A. Description of Advisory Firm Investall, Inc., formerly known as ForeSCITE, Inc. until its name change effective November 2, 2022, a Delaware corporation formed in 2017, is an investment advisory firm that, through the use of a computer-generated algorithmic model, provides investment advisory services to third-party investment managers and advisers (“Investment Advisers”) who, in turn, may in their discretion utilize such advice in advising their own clients and investors (the “Investment Adviser’s Clients”), as well as to retail investors through a mobile app offered by Investall. Investall is owned by Chief Executive Officer and Chief Compliance Officer Balkrishna Shagrithaya, Jonathan Shah, and JAS Trust for which Abbas Shah serves as trustee. B. Types of Advisory Services Offered Investall provides advisory services to registered investment advisers and other qualified investment managers using a proprietary “dynamic beta” algorithmic model that selects exchange-traded funds (“ETFs”) and other securities across various asset classes based on relative value analysis, technological analysis and fundamental analysis and uses real time risk monitoring and dynamic allocation to allocate assets in a portfolio and rebalance monthly between asset classes and within sectors. The investment model makes all proposed investment allocations for the Investment Advisers’ consideration on a monthly basis. Investall delivers its monthly portfolio allocations and buy-sell signals to the Investment Advisers via electronic secure file transfer protocol, application program interface or other secure arrangements. Upon generation and delivery of such signal: (i) the Investment Adviser may use the information delivered by the signal at their discretion in advising their own clients; (ii) the Investment Adviser may ignore, in whole or in part, the signal and not follow it; or (iii) the Investment Adviser can authorize Investall to submit the signals and signal-related information directly to the Investment Adviser’s designated broker-dealer or its execution platform so the broker-dealer can affect the reallocation. Generally, monthly trade signals are executed for the Investment Adviser’s client accounts by rebalancing automatically through the Investment Adviser’s execution platform. In addition, Investall provides risk monitoring and intra-month rebalancing. The algorithmic model includes risk analysis that evaluates various market-impacting risk factors that may materially and adversely impact a portfolio at such time. This risk-monitoring mechanism, when triggered, may signal an intra-month portfolio rebalancing in addition to the monthly reallocation signal. The services provided to the Investment Advisers are also

provided to retail investors through a mobile app offered by Investall. Investall has no direct contact with the clients of the Investment Advisers or users of its mobile app and does not provide any services directly for the clients of the Investment Advisers or users of the mobile app other than trade execution as described in clause (iii) above. In both instances described, brokerage and custody services are provided by third parties or the Investment Advisers themselves. Neither Investall nor its affiliates have custody of client funds, nor does it provide brokerage services. C. Services Tailored to Individual Needs of Investment Advisers and Retail Investors Investall’s advisory services are tailored to the management of each Investment Adviser’s account to the extent that each Investment Adviser provides Investall with information regarding securities positions, assets and cash balances of the Investment Adviser and its clients, which Investall enters into its investment model. Investall’s investment model then makes proposed allocations for the Investment Adviser’s consideration, and such Investment Adviser interacts directly with its own clients. Investall does not model around an Investment Adviser or Investment Adviser’s Client’s restrictions and does not take steps to tailor its signals based on an Investment Adviser’s or Investment Adviser Client’s risk profile. With regards to Investment Advisers that use Investall’s advisory services pursuant to clause (i) in Section B above, such Investment Advisers may adjust their own portfolio and that of their clients at their own discretion and are not bound to take Investall’s signals. In addition, while Investall may be provided authorization from its clients to provide allocation signals directly to the client’s broker-dealer or the applicable execution platform, Investall does not give discretionary advice. Investall tailors its advisory services to retail investors as well as for Investment Adviser Clients of Investall. Retail investors receive the proposed allocations and determine whether to implement them or not. D. Wrap Fee Programs Wrap fees are comprehensive fees charged to a client for providing a bundle of services, such as investment advice, investment research and brokerage services. Investall does not participate in wrap fee programs. E. Investment Adviser Assets As of December 31, 2023, Investall did not have any assets under discretionary management. Investall does not manage client funds. Investall provides portfolio allocation signals to Investment Advisers and mobile app users. The Investall signals are being employed on approximately $ 26,551,726 in total assets.