A. General Description of the Firm MLW is an automated internet and mobile phone-based investment advisory service, registered with the Securities and Exchange Commission (“SEC”) as of September 20, 2017. MLW provides discretionary and non-discretionary investment advisory services for client accounts exclusively through an online interface (the “Site”) and mobile phone application (the “MoneyLion App”). On September 22, 2021, MoneyLion Inc. consummated its business combination (the “Business Combination”) with Fusion Acquisition Corp., a Delaware corporation (“Fusion”), pursuant to the terms of the Agreement and Plan of Merger, dated as of February 11, 2021 and amended on June 28, 2021 and September 4, 2021, by and among Fusion, ML Merger Sub Inc., a Delaware corporation and a wholly owned subsidiary of Fusion (“Merger Sub”), and MoneyLion Inc. In connection with the Business Combination, (i) Merger Sub merged with and into MoneyLion Inc., with MoneyLion Inc. surviving the merger as a wholly owned subsidiary of Fusion, (ii) MoneyLion Inc. changed its name to “MoneyLion Technologies Inc.”; and (iii) Fusion changed its name to “MoneyLion Inc.” MLW is wholly owned by MoneyLion Technologies Inc., which is wholly owned by MoneyLion Inc. Upon completion of the Business Combination, MoneyLion Inc. was publicly listed on the New York Stock Exchange under the stock ticker “ML”. Unless the context otherwise requires, “MoneyLion” refers to the post-Business Combination MoneyLion Inc. and its consolidated subsidiaries. B. Summary of MLW’s Advisory Services Discretionary Investment Advisory Services For its discretionary investment advisory services, MLW utilizes its Site and the MoneyLion App to collect personal investment criteria with respect to client profiles, with a view toward assessing clients’ risk tolerances, age, and time horizon to determine appropriate investment strategy. This profile information is used to determine overall client suitability for the managed investing account (“Managed Investing Account”). MLW will invest client assets into Exchange Traded Fund (“ETF”) model portfolios that reflect the clients’ stated risk tolerance, age, and time horizon (the “Asset Allocation Strategy”). Each client’s Asset Allocation Strategy will reflect one of five ETF model portfolios based on a client risk profile (conservative, moderately conservative, moderate, moderately aggressive, aggressive). Clients can also override the recommended Asset Allocation Strategy after account funding and choose a different one of the five portfolio models, or clients may opt into an equity-only ETF model or a fixed-income-only ETF model. MLW’s selection of portfolios will be based on clients’ responses to a risk questionnaire and, although MLW will gather additional information as part of the account creation process, the Asset Allocation Strategy is currently based on stated risk tolerance, age, and time horizon. MLW will provide detail to clients with respect to the allocation of securities in the ETF portfolio MLW has recommended. The Asset Allocation Strategy uses highly liquid, low-fee ETFs and takes into consideration historical and projected risks and rates of return. In addition to the Asset Allocation Strategy recommended by MLW or selected by the client, clients may also elect to invest in various strategic thematic portfolios (the “Thematic Portfolios”), which are designed to address specific investment interests or themes (e.g., innovative technological or disruptive consumer trends, sustainable and socially responsible behavior, a focus on distribution of dividends, etc.). Any Thematic Portfolios selected by the client will be implemented along with the client’s Asset Allocation Strategy in a single account. Clients choosing to invest in Thematic Portfolios have the option to identify their desired thematic models and modify the target weightings for their selected allocation (both in their Thematic Portfolios and Asset Allocation Strategies). Clients will have discretion in the selection of any Thematic Portfolios made available to them, which will be in addition to the Asset Allocation Strategy recommended by MLW or selected by the client. MLW has discretion with respect to how each Thematic Portfolio is managed, and the ETFs into which each Thematic Portfolio invests. MLW does not identify or recommend particular Thematic Portfolios, and not all Thematic Portfolios will be available for all clients. Over time, MLW may choose to increase or decrease the number and types of Thematic Portfolios that are available to clients, and modify the type of securities offered within a Thematic Portfolio. MLW offers clients the option to select from pre-populated goals or create a customized goal within their Managed Investing Account to help clients track and visualize their personal investment progress. After setting up one or more goals, clients can attribute a portion of their investments to each