A. General Description of Nomad Nomad Fintech Inc. (“Nomad”) is a software-based investment advisor registered with the U.S. Securities and Exchange Commission. Registration does not imply a certain level of skill or training but only indicates that Nomad has registered its business with regulatory authorities. Nomad Fintech Inc. was founded in 2019 and it is wholly owned by Nomad Fintech Holdings, LLC. The firm offers investment advisory services to its clients and manages their investment accounts through Nomad’s mobile app. Additional information about Nomad ownership structure and directors can be found in Schedule A of Part 1A of Nomad’s ADV form. B. Advisory Services Nomad’s advisory services result from the careful evaluation of market conditions, securities opportunities, and clients’ profiles by its investment staff. The investment decision-making at Nomad is carried out by an Investment Committee. The Investment Committee monitors the portfolios recommended to clients on an ongoing basis and may accordingly make revisions to the investment recommendations. The investment team has the authority to remove, add, or replace any element from the portfolios advised by Nomad. Nomad will maintain research files in connection with its investment recommendations. Through our mobile app, our clients answer a set of questions to compile their risk profile, and we propose selected funds that suit the relevant risk profile. In order to obtain a portfolio aligned with the client’s risk profile, Nomad has selected low-cost and best in class ETFs that represent either a multi-asset solution (complete portfolio) or a single asset class solution (e.g. a fixed income ETF), as well as investments in Real Estate Investment Trusts (“REITs”). Nomad offers non-discretionary investment services (where clients retain the ultimate responsibility for making investment decisions in their accounts). Nomad creates and curates a Basket of single stocks and/or ETFs (hereinafter “the Basket”), in which clients make the ultimate decision regarding the purchase or sale of such securities purchases. This type of service is recommended for clients classified in moderate, conservative

and aggressive risk profiles, however, any client can access it at his/her/their sole discretion. Nomad also provides clients with periodicals or newsletters and offers educational seminars/workshops that cover recent market and regulatory news for informational purposes. C. Tailored Services Nomad does not tailor clients’ portfolios to their individual financial goals. Rather, Nomad classifies clients according to their risk profile. As discussed in Item 4.B of this Brochure, the risk profile is determined through a set of questions answered by each client. After Nomad has classified a user within a risk profile, Nomad proposes a selected ETFs that suits the respective risk profile. On no less than an annual basis, Nomad will prompt clients to review and update the responses to previous responses utilized to assess a client’s risk profile, which is in turn utilized to propose selected ETFs. Nomad requests that clients reconfirm their responses as needed and on an annual basis, and encourages clients to update such information on an as-needed basis in response to material life events and changes in status. The accuracy and quality of the information provided by our clients have a direct impact on the applicability of Nomad’s recommendations, therefore, Nomad encourages clients to ensure that risk profile determinants and responses remain as up to date as possible to ensure that Nomad is providing recommendations that align with each client’s interests. D. Wrap Fee Programs Nomad offers its services through a wrap fee program in which clients are charged a single bundled fee that covers the investment advisory services it provides, as well as the brokerage and custodial services associated with holding and trading securities provided by DriveWealth LLC. Clients investing in The Basket will pay a monthly subscription fee of $5 USD. For more details on this fee please refer to Item 5: Fees and Compensation in section A. Advisory Fees. For certain clients, Nomad’s annualized wrap fee may be reduced by discounts and other promotions. E. Assets Under Management As of December 31, 2023, Nomad manages $215,028,770 USD on a non-discretionary basis.