Firm Description Thrive Capital Management, LLC, (“Thrive”) is a fee-based investment management and financial planning firm founded in 2015. Thrive is wholly owned by Thrive Holdings, LLC, which represents the interests of the firm’s managing partners Bret Elam, David Bezar and Karen Bezar. Investment Advisor Representatives (“IARs”) of the firm may be dual employees of Thrive and its affiliated entity that sells insurance products. Thrive advises its clients regarding cash flow, retirement planning, tax planning and estate planning. An evaluation of each client's initial financial situation is conducted by Thrive. Thrive monitors clients’ accounts on an ongoing basis and conducts periodic reviews as part of their investment management and financial planning process. Communication is provided to the client regarding the specific courses of action that Thrive recommends. If applicable, other professionals (e.g., lawyers or accountants) are engaged directly by the client. Any conflict of interest will be disclosed to the client in the event it should occur. Types of Advisory Services Thrive provides investment management services and furnishes financial planning and investment advice to its clients. Asset Management Thrive offers discretionary asset management services to advisory clients. Discretionary authority means Thrive will determine the specific securities, and the amount of securities, to be purchased or sold for your account without prior approval for each transaction. All discretionary trades made by Thrive will be in accordance with each client's investment objectives and goals. Thrive will offer clients ongoing portfolio management services by determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocations, portfolio monitoring, and the overall investment program will be based on the above factors. After conducting our initial review, Thrive will determine an asset allocation strategy customized to your specific goals, investment objectives and risk tolerance. The portfolio recommendations may involve the sale of positions currently held by you. Thrive generally utilizes exchange traded funds; stocks; bonds; mutual funds, money market funds; and third-party money managers. In performing its asset management services for each client, Thrive will utilize a third-party platform operated by an unaffiliated investment advisor, AE Wealth Management (“Sub-Advisor”). The Sub- Advisor provides Thrive with certain sub-advisory administrative, technical and support services. Thrive will provide you with the Sub-Advisor’s disclosure documents, including Form ADV 2A. Please refer to these disclosure documents for additional details regarding the Sub-Advisor. Use of Model Portfolios Thrive has constructed a number of diversified model portfolios that vary in characteristics including but not limited to risk profile, asset allocation, and investment objectives. The portfolios primarily consist of exchange traded funds and are monitored by Thrive’s Investment Committee. Model Portfolios are intended to provide a diversified investment approach to target a particular balance of return and risk or portfolio objective. Use of Other Investment Managers Thrive may use the services of other unaffiliated third-party money managers when selecting investment strategies for clients. Such services may involve active or passive asset management using a customized or a model portfolio approach. In all cases, Thrive will monitor the third-party money managers and possess the

discretionary authority to hire and fire any such outside manager. Additional fees may apply when utilizing a third-party money manager. Please see Item 5 for additional details. Financial Planning and Consulting Thrive provides financial planning services on a one-time basis. These fees are detailed in the “Fees and Compensation” section of this brochure. Services include, but are not limited to, a thorough review of all applicable topics including Retirement Analysis, College and Major Goal Funding, Estate Plan/Trusts Review, Investment Related Tax Planning, and Insurance Needs Analysis. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You are under no obligation to act upon the financial planning recommendations. Should you choose to act on any of the recommendations, you are under no obligation to affect the transaction through Thrive. Thrive is not authorized or qualified to give legal advice, prepare legal documents, or to act as a trustee. You should consult your attorney, accountant, and other personal advisers for these services. Seminars and Workshops Thrive holds seminars and workshops to educate the public on different types of investments and the different services it offers. The seminars are educational in nature and no specific investment or individual tax advice is given. Thrive does not charge a fee for attendance for these seminars. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect client stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Wrap Fee Programs Thrive does not sponsor any wrap fee programs. IRA Rollover Recommendations For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Client Assets under Management As of December 31, 2023, Thrive has approximately $392,766,587 in client assets under management on a discretionary basis.