A. General Description of Save Advisers Save Advisers is an investment adviser registered with the SEC. Save Advisers provides its clients with wealth management services through web-based algorithmically driven wrap-fee investment advisory programs (the “Save Advisory Services”). Save Advisory Services are described in the Save Advisers Wrap Fee Programs Brochure, attached to this Brochure. The Save Advisory Service launched in January 2021. Save Advisers is a wholly owned subsidiary of Fintex Holdings Inc., which is a privately held company headquartered in Houston, Texas. Michael Nelskyla, the Chairman and Chief Executive officer of Save Advisers holds more than 25% of the common shares of Fintex Holdings Inc. Additional information about Save Advisers’ products, structure and governance is provided on Part 1 of Save Advisers’ Form ADV which is available online at http://www.adviserinfo.sec.gov or at www.joinsave.com. We encourage visiting our website www.joinsave.com (the “Site”) for additional information. B. Summary of Investment Advisory Services Save Advisory Services currently offers our advisory clients’ (each, a “Client”) the choice of two wrap-fee investment advisory programs—the Save Advisers Market Savings Wrap Fee Program (the “Market Savings Program”), and the Save Advisers Market Trust Wrap Fee Program (the “Market Trust Program). All programs collectively shall be referenced as the “Wrap Fee Programs”. The core investment philosophy of Save Advisers is to generate stable returns for Clients’ Accounts across each of the products offered. These returns are created using market equivalent investments (“Equivalent Investments”) that do not require any Client outlay of capital, instead, utilize the economic value generated by those products (e.g. annual fees, interchange fees, interest, promotional incentives, fee rebates or other rebates) to directly benefit the Client Account in the form of investment capital. When purchasing Equivalent investments, Save buys strategy-linked securities whose value is equal to the notional value of the purchased strategy-linked security. The notional value accounts for the total value of the position, vs. market value which is the price at which that position can be bought or sold in the market. To execute that investment philosophy, each Wrap Fee Program utilizes a custom-structured private security, what Save Advisers refers to as a “strategy–linked security” to track a proprietary quantitatively driven strategy (collectively, the “Strategies”) developed by Save Advisers. As described more fully below, Save Advisers uses Quantitative Investment Strategy Techniques (“QISs”) to develop the Strategies. The investment goals of the Strategies are to maximize a portfolio’s expected return for a given amount of portfolio risk, equivalently, minimize risk for a given level of expected return, by selecting the proportions of various investment classes rather than selecting individual securities. Save Advisers uses QISs to develop various Strategies which utilize securities tracking investment classes (each, an “Investment Class”) in which to invest. Save Advisers will select an exchange traded fund (an “ETF”), call warrant (a “Warrant”), or other security (collectively with ETFs and Warrants, “underlyings”) to represent each Investment Class included within a Strategy. Investing in the Warrants is Not the Same as Investing in the Components of the Index - Your return on the Warrants, if any, will not reflect the return you would have realized if you had directly invested in the ETFs or other components of the Index. The actual calculation of the index does not involve the execution of any securities included as components of the Index. If the final level is sufficiently above the strike level, you will receive a percentage return on your initial investment that is greater than the percentage increase in the level of the Index from the pricing date. However, unlike a direct investment in the components of the Index, if the final level is less than or equal to the strike level, you will lose your entire investment in the Warrants. Each strategy–linked security and all cash balances in respect thereof will be maintained in a brokerage account at APEX Clearing Corporation (“APEX”), a member of the Financial Industry Regulatory Authority. Each Client will open a brokerage account at APEX pursuant to the Save Client Brokerage and Custody Agreement (the “Brokerage Agreement”). Additionally, for the Market Savings Wrap Fee Program - an FDIC-insured deposit will be maintained in a Client deposit account at the Bank Partner, if any, or otherwise at the FDIC-insured banking institution holding the deposit. Currently, Save Advisers offers only taxable Client Accounts and not tax-deferred programs. However, Save Advisers designed the Strategies with the goal of delivering returns in a more tax- efficient manner than typical for the industry. By indexing the underlying strategies and using investment vehicles such as ETF’s and warrants, any rebalancing activity in the strategy does not incur a taxable event. As provided in our Advisory Agreement (the “Advisory Agreement”) each of our Clients grants Save Advisers discretionary authority to manage its Client assets in its account(s) (each, a “Client Account”). 