goal, including a goal of general investing. The selection or creation of goals and the attribution of percentages of the client’s investments to each goal does not impact the client’s existing underlying investments or Asset Allocation Strategy. Future investments will continue to be invested according to the client’s Asset Allocation Strategy, but the visualization of the client’s goals will reflect the attribution selected by the client. When a client removes a goal, the goal will be removed and investments will appear as part of the general investing goal. If the client reaches the target amount for a goal, the client will be notified that the goal has been achieved but the client’s attribution of percentages amongst the goals will remain consistent with their original attribution unless the goal is removed or the attribution is otherwise updated by the client. Non-Discretionary Investment Advisory Services For its non-discretionary investment advisory services, MLW offers members of the WOW membership program offered by MoneyLion (as described in the section below) the ability to obtain and maintain an active investing account (“Active Investing Account”). MLW utilizes the Site and the MoneyLion App to provide its clients with non-discretionary investment advice with respect to such Active Investing Accounts. The non-discretionary investment advice includes MLW’s selection of various publicly traded securities, including ETFs, shares of stock of publicly traded companies (“Single Stocks”), and/or similarly traded instruments (collectively, “Active Securities”), that are made available to its clients for purchase and sale at the client’s discretion in their Active Investing Accounts. Not all individual stocks, bonds, or options will be made available by MLW for Active Investing Accounts. MLW also provides non-discretionary investment advice in the form of a suite of tools that uses qualitative and/or quantitative inputs to analyze, rank, and/or otherwise distinguish publicly traded securities and/or portfolios of such securities based on various investment characteristics and/or factors according to research conducted by MLW, its affiliates, and/or third- party service providers to assist a client with securities selection, building a portfolio and/or monitoring their portfolio. Over time, MLW may choose to increase or decrease the number and modify the types of Active Securities that are available to clients as part of MLW’s non-discretionary investment advice. MLW may change the Active Securities available through the Active Investing Account that MLW deems appropriate to address the investment objectives, investment time horizons, and risk tolerances of its clients. Clients will receive notice of forthcoming changes to the universe of Active Securities if it impacts the Active Securities that are held in their Active Investing Accounts. Clients may change the Active Securities held in their Active Investing Account at any time, subject to MLW’s Day Trading Policy, the Advisory Agreement and the Terms of Service applicable to the Site and the MoneyLion App. Please review the relevant policies and agreements for further information. Clients are solely responsible for the decision to invest in Active Securities in their Active Investing Account. MLW does not have authority or discretion to designate the Active Securities for purchase or sale in clients’ Active Investing Accounts. However, DriveWealth LLC (“DriveWealth”), the clearing broker and custodian for client accounts offered by MLW, including Active Investing Accounts, may require MLW and its clients to sell or liquidate a position if one or more Active Securities becomes subject to a corporate action or other event that results in its delisting and becoming unavailable for trading on a public exchange. Clients will receive notice of such sales or liquidations. MLW has no obligation to and does not rebalance the assets in clients’ Active Investing Accounts or purchase or sell any Active Securities at any particular time or at any particular share price. For example, there could be certain delays in the amount of time it takes DriveWealth to execute each transaction if the trade is placed outside of market hours, in which case it will be processed at the start of the next trading day, or due to unanticipated technical errors or outages that may impact MLW and/or DriveWealth. Although trades placed during market hours are generally expected to be executed by DriveWealth within seconds, any delays in placing or executing transactions could reduce, perhaps materially, any profit earned in each Active Investing Account or could cause a material loss. The Membership Programs MLW’s automated internet and mobile phone-based investment advisory service can be accessed as just one of many components of the MoneyLion Credit Builder Plus or WOW membership programs offered by ML Plus LLC (“ML Plus”). The membership programs provide access to MLW’s professional portfolio management services, in addition to other tools provided by ML Plus or other MLW affiliates, and

