Advisory Services Zoe is a corporation organized in the State of Delaware and was formed in June 2016. Andres Garcia is the principal owner. Zoe sponsors the Zoe Financial, Inc. Wrap Program (the “Program”) described in this Brochure that is offered through investment advisor representatives (“IARs”) affiliated with third party registered investment advisory firms (“Advisors" or “Investment Advisors”) to their clients. The Program provides reporting, administrative services, and other services relating to the administration of client accounts managed by the Advisors. Advisors engage Zoe for the provision of such administrative, management, and support services on behalf of their clients. The Investment Advisors offer investment advice to clients and manage assets through the Program. To participate in the Program, a client will enter into an advisory agreement with his/her Investment Advisor that outlines the services to be performed by the Investment Advisor, the authority of the Investment Advisor and/or the client over transactions in the client’s account, the compensation to be paid by the client to the Investment Advisor, and agreement to terms governing participation in the Program. A client also will open a custodial account with Apex Clearing Corp. ("Apex"), who is the sole approved custodian for the Program and will hold client investments. ZOEFIN is not affiliated with Apex Clearing Corp. It is the responsibility of the Investment Advisor to gather sufficient information from the client to evaluate the client's financial situation, investment objectives, financial goals, tolerance for risk, and investment time horizon. Because the management of a client's investments is based on the client's financial circumstances, it is important that the client provides complete and accurate information to your Investment Advisor. The Investment Advisor is also responsible for determining whether the client's participation in the Program is appropriate for the client, and for selecting the appropriate investment strategy. The Program has a wrap fee structure that provides an Investment Advisor's clients with advisory and other services for a bundled fee with no additional account activity charges or transaction costs. The single bundled fee covers the administration fees, account maintenance fees, and trading and custody fees. The wrap fee is not based directly upon the actual transaction or execution costs for the transactions within a client's account. Under a typical wrap fee program, you pay a higher advisory fee and transaction costs are billed to your Investment Advisor. Please see below for additional detail regarding wrap fees and other fees you will be charged. You may receive comparable services from other broker-dealers or Investment Advisors and pay fees that are higher or lower than those charged under the Program. Fees may be more or less than you would have paid if the services (account management, custody, and brokerage transactions) were purchased separately outside of the wrap fee program. ZOEFIN is not a current client of any investment adviser included on the Zoe Advisor Network. Managed Account Program Investment Advisors are responsible for assisting clients in selecting an investment strategy and completing a suitability review. Pursuant to your investment management agreement with your Advisor, the Advisor has discretionary authority to buy, sell, or otherwise effect transactions in stocks, options, bonds, mutual funds, money market funds, exchange traded funds ("ETFs"), and any other securities in your account. Advisors will submit trade instructions directly to Apex for execution. Advisors also may grant Zoe the authority to submit trades per their instructions to Apex for implementation. This authorization may also include the ability to rebalance or reallocate the account, in which case Zoe will do so in accordance with the Investment Advisor's pre-determined investment criteria for the client. The rebalancing or asset reallocations may result in transactions in your account. At no time is Zoe responsible for providing investment advice to any Advisor's client or through its ability to submit trades and/or rebalance a client's account in accordance with the Investment Advisor's pre-determined investment criteria. Your Advisor will manage minimum cash in the account and can also define the minimum cash percentage as rebalancing account defaults. All stock and ETF dividends will be paid to cash unless requested otherwise at the time of onboarding. Your Advisor will have the ability to select the appropriate setting as part of the onboarding process. Client trades are sent to Apex. Apex aggregates client trades for execution, and allocates securities among client accounts on a pro-rata basis based on the average price of all securities that were block traded. Although stocks and ETFs may be traded throughout the day at market prices, the last trade instructions will be sent to Apex at or around 3 pm eastern standard time. You will receive notification of all transactions in your account in the form of a monthly account statement provided by Apex every month. You will remain the owner of all securities held in your account and have all ownership rights associated with these securities. ERISA Accounts Zoe currently does not offer the wrap fee program to ERISA covered retirement plans. Wrap Fees Zoe’s wrap fee includes account