1. Save Advisers Market Savings (Market Savings) Wrap Fee Program The Market Savings Wrap Program is designed for investors with a cash savings investment profile. The investment objective of the Market Savings Wrap Program is to enhance our Clients’ cash savings investment profile by providing attractive returns on capital using Save ’s core investment philosophy while preserving their initial investment. The Market Savings Wrap Program customizes each Client’s portfolio based on the individual risk tolerances of that Client. With each deposit, Save Advisers will, on behalf of the Client:  Place each deposit in a Deposit Account with one of our FDIC insured Bank Partners and;  Purchase a strategy–linked security within the Client Account (at clearing brokerage), selected based on the risk tolerances of each Client. The deposit account is insured by the Federal Deposit Insurance Corporation (the “FDIC”) to the maximum extent permissible under law, which is $250,000 per depositor, per insured bank. The FDIC is an independent agency of the federal government that protects against the loss of insured deposits in the event an FDIC-insured bank or savings association fails. The FDIC is backed by the full faith and credit of the United States government. If any bank issuing an FDIC-insured deposit account in a Client Account fails, FDIC insurance will cover the deposit accounts, dollar for dollar up to the insurance limit for the given ownership category, including principal and any accrued interest through the date of the insured bank’s closing. Clients who make multiple investments over time will have multiple pairs of strategy– linked securities and FDIC-insured deposit accounts, each pair corresponding to its respective investment date. Save Advisers refers to each pair of a strategy–linked security and an FDIC- insured deposit account as a “Program.” Thus, as a Client makes additional deposits, another FDIC insured deposit is created within the client account with our Bank Partner. Save Advisers will then invest in another strategy–linked security thereby creating another Program. A Client Account may therefore have multiple Programs. Each Program has a predetermined scheduled maturity at which (or approximately by which) the strategy– linked security will mature, and the FDIC insured deposited funds related to the matured investment become available for earl or re-investment. The maturity terms for each Market Savings Program can vary. The Market Savings Program currently offers terms between one (1) year and five (5) years. Future programs may include maturity terms beyond five (5) years. Under the Market Savings Wrap Program, Save Advisers partners with banks (“Bank Partner”), where a FDIC-insured deposit account associated with the Program will be established for the Client. The Bank Partner’s sole responsibility is the provision of such deposit account pursuant to a deposit account agreement between Bank Partner and Client. The Bank Partner is not responsible for, and does not provide, any of the investment advisory or brokerage services discussed herein or for any Program. For each individual program that is created, Save Advisers will deduct the Program Cost (“Program Cost Obligation”) from the FDIC-insured Deposit Account within 7 to 10 business days, and use those funds to purchase the strategy-linked security corresponding with the risk tolerances selected by each Client. Save Advisers will credit back to the FDIC-insured Deposit account an amount that matches the deduction of the Program Cost Obligation. This rebate program ensures that no client outlay of capital is at risk of loss. Both the debit (Program Cost Obligation) and credit (Rebate) transactions will be viewable within the Client’s FDIC-insured account statement. The net result of these transactions will always amount to a zero (0) value change within the Client’s FDIC-insured deposit account; however, Save Advisers acknowledges that minor transactional time discrepancies may occur. The amount of the Program Cost Obligation and value of the subsequent purchase of a strategy-linked security will vary dependent on prevailing market interest rates. Upon purchase of each strategy-linked security, if any incremental funds remain due a difference between the economic value of the original Program Cost Obligation deduction and actual cost of the strategy-linked security, those funds will remain as a cash balance in the Client Account with Apex. Upon at least seven (7) days’ notice prior to the scheduled maturity of a strategy-linked security within the Client Account, the Client may instruct Save Advisers to remit the proceeds of the Program (and any cash in the Client Account) to an account directed by the Client. Absent direction from the Client, Save Advisers will reinvest the maturity proceeds of each Program together with any cash in the Client Account consistent with minimum denominations of the strategy-linked security. Any fractional remainder will be carried as cash until the next maturity date. If the Client does not elect to withdrawal funds post investment maturity, the maturity proceeds will fund a new Program using a deposit with the Bank Partner, as further described below under Save Advisory Service Wrap Fee Programs. Save Advisers will not retain compensation from the Bank Partner or pay any compensation to the Bank Partner in connection therewith. Save Advisers (like all other advisers) cannot guarantee any level of return on a Client’s initial investment. We believe what makes the Market Savings Wrap Program unique, is that the entirety of each Client’s initial deposit is placed in a deposit account insured by the FDIC. This means that at scheduled maturity of a Program the proceeds will be worth at least your initial deposit amount. In addition, Save Advisers developed a fee rebate program. This rebate feature means that for each Program, Save Advisers takes an advisory fee only if you receive positive net investment performance on that Program. 2. Save Advisers Market Trust Wrap Fee Program The Market Trust Program is designed for investors with a long-term investment profile. The investment objective of the Market Trust Program is to enhance our clients’ investment profile by providing attractive returns on capital using SAVE’s core investment philosophy while preserving their initial investment. The Market Trust Program is a hybrid product and service that includes allocations to an annuity contract and an investment within Save's portfolio of strategies. The Market Trust Wrap Fee Program customizes each Client’s portfolio based on the individual risk tolerances of that Client. Here's how Save Advisers manages a Market Trust Program for Clients: 1. Customer funds allocated to Market Trust will be deposited initially into a non- interest-bearing deposit account at a partner bank. The exact amounts

allocated for both the purchase of the annuity and the purchase of the investments may vary and are dependent on prevailing market rates. Customers will be able to view exact allocations within their SAVE account. 2. The majority of the Market Trust assets will be used to purchase an annuity contract issued by a life insurance company that is not affiliated with Save Advisers. When the annuity contract is ready for funding, Customer funds will be transferred from the deposit account to the issuing insurance company. The annuity contract will be held within a grantor trust where the client is the grantor of the grantor trust and the annuitant under the annuity contract; and the Company is the trustee of the grantor trust. 3. The majority of the assets that remain after the purchase of the annuity contract will be allocated to a third party custodial clearing broker and used by Save to purchase strategy-linked securities on the Customer’s behalf, with any remainder to be held as cash reserve in the Customer’s clearing broker account. The investment portion of the Market Trust account and service is provided by Save Advisers. Neither Save Advisers nor any of its investment affiliates is a bank. The annuity contract is backed by the issuing life insurance company, subject to its financial strength and claims-paying ability. The insurance companies that SAVE chooses for the Market Trust Program are all U.S.-domiciled life insurers that have been issued a B++ (Good) or higher Financial Strength Rating by A.M. Best. A.M. Best is a large third-party independent reporting and rating company that rates an insurance company on the basis of the company’s financial strength, operating performance, and ability to meet its obligations to contract holders. ANNUITY PRODUCTS ARE NOT GUARANTEED BY ANY BANK NOR INSURED BY FDIC OR NCUA/NCUSIF. NO BANK/CREDIT UNION GUARANTEE. NOT A DEPOSIT. NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY. Most jurisdictions require life insurance companies to participate in guaranty associations, which are organized to pay contractual benefits if an insurer licensed in their state becomes financially unable to meet its obligations and a court has declared it insolvent. These associations levy assessments, up to prescribed limits, on all member companies in the applicable state, based on the proportionate share of premiums in each applicable line of business written by the member companies. If an insurance company fails, each applicable guaranty association