A. General Description of Advisory Firm BrightPlan LLC (“BrightPlan”) offers a comprehensive employee financial wellness service (“Financial Wellness”) that includes education, goals-based planning, investment advice, and comprehensive personal financial management that helps employees achieve financial success. Our advice is personalized, actionable and integrated with employer benefits. BrightPlan is led by a team of experienced Silicon Valley executives and technology innovators with extensive software and industry expertise. BrightPlan combines transformational digital capabilities with access to financial advisors to make wealth management accessible to everyone, regardless of net worth. BrightPlan is a Delaware limited liability company formed in 2015 and is a wholly owned subsidiary of BrightPlan Group, Inc. (“BPG”). No individual or entity owns more than 25% of BPG. BrightPlan is focused on the Employee Financial Wellness market. Employers are recognizing that employee financial stress is impacting employee well-being and their bottom line. Stressed employees are less productive, miss more work, are less engaged and more likely to leave their jobs. Many employers are looking to Financial Wellness programs that provide education and tools to help employees adopt positive financial behaviors to manage their finances, achieve their long- term financial goals and help protect against key financial risks. BrightPlan works with employers who provide it as a benefit for their employees. Additionally, Employees may choose to invest through BrightPlan and pay an additional fee based on assets under management. BrightPlan is certified by the Centre for Fiduciary Excellence, LLC ("CEFEX") as having met their standards for Fiduciary Practices for Investment Advisors. The issuance of a Certificate of Registration and mark by CEFEX following the conclusion of the assessment process signifies that the investment advisor is generally meeting the Fiduciary Standard for the matters and for the time period covered by the certificate, subject to the limitations on scope expressed on the certificate. This certification is valid for twelve months. BrightPlan was first certified in 2017 and has been recertified every year since. B. Summary of Services Offered BrightPlan’s mission is to make financial success attainable for everyone. When you build a plan tailored to your unique aspirations and dreams, you can make better financial decisions. And better financial decisions can improve your probability of long-term success. BrightPlan works with employers who wish to offer the BrightPlan service as a Financial Wellness benefit to their US employees. BrightPlan uses patented, proprietary technology to provide integrated digital and human solutions to provide financial education, planning, investment, and day to day money management services through its website at www.brightplan.com and through its mobile application. BrightPlan’s service provides clients: ● The digital BrightPlan Financial Wellness Coach™ to guide clients to build their financial plan ● An overview of their personal finances including net worth, spending analysis, budgeting, debt reduction and cash flow tracking ● Asset allocation recommendations based on their unique goals and risk tolerance ● Ongoing monitoring of the plan to help clients stay on track ● Equity Compensation Planner to assist in the tracking of grants and vesting of equity compensation ● Education on financial topics, including managing personal finances, money and investing ● Access to a human financial advisor When clients prepare financial plans using the BrightPlan automated tools, each goal receives its own investment asset allocation recommendation. Clients may opt to personally apply BrightPlan’s recommendations on their own external accounts, see below BrightPlan’s non- discretionary services. In addition to the website and mobile application, clients have access to a team of financial planners via video conference and/or telephone. Financial planners can help clients evaluate their financial goals and objectives, and provide general assistance with the products and services provided by BrightPlan. They help clients evaluate their ability to meet their identified goal(s); however, they are not obligated to provide ongoing financial planning advice, update any analysis provided, or monitor Client progress toward a goal. BrightPlan

utilizes a sub-advisor to assist with these consultations and as such the financial planner may be a representative of BrightPlan or of BrightPlan’s sub-advisor. Please see Item 10 for more information about this sub-advisory relationship. Non-Discretionary Services Clients can use BrightPlan’s planning tools to discover their goals and receive a plan to reach them. By linking external savings, investment, employer-sponsored retirement plans, and other financial accounts, clients can track their progress toward their goals over time. After linking accounts, clients can also gain insights into their financial situation, including budgeting, the ability to monitor their net worth, cash flow, transactions, and investment strategy across their linked accounts. Each goal also includes a BrightPlan recommended asset allocation which clients can implement independently through their account custodian or plan sponsor. For goals linked to an employer- sponsored plan, if an employer opts into the service, the BrightPlan application is able to provide security specific recommendations. BrightPlan’s sub-advisor will analyze the investments available in the plan and recommend which securities to use to implement the asset allocation. The client is then responsible for working with their plan sponsor to implement the recommendation. Clients may adjust their goals and risk tolerance on the website at any time. Responsibility of Clients BrightPlan relies on client information to provide the services. Clients have the responsibility to review and update their profile information and to maintain current and accurate contact information. Recommendations will continue to be based on the client's profile information and it is the client's responsibility to advise BrightPlan through the BrightPlan Website or through a representative if there are any changes. It's important for clients to understand that their profile information, which is used to determine an appropriate asset allocation strategy, will not automatically update as a result of any changes client’s model on their own in any financial planning tool that is made available online. Third Party Service Provider Recommendations BrightPlan may also recommend the services of third-party non-investment service providers such as tax or accounting advisors. Clients are under no obligation to engage the services of any such recommended third-party service provider and are free to accept or reject any recommendation from BrightPlan. To the extent that a client engages a recommended service provider, such relationships will be directly between the client and such service provider and will be governed by any applicable terms and conditions associated with the engagement. C. Tailoring of Advisory Services and Client Imposed Restrictions Investment and financial planning advice are provided by BrightPlan’s proprietary software and algorithms, which are overseen and monitored by BrightPlan’s Investment Committee. Please see Item10 for more details. When a client signs up for BrightPlan’s services through www.brightplan.com, the client will be required to input information about his or her finances, life, financial goals, and tolerance for risk. BrightPlan’s proprietary software and algorithms use this information to generate investment and financial planning advice, including asset allocation recommendations. Each asset allocation strategy is one in a series of asset allocations that range from conservative (lower risk and return potential) to aggressive (higher risk and return potential). BrightPlan’s software and algorithms select one of several asset allocations that BrightPlan believes is most likely to help the client achieve the client’s goals, based on the information provided by the client. BrightPlan’s Investment Committee oversees this process and has approved each potential asset allocation. Please see Item 8 for additional information about the asset allocation process. BrightPlan’s services are not for investors looking to actively manage and trade within their own accounts. Clients are strongly encouraged to consider their individual circumstances, risk tolerance and needs prior to following any BrightPlan generated recommendation. D. Assets Under Management As of December 31, 2023, BrightPlan had no regulatory assets under management.