Invstr is a digital only investment advisory firm providing non-discretionary investment advisory and investor education services to individual retail clients, depending on the services selected. Founded in 2019, Invstr Financial is a US tax registered company with its registered office at 8 The Green, Suite A, Dover, Delaware 19901, and its main office at 3201 Cherry Ridge Road, Suite 213B, San Antonio, TX 78230. Invstr Financial is wholly owned by Marketspringpad Holdings Limited, a Jersey based financial technology company, which is majority owned by Kerim Derhalli. All of our clients receive services over the internet through the Invstr smartphone/tablet app, which is available for iOS and Android, or desktop. Invstr also has an online community on its app where our clients can learn from each other through a social feed and messaging. We also offer electronic feedback and analytical tools to help our clients understand the investment process and to assist in the evaluation of potential investments. ● Invstr “Stats” is a tool that endeavours to assist our clients to better understand their investment performance, the risk profile of their portfolio, their behaviour as investors and the efficiency of their purchase and sale transactions. ● “Portfolio Builder” is a tool that uses factor based analysis of US listed securities combined with customer preferences to calculate and back test suggested portfolios. ● “Portfolio Optimizer” is designed to help clients enhance the expected risk-adjusted returns of their holdings. By looking at their current portfolio and comparing each position to similar instruments with a higher ranking according to the Invstr instrument score, it suggests upgrades to their holdings without changing the fundamental nature of the risks already defined by the client. It is important to note that any Generated Account Information provided by Invstr’s proprietary system is non-discretionary

in nature, meaning that it is up to the individual client to not only evaluate and review such information but also whether to ultimately implement, on his/her own, any subsequent investment transaction(s) based on such information. Invstr does not make individual representatives available to discuss client servicing matters or the Generated Account Information provided by the system with clients. As such, each participating client should understand that he/she alone is solely responsible for making any and all investment decisions related to the Invstr account (whether based on the Generated Account Information or otherwise). In addition, participating Invstr clients should understand that output from any Generated Account Information is solely dependent on the participating client’s active and consistent use of the Invstr app. A participating client acknowledges and understands that the Generated Account Information provided by Invstr’s proprietary system is based SOLELY on such client’s interactions and information provided within the Invstr app and neither Invstr nor its proprietary system will consider any data or information (including any other securities, investments, cash or assets owned by the client) that are outside the Invstr app or not provided by the client via the Invstr app. As such, participating clients understand and acknowledge that the Generated Account Information provided by Invstr’s proprietary system as described above is limited in nature and not meant to be, nor should be understood to be, based on a comprehensive or complete review of the client’s financial situation, personal circumstances, investment goals or objectives, or risk tolerance. Please also see Item 7 below for important additional information regarding Invstr’s account offerings and services. Assets under Management As of the date of this Brochure, Invstr manages approximately $1118922 in assets under management on a non-discretionary basis.