A. Description of the Advisory Firm Magnifi LLC (“Magnifi”), a Delaware limited liability company, was formed on June 11, 2018. Magnifi is registered with the United States Securities and Exchange Commission (“SEC”) under Rule 203A- 2(e) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and therefore conducts business solely through an online advisory platform. The TIFIN Group LLC (“TIFIN”) is the principal owner of Magnifi. Dr. Vinay Nair is the Chief Executive Officer of Magnifi. Registration as an investment adviser does not imply any certain level of skill or training. B. Types of Advisory Services Investment Advice Magnifi’s proprietary web-based technology provides a natural language powered platform which enables users to navigate a universe of exchange-traded funds (“ETFs”), individual stocks, and mutual funds while using such information to build and/or enhance the user’s existing portfolios. Magnifi’s platform is utilized by investors, investment advisers, and wealth managers (the “Clients”). Magnifi’s algorithms use technology and science to personalize and facilitate discovery, comparison, and action in the investment process by generating investment recommendations based on Clients’ natural language searches, unique goals, investment types, risk tolerance, and other information inputted by the Client in Magnifi’s website and/or mobile application. Pursuant to each Client’s investment advisory agreement with Magnifi (each, an “IA Agreement”), Magnifi provides investment recommendations through its website and mobile application with the objective of enabling Clients to personalize their investment preferences, receive analysis and/or recommendations of ETFs, individual stocks, and mutual funds and create and edit mock portfolios and watchlists. Clients may utilize Magnifi’s platform to discover investments using natural language searches to analyze and compare information compiled by Magnifi’s web-based platform regarding ETFs, individual stocks, and mutual funds. Clients may build proposals and track aggregated investments directly on Magnifi’s platform. Clients who have a Magnifi account may also open a brokerage account with a unaffiliated broker- dealer (“Magnifi Investment Account”) so they can make trades based on the advice provided by Magnifi. In addition to providing advisory services to our Clients directly, we also offer technology solutions where by our services can be used by an asset manager partner with respect to that asset manager’s clients. Magnifi offers additional advisory services; Magnifi (Subscription) and Magnifi International, as described below: Magnifi (Subscription) Magnifi has a subscription offering providing value as an investing assistant using conversational artificial intelligence (“AI”). Through a chat bot experience, Magnifi gives users access to conversational investing guidance, portfolio insights, market intelligence, and educational resources to

help investors make more informed decisions. The chat bot employs a proprietary, closed environment AI model. Magnifi International Magnifi offers its technology services to financial professionals around the world. These financial professionals can put together their own model portfolios and track their performance through the system. They can share their ratings of individual investment funds with other financial professionals through community membership. These model portfolios are rated against benchmarks by Magnifi and the results are scored and compared across other professionals. This service is not available for retail investors. Non-Advisory Service: Platform Sponsorship Magnifi has entered into partnerships with various financial institutions that may be registered investment advisers to ETFs and/or mutual funds (collectively, the “Fund Managers”). Under these arrangements, Magnifi may license its proprietary web-based technology to the Fund Managers in connection with the Fund Managers’ own research and sales activities, and permit Fund Managers to sponsor additional features using Magnifi’s patented Fund Selector and Portfolio Enhancer to enhance the visibility of information provided about the ETFs, and/or mutual funds managed by the Fund Managers. By sponsoring personalized fund selectors identified as “Sponsored” in search results, Fund Managers can create awareness for their ETFs and/or mutual funds during the discovery phase to stand out with financial advisors during key fund comparison moments. Sponsored investment products will be returned as the top search results when clients use Magnifi’s search function, and are promoted on the website. Through its partnerships with Fund Managers, digital platform licensing fees and sponsorship fees are paid by the respective Fund Managers to Magnifi. C. Client-Tailored Services and Client-Imposed Restrictions Advisory services are tailored to achieve Clients’ searches. Magnifi provides limited investment advice and only through its website and mobile application. Security recommendations are made solely based on the search terms provided by the Client. Clients are urged to consult their financial professional for comprehensive financial advice relating to the recommendations provided by Magnifi. Magnifi currently provides investment recommendations with respect to exchange traded funds, closed-end funds, exchange-traded notes, mutual funds, and individual stocks. Investment recommendations may include sponsored funds for which Magnifi or an affiliate of Magnifi serves as a marketer pursuant to compensated sponsorship arrangements (“Sponsored Funds”). Magnifi has conflicts of interest when providing its services to Clients by recommending Sponsored Funds for which the Firm or its affiliate(s) receive fees and/or compensation. D. Amounts Under Advisement Magnifi has approximately $1,650,000 in non-discretionary assets under advisement as of December 31, 2023.