A. Background Webull Advisors LLC (“Webull Advisors” or the “Advisor”) is a Delaware domiciled Limited Liability Company and an SEC-registered investment advisor. Webull Advisors maintains its principal office at 200 Carillon Parkway, St Petersburg, FL 33716. Webull Advisors is a wholly owned subsidiary of Webull Holdings (US) Inc., a Delaware domiciled holding company which is a wholly owned subsidiary of Webull Corporation, a Cayman registered company. Webull Holdings (US) Inc. is also the parent company of Webull Financial LLC (CRD #289063)(“Webull Financial”), Webull Securities (US) LLC (“Webull Securities”), Webull Technologies Inc (“Webull Technology”), and Water Castle Holdings LLC. B. Advisory Services Webull Advisors offers investment advisory services to individual clients on a fully discretionary basis. This means the Advisor is authorized to trade within each client account to maintain the target investment allocation without client consent for each trade. The Advisor provides these “robo-advisory” portfolio management services via Webull Technology Pte Ltd.’s mobile application (the “app”). To participate, clients must enter into a Webull Advisors Customer Agreement and Webull Financial Customer Brokerage Agreement (collectively, “Advisory Agreement”), which provides full discretionary authority to Webull Advisors to manage the client’s assets. Client accounts are opened and maintained at Webull Financial pursuant to the Advisory Agreement. Webull Advisors uses model portfolios provided by an unaffiliated portfolio management firm. The type of investment advice offered is limited to those types of investments chosen by the portfolio management firm. The current portfolios range from conservative to maximum growth and primarily utilize Exchange Traded Funds (“ETFs”) and cash positions. See Item 8: Methods of Analysis & Investment Strategies for more information.

C. Tailored Services and Investment Restrictions Webull Advisors uses a Risk Tolerance Questionnaire (“RTQ”) to obtain client profile information including a client’s attitude towards risk, investment objectives, and time horizon. Based on this information, Webull Advisors will recommend an investment strategy based on one of six model portfolios with risk and potential return characteristics deemed most aligned with client’s scoring on the RTQ. Clients can select the proposed strategy or a strategy that is one risk level below or one risk level above the recommendation. The model portfolios are provided by one or more unaffiliated portfolio management firms (each, a “Portfolio Manager”). The current model portfolios range from conservative to maximum growth and primarily utilize Exchange Traded Funds (“ETFs”) and cash positions. Neither Webull Advisors nor any of its affiliates pays any compensation to any Portfolio Manager in connection with Webull Advisors’ use of their model portfolios. Robo-advisory services may not be appropriate for everyone. Clients should be aware that automated tools have certain limitations. Webull Advisors’ automated tools use predefined algorithms that are dependent on user input and do not consider unique circumstances. The usefulness of the results is limited by the information provided by the user. The Advisor’s recommendation could be materially impacted if a client provides inaccurate information or fails to update their information when it changes. Webull Advisors does not offer financial planning or other comprehensive or individualized investment advisory services. Clients should consider these limitations when deciding if a robo-advisory account is right for them. D. Wrap Fee Programs The Advisor offers a wrap fee program. E. Assets Under Management As of February 29, 2024, Webull Advisors has $24,745,709 in AUM.