NDVR provides personal financial advice, financial planning, portfolio design and management services that we describe collectively as our “Wealth Optimization Services,” or simply “Services.” We offer our Services in the U.S. to individuals, families, and their related entities, such as trusts, estates, and charitable organizations, that open an NDVR account (each, a “Client,” also referred to throughout as “you” or “your”) and enter an NDVR Client Account and Investment Advisory Agreement (“Client Agreement”). We built our Wealth Optimization Services with the goal of improving your financial outcomes. We design and manage intelligent portfolios that are personalized, adaptive, and optimized for the purposes of growing your wealth, protecting your planned cash flows, and efficiently transferring your estate to the next generation. Our approach is founded on rigorous and proprietary quantitative research and powered by advanced technology. Personalized Planning and Portfolio Design We provide our Services through proprietary digital tools with the support of NDVR personnel who are professional financial advisors (“NDVR Advisors”). The combination of advanced technology, quantitative investing techniques, and a dedicated team is designed to assist you in developing and pursue your unique wealth optimization plans. Please see Item 8 for more information on our methods of analysis, investment strategies, and risk of loss. NDVR Portal As a Client, you can work with an NDVR Advisor and use the NDVR Portfolio Lab™ and NDVR Optimization Engine™, which we describe below. These tools and all the features of your NDVR account are accessible through the “NDVR Portal,” which includes any website, mobile application or other means of electronic access or communication through which we provide Services. NDVR Portfolio Lab™ We use our proprietary digital tools to tailor our Services to each Client. Using the NDVR Portfolio Lab, you can create a plan for your portfolio that describes your: (i) initial investment, (ii) planned contributions and withdrawals over your intended time horizon, and (iii) current and future tax profile (together, your “Requirements”). You can also use the NDVR Portfolio Lab to set your priorities and investment preferences, including: (i) equity geographic diversification, (ii) socially responsible investing rules, (iii) restrictions, and (iv) investment factor overlays you would like to apply to your U.S. equity portfolio (together, your “Investment Instructions”). You will typically have Requirements and Investment Instructions for each unique portfolio that you engage us to manage (a “Portfolio”). As described below, we use the NDVR Optimization Engine™, which you access through the NDVR Portfolio Lab, to analyze potential portfolio configurations, or strategies, for you to consider and select. NDVR Optimization Engine™ The NDVR Optimization Engine is powered by proprietary algorithms that we use to analyze your Requirements and Investment Instructions, the investments you could hold in your Portfolio, and potential future market conditions. The NDVR Optimization Engine uses rigorously researched models that incorporate historical and current data of various financial assets, including U.S. equity securities, foreign equity securities, futures, options, and U.S. Treasury bills, notes and bonds, to generate realistic simulations of potential future market conditions. We model the performance of assets in different market and economic conditions by analyzing class returns, volatility, and correlation among the classes. Our algorithms evaluate the performance of possible portfolios under those simulated conditions to generate a range of potential portfolio strategies. You can use the NDVR Portfolio Lab to evaluate these strategies and instruct us to implement a portfolio strategy that we show you; or you can make changes to your Requirements or Investment Instructions and generate new portfolio strategies. When you select a portfolio strategy and fund it, we will use the NDVR Optimization Engine to build and manage it as a live Portfolio. Each live Portfolio is subject to actual market conditions and investment choices. Each live Portfolio is allocated and rebalanced by our proprietary algorithms, under the oversight of our Portfolio Management team. For additional information regarding our portfolio design and management processes, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. NDVR’s Investment Committee (the “Committee”) is responsible for approving material changes in our portfolio design and management processes as well as related matters such as the design

and operation of the NDVR Optimization Engine. The Committee can change these processes and related matters without prior notice to you, including, for example, by adjusting or overriding algorithms, by manually implementing recommendations they generate, and temporarily suspending trading if the Committee believes it is in the best interest of Clients to do so. The NDVR Optimization Engine may invest in a range of Assets to create your Portfolio. When applied to your Portfolio, the term “Assets” includes all cash, stocks, bonds, commodities, mutual funds, exchange traded funds (“ETFs”), exchange traded notes (“ETNs”), money market funds, investments in other collective investment vehicles, futures, options, swaps, and other financial instruments and related contracts, whether certificated or uncertificated and whether for present or future delivery, and all rights and entitlements thereto, including the securities and other property and the proceeds thereof currently or in the future held in a designated custody account with a qualified, third-party custodian (a “Linked Custody Account”). As provided in your Client Agreement, you grant us discretionary authority to manage your Assets held in a Linked Custody Account. For purposes of this brochure, an “Account” consists of all the Assets held in one or more associated Linked Custody Accounts. The NDVR Optimization Engine will manage your Portfolio and adjust the Assets that comprise it based on factors such as the passage of time, changing market conditions, tax efficiency, and unplanned contributions and withdrawals without any action required on your part and without notifying you prior to making such adjustments. We may, in our sole discretion, but subject to your Requirements, Investment Instructions, and selected strategy, invest and manage your Portfolio in a way that differs from your initial Portfolio allocation, including to a material extent. We will also adjust the Assets in your Portfolio based on new information that you provide us. Your Requirements, Investment Instructions, and corresponding Portfolios are unique and specifically designed for you based on the information you provide us. We encourage you to ensure your information is accurate and current. We do not provide accounting, legal or tax advice, although (through the NDVR Optimization Engine) we will provide investment advice that takes into account your stated tax status and on that basis aims to maximize your after-tax performance. Clients should not construe any recommendation made by NDVR or any information in the NDVR Portal as tax or legal advice. Cash Delivery We manage your Portfolio pursuant to your Requirements, Investment Instructions, and selected strategy, and to account for the withdrawals in your Requirements. You can link checking and other accounts to your Account and instruct us to deliver cash directly to them on a one-time or recurring basis. NDVR Advisors When you open an Account, we will assign one or more NDVR Advisors to help you use our Services. You will be able to schedule consultations with your NDVR Advisor, who is available to provide personalized financial planning and advice, including advice relating to your use of the NDVR Portal and our proprietary tools, such as the NDVR Portfolio Lab and NDVR Optimization Engine, to create your Requirements, Investment Instructions, and Portfolios. NDVR Advisors are available by appointment and during normal business hours. They can be reached via telephone, email, or video. Any information NDVR and NDVR Advisors provide is not a substitute for the advice of a qualified attorney or tax advisor. You should consult with your attorney or tax advisor to discuss any legal or tax-related concerns. Our advice is based on the information you provide us, including your Requirements and Investment Instructions associated with each Portfolio as well as personal attributes such as age, beneficiaries, employment status, estate planning objectives, and investment time horizon. We use our proprietary algorithms to monitor and manage your Portfolios. Your NDVR Advisor will contact you periodically to review your Requirements, Investment Instructions, and Portfolios. If you make material changes to your Requirements, Investment Instructions, or Account information, your NDVR Advisor might contact you to discuss them. Discussions with your NDVR Advisor are not a substitute for updating, as necessary, your Requirements, Investment Instructions and selected strategy. Our founder and CEO, Michael Simon, is the principal owner of NDVR. NDVR was incorporated in Delaware on January 23, 2019. As of January 31, 2024, NDVR managed $175,400,000 of Client Assets.