A. Firm Description Monorail Securities LLC(“Monorail Securities” or the “firm”) is a Florida limited liability company. The firm was formed in June 2016, and the principal owner is Vimvest Holdings, LLC (“Holdings”). Holdings is principally and indirectly owned by Phillip Dickson, Stuart Dickson, and Margaret Hixon. Advisory Services Offered Portfolio Management Services Monorail Securities provides portfolio management services to its clients via an online interface. Currently, the firm’s only offering is a number of model portfolios (the “Portfolios”) composed of exchange-traded funds (“ETFs”). This entails the use of algorithm-based portfolio management advice rather than in-person investment advice. Through the firm’s online platform, clients will establish an investment advisory account with Monorail Securities. Clients are also given the option of subscribing to the Monorail online app, through which they can elect to open self- directed trading accounts and/or Monorail-managed investment advisory accounts through Viewtrade. Monorail Securities will provide clients with custodial and execution services necessary to effect trades in client accounts according to the level of account assets that are assigned by the client to the Portfolios in accordance with the terms of the program agreement. All clients receive Monorail Securities’ discretionary advisory services over the internet. There is a $5 minimum investment requirement. Clients are given access through a computer app to a risk questionnaire to complete when they open an investment account. Based upon information input by the client, Monorail Securities, through the platform, generates an asset allocation, and selects among Portfolios composed of twelve ETFs in a proportion to fulfill the specific client’s system-generated asset allocation. Pursuant to the client’s authority, Monorail Securities will have the limited authority, without further direction from client, to allocate assets within the available Portfolio(s) selected by the client, which are composed of ETFs and cash (“portfolio components”) that are constructed, monitored, and modified by Monorail Securities for the program. Clients also retain the ability to make adjustments to their profile, which in turn may result in a new asset allocation among the Portfolios made available through the platform. Monorail Securities generally limits its investment advice to publicly traded ETFs and specifically utilizes a limited number of ETFs in its Portfolio structures depending on the level of risk tolerance a client is willing to assume. Monorail Securities utilizes modern portfolio theory and efficient frontier to construct its Portfolios as further described in Item 6 of this brochure. When Portfolio changes are identified, such as the addition of new clients, changes to an asset allocation, and the underlying ETFs utilized, orders are aggregated and generated during the course of the applicable trading day, and a draft of the order file is sent to Monorail Securities for review and approval. Once approved, the trades are generally executed throughout the day on the day following the date the approval was processed. The firm, through its contractual commitments with clients, provides for a three-day trading window; therefore, please be aware that as a result given market fluctuations, corrections to the trade file, etc., trades may be executed at prices higher or lower than the day the trade recommendations were generated. Monorail Securities does not construct the Portfolios based on the specific investment objectives or limitations of the client, but instead constructs and continually rebalances the Portfolios among the portfolio components to achieve their differing investment objectives. Monorail Securities will have authority to buy or sell portfolio components directly for client accounts for the Portfolios, which are based upon client profile inputs selected by the client. The client will determine how much of the assets are allocated to each Portfolio via the platform’s functionality. Clients should understand that changes they make to their profile do not cause the system to automatically change their allocation or investments. Clients must proactively change their allocation through app’s functionality. Monorail Securities does not have any authority respecting any client assets not in the account, and Monorail Securities will not have any authority to access any of the client’s assets – in the account or otherwise – except for Monorail Securities’ authorization to deduct its fees directly from the underlying program account. Similarly, Monorail Securities does not have authority to alter how much client assets are in particular Portfolios – it only has authority to rebalance assets once a client has determined how much to invest in the Portfolios. The Portfolios are not a comprehensive asset management service. For example, the Portfolio components are limited to cash and a limited number of ETFs, and therefore severely constrains the universe of potential investments in the Portfolios. The composition and operation of the Portfolios is done through automation, meaning their ability to achieve stated objectives is necessarily limited and subject to their design. The program limits Portfolio transactions at certain times of the trading day, and only rebalances Portfolios if certain events occur. Changes made to the client’s allocation among Portfolios (including withdrawals, re-allocations, or deposits) will necessarily alter the outcomes of the investment’s allocations. Clients agree to promptly inform Monorail Securities, via the platform, if the information provided, including client’s investment objectives, goals, risk tolerance, other personal and financial circumstances, time horizon, and investment experience becomes inaccurate, and to provide updated information, if any, about the client’s financial circumstances and investment objectives. Goal-Based Advisory Services through Viewtrade Our goal-based software allows clients to identify and segregate investment goals. The goals remain in place until the client proactively closes their goals. Any automatic funding (automatic deposits) will continue until the client manually shuts it off. The client may choose to close one or more of the account’s goals at any time. In order to do so, the client must liquidate and withdraw all funds from the goal before it can be closed in the app. Fees and Compensation Portfolio Management Services Fees The annual fee for the Portfolios is calculated using the value of the assets on the last business day of the prior billing period according to the following fee schedule, which represents the firm’s maximum fees for individual services. Total Assets Under Management Annual Fee Rate Monthly Subscription Fee for Monorail App* All assets 0.25% $3.00 *The subscription fee is in addition to the asset-based fee, applied to each user on the account. For example, on an account with $10,000 and one user, the annual fee is $28 (10,000 x .0025 + $3); on a joint account with $10,000 and two users, the annual fee is $31 [(10,000 x .0025) + ($3 x 2)]. Asset-based

