Firm Description Incorporated in November 2006, Accelar, Inc. is a registered investment advisor, doing business as XoomFi Advisors (“XoomFi” or the “Firm”), offering investment advisor services, as further described below, through the internet since June 2021. Principal Owners Kumar Shah is the principal owner of XoomFi. Types of Advisory Services XoomFi is an internet-based advisor which uses an algorithm created to manage client accounts based on their individual financial situation and goals. Clients provide information about themselves and their investment objectives exclusively through XoomFi’s interactive website. We rely on integrated, cloud-based portal for the account opening process. Through the interactive website, each client completes a client profile and answers a risk tolerance questionnaire. Based on the information provided in the risk tolerance questionnaire, the algorithm generates an allocation of the client’s funds in one or more of the XoomFi investment models. Our algorithm creates an investment profile for each client based on a variety of factors - capital investment amount, stocks and options investment experience, expectation of return on their investment, risk / reward profile, among others. This profile is based on the questionnaire each client fills out online. Investment allocation to one or more than 1 investment model is typically determined by the amount you invest:  $5,000 to $24,999: 1 portfolio  $25,000 to $49,999: 2 portfolios  $50,000+: 3 portfolios Our algorithm will select one or more of the following investment models – Balanced Income & Growth, Turbo Income &Growth and / or Ultra Income & Growth - based on your investment profile and invested amount. While there is no direct, set, or permanent correlation between the market cap of the equities in your account and other selection criteria and associated risks and rewards, in our assessment, risks and rewards will tend to be lower for the Balanced Income & Growth portfolio compared to Turbo XoomFi Advisors, 111 N Market St, Suite 300, San Jose, CA 95113 Page 4 of 13 Income & Growth, which, in turn, will be lower than the risks and rewards associated with the Ultra Income

& Growth portfolio. Clients will electronically enter into an advisory agreement with XoomFi and open a brokerage account with Interactive Brokers, an independently registered broker dealer acting as the custodian of client accounts. XoomFi will maintain discretion over client accounts. Each client account is managed as a Separately Managed Account (SMA) by XoomFi with no co-mingling of funds between the SMA’s. The algorithm uses the following assumptions in recommending investment models:  A lower risk level is preferred over a higher risk level for the same level of return  An individual security impacts the risk and return profile of an entire portfolio, therefore diversified portfolios can outperform while reducing risk and volatility  Assets in a portfolio that have a negative correlation, could realize stronger returns rather than exclusively holding one type of asset within a portfolio The algorithm may also have limitations that include:  Minimalizing risk may limit returns  Purchase of underperforming equities and sale of better performing equities to achieve targets which can create capital gain tax liabilities  The lack of updated information on a timely basis by a client Risks inherent in the use of an algorithm may include:  The inability to react to significant events on an intraday basis  The inability to recognize prolonged changes in market conditions  Technology failures  Systemic risk may be amplified Conditions that might cause XoomFi to override the algorithm include:  Significant events that move the market or an individual asset on an intraday basis  Prolonged changes in market conditions  Technology failures Clients should review and update their personal information at least yearly and whenever a significant life event occurs that changes one or more of the original inputs. Limited Types of Investments Our investment models only invest in stocks and options. XoomFi Advisors, 111 N Market St, Suite 300, San Jose, CA 95113 Page 5 of 13 Tailored Relationships Clients will not be allowed to place restrictions on their accounts. Client Assets As of December 31, 2022, XoomFi had approximately $27 thousand in discretionary assets under management.