Clarivor is an investment adviser firm registered with the U.S. Securities and Exchange Commission (“SEC”) as of August 17, 2020 under Rule 203A-2(e) of the Investment Advisers Act of 1940 (the “Act”). The principal owner of Clarivor is Jonathan Spiegel, Managing Member. Clarivor’s primary business is providing fee-based custom portfolio management services over the Internet. Clarivor focuses on the construction of customized, rule-based investment strategies utilizing its automated system. The strategies generally use options with the aim of achieving investment objectives such as yield, protection or risk-adjusted returns. Through its software, Clarivor provides analysis of these strategies, and clients may select and invest in customized portfolios of these strategies. Additionally, Clarivor offers Internet-based discretionary management, for both customized portfolios and model portfolios, based on objectives and constraints that clients provide to Clarivor through its website. Clarivor primarily uses exchange-listed options, ETFs and stocks to construct portfolios. The exchange-listed options may include ETF options, including bond and/or commodity ETFs, index options, and single-stock options. Clarivor may recommend, on occasion, redistributing investment allocations to diversify the portfolio in effort to reduce risk or increase performance. Clarivor may recommend selling or unwinding positions for reasons that include, but are not limited to, harvesting capital gains or losses, business, sector, geographical or quantitative risk exposure to a specific security or class of

securities, overvaluation or overweighting of the position(s) in the portfolio, change in client’s objectives, or any risk deemed inconsistent with the client’s objectives. Portfolio Customization Software Clarivor provides proprietary web-based software that enables clients to view recommendations and screen investment strategies. Clients can also view the back-tested performance, performance statistics and risk scenario analysis for strategies. Additionally, the software allows clients to construct customized portfolios, allocate to such portfolios, and monitor information related to investment performance and risk management. Clarivor tailors its advisory services to a client’s individual needs based on information the client provides to Clarivor through its website. For example, a client may elect to allocate to strategies that only invest in a single security and related options. Alternatively, a client may allocate to a model portfolio designated for specified constraints, such as risk tolerance, and/or objectives such as yield, protection or risk adjusted returns. Clarivor may also tailor its advisory services based on existing client holdings, for example investments with significant capital gains. Given that Clarivor may use ETFs that track broad indices, clients may not be able to restrict Clarivor from indirectly investing in specific stocks, bonds, or industries. Clarivor does not provide portfolio management services to wrap fee programs. Clarivor Page 5 As of March 29, 2024 Clarivor had $7,689,100 in client assets under management, all discretionary.