fees are always subject to the investment advisory agreement between the client and Monorail Securities. Such fees are payable quarterly in advance. The fees will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar month. The trading cost component of the above-mentioned advisory fees are estimated to range from $50 to $250 per account per year. These fees include charges for all transaction costs such as commissions on purchase and sales of stocks, bonds, exchange-traded funds and options, and mutual fund transactions fees. Except as otherwise provided below, client will incur no charges other than the adviser’s fee pursuant to the above fee schedule in connection with the maintenance of and activity in client’s account. The wrap fee does not include private alternative investment fees and expenses, annual account fees or other administrative fees, such as wire fees, charged by manager or brokerage firm; fees for securities transactions executed away from the custodian; certain odd-lot differentials, transfer taxes, transaction fees mandated by the Securities Act of 1934, postage and handling fees, and charges imposed by law with regard to transactions in the client’s account; and advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds), closed-end investment companies or other managed investments, if any, held in client’s account. The wrap fee also does not cover certain costs associated with securities transactions in the over-the-counter market, such as fixed income securities where manager must approach a dealer or market maker to purchase or sell a security. Such costs include the dealer’s mark-up, mark-down or spread and odd-lot differentials or transfer taxes imposed by law. The client authorizes the qualified custodian to automatically deduct the fee and all other charges payable hereunder from the assets in the account when due with such payments to be reflected on the next account statement sent to the client. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. Monorail Securities may modify the fee at any time upon 30 days’ written notice to the client. B. Disclosure of Cost Difference if Services Purchased Separately Depending on a number of factors, such as the number, size and nature of the securities transactions in an advisory account, the overall fees and charges borne by the client over time could be more or less than what these fees and charges would be if the same services were provided on a separate basis. Bundled fees generally provide an economic incentive for the advisory firm to select investments and strategies that minimize trading costs. Frequent trading in an account where transaction fees are included as part of the overall advisory fee to the client drive trading costs higher and reduce the overall fee revenue to the advisor. As a result, higher trading costs in a bundled fee account have a negative impact on the advisory firm’s profitability. C. Additional Client Fees and Terms of Payment Client Payment of Fees Portfolio Management Services Fees Monorail Securities generally requires fees to be prepaid on a quarterly basis. Monorail Securities requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. Subscription fees will be paid on the Monorail online app with the subscriber’s credit card. Monorail Securities will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. A client investment advisory agreement may be canceled at any time by the client, or by Monorail Securities with 30 days’ prior written notice to the client. Upon termination of any account, any unearned, prepaid fees will be promptly refunded. A subscription to the Monorail app may be canceled by the client at any time for any reason but will continue until the end of the subscription period. The subscription will auto-renew unless canceled by the client before the end of the subscription period. No refunds will be issued if the subscription is terminated before the end of the subscription period. Prepayment of Client Fees Monorail Securities collects fees in advance. Refunds for fees paid in advance will be returned within fourteen days of the effective date of the termination via check, or return deposit back into the client’s custodian account. For all asset-based fees paid in advance, the fee refunded will be equal to unearned fees for the balance of the quarter beginning on the effective date of the termination through the last day of the quarter in which the termination became effective. Additional Fees All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by ETFs, investment advisers, and trade-away fees imposed by broker-dealers and custodians, if any. Such fees and expenses are described in each ETF prospectus, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. A client using Monorail Securities’ product offering may be precluded from using certain ETFs because of their lack of availability on our platforms or otherwise may not be offered by the custodian. Please refer to the Brokerage Practices section (Items 9.B.2 and 9.B.3) for additional information regarding the firm’s brokerage practices. D. Compensation for Recommending the Monorail Securities Wrap Fee Program The Monorail Securities Wrap Fee Program is a proprietary product offered exclusively through Monorail Securities. As such, there is a conflict of interest in that we are economically disincentivized to trade your portfolio. The less we trade the more money we make, as our wrap fee includes trading costs. E. External Compensation for the Sale of Securities to Clients Monorail Securities’ advisory professionals are compensated based upon a salary and bonus. Certain personnel are registered with an insurance agency and may be paid sales, service, or administrative fees for the sale of insurance products. Please see Item 9.A.2 for detailed information and conflicts of interest. F. Client Assets Under Management As of December 31, 2023, Monorail Securities had $0 of discretionary assets and $146,815 of non-discretionary assets under management. Item 5: Account Requirements and Types of Clients