not MLW, that seek to enhance clients’ credit, financial well-being and financial literacy. ML Plus is a non-adviser entity under common control with MLW and MoneyLion Technologies Inc. is the direct parent and sole owner of MLW. Non-members can obtain and maintain a Managed Investing Account outside of the membership (see Standard Services section below). Additional services in the membership programs are not provided by MLW, and may include, but are not limited to, access to partially secured installment loans (“Secured Loans”) that are originated by non-MLW, non-adviser entities that are under common control or otherwise affiliated with MLW (“Lenders”), credit monitoring analytics tools, monthly credit reporting to credit bureaus, financial literacy materials, bank accounts and debit cards, and other rewards opportunities. For a more complete description of ML Plus and other related entities, please refer to Item 10. Membership in the Credit Builder Plus program costs clients $19.99 per month, subject to change in MoneyLion’s sole discretion. The membership fees are charged by ML Plus and not by the MLW investment adviser. Clients have the opportunity to earn back their entire membership fee each month by engaging with the app daily and making purchases with their MoneyLion debit cards. Membership in the WOW program costs clients $9.99 per month, with reduced rates available for memberships paid semi-annually or annually. Membership rates are subject to change in MoneyLion’s sole discretion. The membership fees are charged by ML Plus and not by MLW. Only WOW members can obtain and maintain an Active Investing Account. Members in both the Credit Builder Plus and the WOW membership programs may incur additional fees or costs depending upon the services they use in connection with their membership. Standard Services Outside of the two membership programs described above, clients can also access MLW’s automated and mobile phone-based investment advisory service directly by obtaining and maintaining a Managed Investing Account (as previously described under Discretionary Investment Advisory Services in Section 4). Non- members do not need to pay a monthly membership fee, but will be subject to a monthly account fee (as described in Section 5). Non-members will have access only to a limited subset of the non-advisory offerings and membership benefits available to either Credit Builder Plus members or WOW members. Non-members may incur additional fees or costs depending upon the services they use. Credit Builder Plus Loans Clients in either the Credit Builder Plus or the WOW membership program are eligible for Secured Loans, which are originated by Lenders affiliated with Adviser. Secured Loans are non-purpose loans, meaning that the proceeds of the loan may not be used to purchase or carry margin securities (including margin stock). In order to obtain a Secured Loan, clients will be required to (i) establish a “Credit Reserve Account” in the client’s name at DriveWealth; (ii) pledge the cash and securities in their Credit Reserve Accounts as collateral for the loan; and (iii) enter into a Securities Account Control Agreement with Lender and DriveWealth. Depending upon the creditworthiness of the client as determined solely by Lenders, clients may be required to deposit a portion of their loan principal in their Credit Reserve Account until the loan is paid off (the “Required Deposit”). Funds in the Credit Reserve Account will be held solely in non-marginable securities, which for this purpose includes, but is not necessarily limited to, DriveWealth’s available money market fund or FDIC bank sweep products. For so long as the assets in the Credit Reserve Account are pledged as collateral for the Secured Loan, MLW will not have investment authority over the investments held in that account as restricted by the Lender. Clients will not be able to withdraw any portion of their Required Deposit until they have paid back the full principal and interest of their Secured Loan. However, clients can pay off their Secured Loan early at any time without penalty, and can use the funds in their Credit Reserve Account to do so, as long as the balance in their Credit Reserve Account exceeds the outstanding balance on their Secured Loan. The amount of the Required Deposit may differ between clients depending upon applicable underwriting criteria and the terms of their Secured Loans. Clients are not able to request any modification to, or impose any restrictions on, the non-marginable securities into which their Required Deposit is held. Although the Required Deposit in a client’s Credit Reserve Account belongs to the client and will be held in their name, it will serve as collateral for the Secured Loan. Clients will not be able to identify specific securities or types of