will pay claims up to the state’s statutory limits. The average amount of annuity protection from guaranty associations is $250,000 per contract owner. Clients who make multiple investments over time will have multiple pairs of strategy–linked securities and annuity contracts, each pair corresponding to its respective purchase date. Save Advisers refers to each pair of a strategy–linked security and an annuity contract as a “Program.” Thus, as a client adds funds to its Client Account, Save Advisers will purchase another strategy– linked security and another annuity contract therefore creating another Program; a Client Account may therefore have multiple Programs. Each Program has a predetermined term length at which (or approximately by which) the strategy–linked security will mature and the annuity contract will reach the end of the term. Save expects that the scheduled maturity will be approximately five years from the purchase date of each Program. Under the Market Trust Program, Save Advisers will partner with selected insurance carriers (“Insurers”). As a Program matures, the maturity proceeds will fund a new Program using a new annuity term with the Insurer. In addition, in the case of early termination of the annuity contract or the investments associated with the Program, additional costs or fees may be charged. These costs or fees may include trade execution costs, administration costs, and other fees as well as surrender charges and a market value adjustment (which may have a positive or negative effect on the annuity proceeds) in case of early withdrawal from the annuity. Each individual Insurer will provide its own surrender charge table for reference in case of early termination. In addition, IRS tax penalties may apply to withdrawals from the annuity contract prior to age 59 ½. Save Advisers will not receive compensation from any Insurer or pay any compensation to an Insurer in connection with the Market Trust Program. Save Advisers (like all other advisers) cannot guarantee any level of return on a Client’s initial investment. We believe what makes the Market Trust Program unique, though, is that a large majority of each Client’s initial investment is placed in an annuity contract. This means that at scheduled maturity of a Program the proceeds will be worth at least your initial investment. In addition, Save Advisers has developed a fee rebate program. This rebate feature means that for each Program, Save Advisers rebates the management fees accrued over the life of the investment if the returns don’t exceed the accrued management fees. THE INITIAL INVESTMENT IS GUARANTEED ONLY AT PROGRAM MATURITY, PREMATURE REDEMPTION CAN RESULT IN PRINCIPAL LOSS AND IRS TAX PENALTIES. Upon at least ten (10) days notice prior to the end of the annuity contract term within a Program, the Client may instruct Save Advisers to remit the proceeds of the Program (and any cash in the Client Account) to an account directed by the Client. Absent direction from the Client, Save Advisers will reinvest the maturity proceeds of each Program together with any cash in the Client Account consistent with minimum denominations of the annuity contract and purchase price of the strategy-linked security. Any remainder will be carried as cash in the Client Account custodied at APEX. Wrap Fee Accrual and Deductions. Save Advisers may, to the extent that there is cash in a Client Account, accrue fees on a daily basis and deduct accrued fees from the Client Account no later than the tenth business day of the following month, and any unpaid amounts will remain payable until there is sufficient cash or the scheduled maturity of the Program. Any uncollected wrap fees related to a given Program will be deducted from the Client Account no later than the tenth business day following the maturity of that Program. C. Tailored Services and Investment Restrictions Save Advisers tailors its investment advisory service to the individual needs of each of its Clients in accordance with a web-based algorithm (the “Recommendation Tool”). The Recommendation Tool uses Save Advisers’ proprietary algorithm to recommend a suggested Strategy (the “Suggested Strategy”). Save Advisers asks each prospective Client a series of subjective and objective questions to evaluate both the individual’s objective capacity to take risk and subjective willingness to take risk. The Recommendation Tool assesses each Client’s risk tolerance, investment experience, age, and liquid net worth. Based on these inputs, the Recommendation Tool recommends a Suggested Strategy from among three Strategies. The Suggested Strategy will be incorporated into the strategy– linked security in the related Wrap Fee Program. Clients will have the ability to designate a different Strategy from that recommended by the Recommendation Tool, including one that excludes at least one Investment Class. D. Wrap Fee Programs