management, trading execution, clearance, custody and reporting fees. Zoe's wrap fee is separate from the fees embedded in the securities purchased on your behalf and Zoe does not receive any portion of these fees. Zoe’s wrap fee will generally vary from 0.00% to 1.00% and is based on the client assets. Certain Investment Advisors may offer some or all of their clients discounted fees based on the amount of assets an individual client or the Investment Advisor has in the Program, the efficiencies gained by managing multiple clients for the same Investment Advisor, and our relationship with the Investment Advisor. Please refer to your investment management agreement for the exact fees you will be charged. Zoe will deduct the wrap fee from your account pursuant to your investment management agreement with your Investment Advisor. Unless indicated below, the wrap fee is based on the average daily account balance for the previous month. If your account was not open for the entire month, then the wrap fee will be prorated. Zoe's wrap fee is generally not negotiable, although we reserve the right to offer discounted fees, promotions, or waiver of fees under certain circumstances. Zoe may from time to time waive the service fees charged to the Investment Advisor which may reduce the fee charged to your account. You should carefully review all fees charged by us, your Investment Advisor, and any funds or ETFs you are invested in to fully understand the total amount of fees that are paid. It is your responsibility to verify the accuracy of the fee we charge to your account. The fee we collect will appear on your custodial statement, though Apex does not determine whether the fee has been properly calculated. Fees charged by us are separate and distinct from fees and expenses charged by mutual funds or ETFs traded within the Portfolio Program. Advisory Fees Your Advisor will charge you an advisory fee for the services it provides to you. Zoe is paid a wrap fee based on the client assets and has a financial incentive when your Investment Advisor recommends that you contribute more money to your account. Zoe receives a portion of the revenue from the advisory fee you pay to the Investment Advisor. You may be responsible for additional fees, including but not limited to, services fees relating to the Program and miscellaneous fees Apex may charge. Your advisory fee will be authorized by you during the account opening process and may only be increased by your written approval. Based on the schedule of advisory fees provided to Zoe, Zoe will calculate and deduct the advisory fees from your account in the manner specified in the agreement with your Investment Advisor. You should review the fees charged by your Investment Advisor which are outlined in your Investment Advisor’s Form ADV Part 2A. Fees paid to your Investment Advisor may include Zoe’s wrap fee. Because Zoe Financial’s contractual relationship with Advisors includes compensation from Advisors for their participation on the Zoe Advisor Network, Zoe Financial may have a material conflict of interest in referring Advisors to prospective clients. Mutual Fund and ETF Expenses Mutual funds and ETFs held in your account can incur additional administrative charges and/or fees or expenses, which may include management and administrative fees, 12b-1 fees and related servicing or marketing expenses, sub-transfer agent fees, deferred sales charges and other fees or expenses. Please consult the applicable prospectus or statement of additional information relating to your investments for more information. When investing in mutual funds, Apex charges Zoe an asset based fee when clients invest in certain funds and share classes. Zoe requires Investment Advisors to select mutual funds that are available on Apex's platform. However, in certain cases when certain mutual funds are not available via Apex, it is possible that you may incur transaction fees in addition to fees charged by the mutual fund. Cost of Program Compared to Separate Purchase of Services If the investment advisory services, brokerage, and custody services are paid separately, it is possible the cost of those services may be less than the wrap fees you pay for participating in the Program. We urge you to evaluate the costs relative to your unique personal circumstance. Fees for Additional Services The fees discussed above do not cover certain charges associated with securities transactions in clients’ accounts, including: (a) dealer markups, markdowns or spreads charged on transactions in over-the-counter securities; (b) costs relating to trading in certain foreign securities; (c) the internal charges and fees that may be imposed by any funds, (such as fund operating expenses, management fees, redemption fees, 12b-1 fees and other fees and expenses); (d) brokerage commissions or other charges imposed by broker-dealers or entities other than Apex if and when trades are cleared by another broker-dealer; and (e) the charge to carry tax lot information on transferred mutual funds or other investment vehicles, postage and handling charges, returned check charges, transfer taxes; stock exchange fees or other fees mandated by law. Trading and custody fees do not cover certain custodial fees that may be charged for specific account services, such as ACAT transfers, electronic fund and wire transfer charges, and for other optional services elected by clients.