securities within their Credit Reserve Accounts to be pledged as collateral to a Secured Loan. If a client defaults on their Secured Loan, the Lender or its affiliates may direct DriveWealth or MLW to sell, with or without giving additional notice to the client other than the notice of default or such other notice as required by applicable law, electronically or by mail, all or any part of the Credit Reserve Account, and have cash or securities proceeds deposited or transferred over to the Lender for payment or set off against the client’s outstanding Secured Loan balance. Round Ups Clients who have an MLW Managed Investing Account as well as a qualifying bank account linked to the MoneyLion mobile application, can enable the Round Ups feature to automatically transfer funds from their qualifying bank account to their Managed Investing Account. Clients authorize the transfer of funds when they enable the Round Ups feature. When a client makes an eligible purchase through their qualifying bank account, the transaction will be rounded up to the nearest dollar with the difference being the “Round Up” amount. When the aggregate total of the Round Up amounts meets a threshold determined by MLW, it is transferred out of the client's qualifying bank account and deposited into their MLW Managed Investing Account. All Rounds Ups deposited into the client’s Managed Investing Account will be invested according to the client’s Asset Allocation Strategy. NFP Portfolios MLW has a relationship with NFP Retirement, Inc. (“NFP”), an unaffiliated investment manager, under which NFP will provide certain model portfolios (the “NFP Portfolios”) that will be offered to clients who sign up for a Managed Investing Account through NFP's WellCents portal. MLW will recommend the appropriate NFP Portfolio to each such client based on the client's stated risk tolerance, age, and time horizon. MLW is responsible for implementing the NFP Portfolios in client accounts. Clients are able to change their NFP Portfolio by selecting a different NFP Portfolio after the initial creation of their Managed Investing Account. NFP Portfolios will be available only to eligible clients who sign up for a Managed Investing Account through NFP's WellCents portal, and such clients will not have access to other portfolios or investment options that MLW offers, including the Thematic Portfolios. MLW will charge an NFP Fee (as defined in Item 5 below) for clients who sign up for a Managed Investing Account through NFP’s WellCents portal. The NFP Fee will be paid to NFP and is separate from the Account Fee (as defined in Item 5 below) that is charged by MLW on each Managed Investing Account. NFP clients are not required to access MoneyLion through NFP and instead may open a Managed Investing Account with MLW directly. If an NFP client opens a Managed Investing Account directly, they would only be subject to MLW’s Account Fee, but the client would not be able to invest in NFP Portfolios. C. Personalized Services and Investment Restrictions For its discretionary investment advisory services, MLW’s investment advisory platform will evaluate key elements of the client’s investment profile to determine an appropriate allocation of ETFs based on the information provided by the client. Elements currently considered are limited to the client’s stated risk tolerance, age, and time horizon. More information on the Asset Allocation Strategy can be found in Item 8. Clients may not impose restrictions on investing in certain securities or types of securities, but are able to change their Asset Allocation Strategy at any time through the MoneyLion App. Clients may also further customize their Asset Allocation Strategy after account funding by selecting an equity-only ETF model or a fixed-income-only ETF model, or by investing in Thematic Portfolios. For its non-discretionary investment advisory services, clients are limited to the purchase of Active Securities made available to them through the Site and the MoneyLion App and Other Advice provided to clients for their use in making investment decisions related to their Active Investing Account. D. Participation In Wrap Fee Programs Wrap fee programs are generally arrangements between broker-dealers, investment advisers, banks and other financial institutions and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. MLW clients do not pay any investment management fees or brokerage execution fees. Brokerage execution fees are paid by MLW. However, clients pay an Account Fee on Managed Investing Accounts and other fees are paid to MLW affiliates as explained more fully in Item 5. MLW does not presently participate in, and is not a sponsor of, any wrap fee program. Clients may pay other fees charged by DriveWealth, including but not limited to ACAT fees. E. Assets Under Management MLW manages the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2023: Discretionary: $ 10,464,255 Non-discretionary: $ 111,475