponsor, or other appropriately regulated financial-services provider.15. Regulatory ComplianceEach client is responsible for determining the regulatory requirements applicable to its particular business and for obtaining appropriate legal and compliance advice.Nothing provided by MajorWin constitutes legal, regulatory, accounting, tax, investment, or compliance advice.MajorWin may recommend that a client obtain independent legal or compliance review when MajorWin believes such review would be appropriate; however, MajorWin does not provide that legal or compliance review itself.16. No Agency or PartnershipUnless expressly provided in a separate written agreement, MajorWin is an independent contractor and is not an employee, partner, joint venturer, fiduciary, investment adviser, broker-dealer, or agent of its client.No MajorWin employee or representative has authority to bind a client to an investment transaction, advisory relationship, securities transaction, or other financial obligation unless such authority has been expressly granted in writing and is legally permissible.17. Accuracy of Client InformationMajorWin may rely upon information, data, performance figures, biographies, investment descriptions, claims, representations, and other information supplied by its clients or third parties.MajorWin does not independently audit or verify such information unless specifically engaged to perform that service.Clients remain responsible for the accuracy, completeness, and substantiation of information they provide for use in marketing or communications.18. Limitation Regarding Regulatory StatusNothing in this Disclaimer is intended to establish or determine MajorWin’s regulatory status under federal or state law.The parties acknowledge that regulatory status is determined by applicable law and, where applicable, by the nature and substance of the activities actually performed.If MajorWin’s activities, compensation arrangements, or services materially change, MajorWin may revise this Disclaimer and its scope of services accordingly.19. Investor DisclaimerMajorWin Advisors is a marketing and business-development company and is not an investment adviser or broker-dealer. MajorWin does not provide investment advice, securities recommendations, portfolio management, financial planning, or other regulated investment services.Any investment-related information appearing in MajorWin materials is provided for marketing, educational, informational, or business-dev...