A. Description of the Advisory Firm Elphinstone, Inc. (“Elphinstone”) provides portfolio management to clients under this wrap fee program as sponsor and portfolio manager. Elphinstone is an automated software platform accessible via the Android and IOS App Stores – Elphinstone is what is known as a “robo-advisor.” All investment advice is provided pursuant to the information provided by the client in the onboarding process. Elphinstone strives to provide what it considers the appropriate investment advice based on client responses (thus a client is responsible for providing accurate information). However, a client may choose a different investment strategy and Elphinstone will work with broker partners (see section 4.E below) to execute. No personalized investment advice beyond the automated software response is provided. Total Assets Under Management Annual Fee All Assets 1.00% Fees will be invoiced and billed directly to the client, payable by bank transfer, on a monthly basis. Fees are paid in arrears. Elphinstone uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Clients may terminate the agreement without penalty, for full refund of Elphinstone’s fees, within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Elphinstone also has a related business in Pakistan operating as Elphinstone Pakistan, Ltd. (“Elphinstone Pakistan”). Elphinstone Pakistan is registered with the Pakistan Securities and Exchange Commission and provides automated investment advising to Pakistani individuals and to corporate customers providing accounts to their employees through Elphinstone Pakistan. This investment advice is distinct from the automated advisory service provided by Elphinstone, Inc. Clients should verify that they are using the correct Elphinstone software application to access Elphinstone’s advisory software. Employees of Elphinstone Pakistan also provide software and technical support to Elphinstone. This brochure and related filings are for Elphinstone for Elphinstone’s US products. B. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). C. Additional Fees Elphinstone will wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.) for wrap fee portfolio management accounts. Elphinstone will charge clients one fee, and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that Elphinstone has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts

and securities transactions. D. Compensation of Client Participation Neither Elphinstone, nor any representatives of Elphinstone receive any additional compensation beyond advisory fees for the participation of client’s in the wrap fee program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, Elphinstone may have a financial incentive to recommend the wrap fee program to clients. E. Broker Relationships Elphinstone does not operate its own broker-dealer, but instead partners with Alpaca Securities and Interactive Brokers to offer brokerage services and accounts to its clients. Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or a bank. The Firm makes custodial recommendations that are based on our perception of the breadth of services offered and quality of execution. We seek to recommend custodians that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including but not limited to the quality of transaction execution services, the quality of asset custody services, the capability to execute and settle trades, the capability to facilitate transfers and payments to and from client accounts, the breadth and choice of no-load and load-waived mutual funds and the availability of, the lowest cost (class) shares within a particular mutual fund family, the availability of investment research and tools that assist our firm in making investment decisions and which therefore benefit the end client, the overall quality of service and communication, the pricing competitiveness in providing services, including trading costs, the willingness to negotiate prices for services, prior service to us and to our clients, the availability of free (no transaction fee) exchange-traded funds, and the availability of other services and investment products that benefit us and our clients. Alpaca Securities does not charge brokerage fees to our clients – or to us – but instead earns its revenue via payment for order flow from market makers in order to offer trade execution services to its clients. Interactive Brokers does charge a brokerage fee to its clients, but those fees are covered under Elphinstone’s wrap fee. F. Custody Custody of client assets invested in US-listed securities is maintained by Alpaca Securities, LLC or with Interactive Brokers. Alpaca Securities’ head office is located at 20 N San Mateo Drive, Suite 10, San Mateo, CA 94401. Interactive Brokers’ headquarters is at One Pickwick Plaza, Greenwich, CT 06830. Elphinstone takes custody of client funds solely for the purpose of facilitating deposit and withdrawal transactions for our clients between their personal bank accounts and their brokerage accounts at the brokerage firms at which they have accounts. Those funds are maintained at JPMorgan Chase Bank, N.A. Generally these funds are passed through within one business day to an Alpaca Securities or Interactive Brokers custodial account, unless there is an unforeseen error or delay technical error. If there is a significant delay, or for some reason the transfer between Elphinstone’s custody account and Alpaca Securities or Interactive Brokers cannot be completed, Elphinstone shall notify the client promptly. For securities in Pakistan through Elphinstone Pakistan, the Central Depository Company of Pakistan physically holds a client’s investments. The CDC Head Office is located at CDC House, 99-B, Block B, S.M.C.H.S. Main Shahra-e-Faisal, Karachi – 74400.