A. Description of the Advisory Firm Goal Based Investors, Inc. (the “Firm” or “GBI”) is a Delaware corporation formed in February 2019. As described in more detail below, GBI provides advice regarding potential investment plans to investors and other users (the “Investors”) through a portfolio allocation “Game.” GBI also generates proposed stock and bond allocations based on data inputted by Investors, and then provides the opportunity for Investors to receive customized “Proposals” for improved investment allocations, which are designed to enhance a particular Investor’s returns, by connecting with financial advisers that are registered with the U.S. Securities and Exchange Commission (the “SEC”) as investment advisers (the “Advisers”) and use GBI’s platform. The Advisers generate the Proposals using GBI’s proprietary analysis, as discussed below. B. Types of Advisory Services GBI sponsors two mobile applications: (1) the “GoalBased Investor” iPhone application (“Lasso”), which allows Investors to build and manage plans (“Plans”) to achieve their financial goals by playing the Game; and (2) the “GoalBased Advisor” iPad application (“Lasso Advisor Portal”), through which GBI provides Advisers data on potential custom strategies for an Investor to improve their investment allocations (“Passes”), based on the information collected through the Game, and provides access to proprietary tools through which Advisers use the Passes and Plans to generate specific recommendations as to how an Investor can optimize their investment allocations (the “Proposals”). Lasso’s Investment Portfolio Allocation Game. First, the app includes a “Game” based on GBI’s innovative proprietary algorithm. The Game generates customized, goal-based financial plans for Investors, with investment allocation recommendations for, among other things, investments in stocks and bonds (the “Plan”). The Plan is customized for the Investor based on an analysis of data inputted by the Investor, including (1) the amount of an Investor’s desired investment goal (e.g. annual retirement income); (2) the amount of capital currently available for this goal (e.g. $320,000); (3) the amount of time until the goal needs to be satisfied (e.g. 15 years); and (4) the amount of the Investor’s annual savings contributions for goal (e.g. 12,000 / year). GBI’s algorithm, which is based on its innovative analysis of historic pricing and risk data, takes these data points and calculates the potential investment returns of the Plan’s recommended “policy portfolio,” a proposed allocation to stocks, which are riskier and have higher potential returns, and bonds, which involve less risk but lower potential returns, based on the information provided by the Investor. Once the Game makes its initial portfolio recommendations, the program generates outputs in the form of “points” that an Investor can manipulate by changing various inputs. As clients change their portfolios, the app updates the “points at risk” (i.e. the points that could be lost in the event of a “normal” bad event). The goal is generally for an Investor to maximize the number of points they can generate, by doing things like increasing savings, adding new asset classes, etc. The Game is generally designed for Investors to gauge the potential risks and rewards of various allocation strategies and for GBI to collect data on Investor risk and reward preferences. The “policy portfolio” serves as a benchmark for the user, which an Adviser can help enhance as described below. It does not provide recommendations for specific stocks or bonds to purchase; those recommendations are provided through the apps, again using GBI’s proprietary technology and algorithms, when and if the Investor connects with an Adviser, as described below. Customized Investment Proposals. After the Game generates a Plan for an Investor, Lasso provides the opportunity for the Investor to receive customized investment “Proposals.” Proposals are generated for Investors based on GBI’s proprietary analysis of various mutual funds and exchange-traded funds (“ETFs”) managed by third-party registered investment advisers, broker-dealers, or investment banks (collectively, “Third-Party Content Providers”). The idea is that the Proposals translate the Plans into specific recommendations for the types of securities the Investor might purchase. To receive Proposals, Investors first browse listings of Advisers and choose to send their Plans to one or more Advisers. Investors can filter Advisers based on location, gender, age and experience and then choose an Adviser at their discretion. The selected Adviser then uses the Lasso Advisor Portal to access “Passes” curated by GBI, which contain data and analysis of the investment funds described above in response to the Investor’s investment preferences

and information collected through the Game. The Passes encompass data about specific allocations among specific securities designed to meet different types of investment goals. GBI is responsible for calculating the Investor’s potential investment returns and capital market forecasts for the Passes. GBI starts with a user’s original stock-bond portfolio (as provided through the Game) as a benchmark and uses its proprietary optimization software to produce a set of portfolios for the Investor that, relative to the original portfolio, it believes will maximize expected returns for a given level of expected risk. Advisers then choose from among the Passes to apply GBI’s proprietary algorithms to the Plan and the Pass and generate one or more Proposals outlining the types of investments Investors can make to optimize their investing. Advisers choose a subset of Passes to generate Proposals and their potential returns, again based on GBI’s proprietary software. Advisers share a summary of the recommendations in the Proposal and why it will enhance the Investor’s current portfolio. If an Investor selects a Proposal, they has the option to contact the Adviser to receive the specifics of how to implement the Proposal. Investors have full discretion to choose a Proposal and an Adviser to use for their Plan. Because GBI provides investment advice solely through its apps, it is registering as an adviser with the SEC under Rule 203A-2 under the Investment Advisers Act of 1940, which allows such registration to advisers that (among other things) provide investment advice to their clients exclusively through an interactive website. GBI is treating the app is a form of website for these purposes. GBI will not interact with Investors in any other way. Advisers may from time to time communicate with Investors outside the app and are solely responsible for determining their registration status. The Plan and any Proposals an Investor receives rely on the information the Investor provides to GBI via Lasso. To the extent any of that information is incorrect, it could negatively affect the quality of an Investor’s Plan and any Proposal they receive. GBI has no responsibility for any incorrect, false, or misleading information provided by an Investor or any Adviser or for any investment or financial decision an Investor makes based on that information. GBI does not make recommendations or provide advice regarding the Advisers to whom an Investor chooses to send Plans. GBI has not performed any diligence on any Adviser and neither guarantees nor takes any responsibility for the performance of any Adviser. Investors are solely responsible for selecting Advisers through Lasso and for reading and understanding the information contained in any Adviser’s Form ADV. An Investor may choose to enter into an advisory agreement (each, an “Adviser Agreement”) with one or more Advisers that an Investor has connected with through Lasso. Any investment advice given to an Investor by an Adviser after an Investor chooses to engage an Adviser will be provided to an Investor under the terms and conditions of the Adviser Agreement with that Adviser and not through Lasso or by GBI. Investors are solely responsible for determining whether to enter into an Adviser Agreement with any Adviser that an Investor has connected with through Lasso and for reviewing and understanding the terms and conditions in any Adviser Agreement, and the Investor acknowledges and agrees that GBI will have no involvement in or responsibility for any services provided by any Adviser under any Adviser Agreement. C. Client Tailored Services and Client Imposed Restrictions GBI provides tailored advisory services in two of the ways described above: (1) by using its algorithm to help Investors develop and enhance their Plans, based on information provided by the Investor; and (2) by developing Proposals based on Investor’s Plans, which are designed to help Investors, working with Advisers, achieve their investment goals. (GBI does not recommend particular Advisers through the app, but it does introduce Advisers and helps them provide advice to Investors by means of the Passes.) GBI does not execute any trades or make any financial or investment decisions on the Investors’ behalf. GBI is not a party to the Adviser Agreement between the Investor and the Adviser. To the extent an Investor seeks to impose any investment restrictions (other than through the parameters of the app), these will be negotiated between the Investor and the Adviser. D. Wrap Fee Program GBI does not participate in wrap fee programs. E. Amounts Under Management GBI does not currently have any assets under management.