All Client Accounts at Save Advisers are managed under the Wrap Fee Programs which are professionally managed investment plans in which all expenses, including brokerage commissions (if any), management fees, and administrative costs are “wrapped” into a single charge for each program that the Client elects to participate in. This means that costs for clearing and settlement and other administrative costs are included as part of the wrap fee program. Each of the Save Advisers wrap fee programs provides Clients with investment plans, portfolio management, and necessary brokerage services for one comprehensive fee, outlined below for each program. Under each Wrap Fee Program, Save Advisers will invest in an initial strategy-linked security consistent with a Client’s responses to the Recommendation Tool and any Client requested modifications thereto. On or prior to each three-month anniversary of the establishment of the Client Account, each Client will receive a notice asking whether there have been any changes in the Client's financial situation or investment objectives and whether the Client wishes to modify or otherwise restrict the management of its Client Account by using the Recommendation Tool to reassess their risk profile. On or prior to each anniversary of the establishment of the Client Account, Save Advisers will contact each Client to make the same determination and use the Recommendation Tool to reassess their risk profile. Should the Client maintain the same risk profile Save Advisers will continue to manage the Client Account in accordance with the Client’s existing risk profile. Should the Client determine to reassess its risk profile, the Client must consult the Recommendation Tool to determine a revised Suggested Strategy and the revised risk profile will be incorporated into all strategy-linked securities added to the Client Account after the alteration of the Client’s risk profile (or with funds received upon the scheduled maturities of each strategy-linked security then in the Client Account). Upon addition of funds to the Client Account and at each scheduled maturity of an existing strategy- linked security, Save Advisers will manage the Client Account in accordance with the Client’s most recent risk profile. Clients should understand that any alteration of their risk profile will only be incorporated into investments in strategy-linked securities after the alteration of the Client’s risk profile (including investment of funds received upon scheduled maturities of each strategy-linked security then-existing in the Client Account). Save Advisers believes that this rolling implementation of the revised risk profile based on scheduled maturities of existing strategy-linked securities reflects Save Advisers’ buy and hold investment philosophy. The rolling implementation also prevents Clients from incurring transaction fees to liquidate the strategy–linked security. Clients must understand that implementation of any changes to their investments other than on this rolling basis will require termination of their Client Account. Specifically in connection with a Client Account termination under the Market Savings Program that does not coincide with the rolling basis described above, Save Advisers expects that early redemption of the FDIC-insured deposit will involve forfeiture of strategy- linked security returns pursuant to the terms of the [warrant][strategy-linked security]. See Item 16 for a description of Save Advisers’ discretionary investment authority, including the timing of Save Advisers’ responses to Client changes in risk profiles and withdrawal requests. Also, see Item 8 for a description of the potential losses that may result therefrom. In order to implement Save Advisers’ investment advice, Save Advisers only provides investment advisory and portfolio management services on a fully discretionary basis. E. Sub-Advisory Services Save offers Third-Party Investment Advisors the ability to offer Save Products and Services to their customers. In such circumstances, Save will receive its management fees as outlined under each Wrap Program. Third-Party Investment Advisors may also charge management fees to the customers in accordance with their own management fee schedules. Save will collect no additional fees outside of the fees outlined within each Wrap Fee Program. Each Third-Party Investment Adviser acts as the liaison between the customer and Save. The Third-Party Investment Advisor helps the client complete the necessary paperwork for Save, provides ongoing services to Save customers, will provide Save with any changes in client status as provided to the Third-Party Investment Advisor by the customer and review the quarterly statements provided by the Save. The Third-Party Investment Advisor will deliver the Save Form ADV Part 2, Privacy Notice and Solicitors Disclosure Statement directly to customers.