A. FIRM DESCRIPTION Beagle Invest, LLC (“Beagle Invest” or the “Firm”) is a SEC-registered automated investment advisor. Beagle Invest was founded in June 2021 with its principal office at 1049 El Monte Avenue, Ste C #588, Mountain View, CA 94040. The Firm is owned by Beagle Financial Services, Inc. If you have any questions about the contents of this Brochure, please email us at [email protected]. B. TYPES OF ADVISORY SERVICES The primary focus of Beagle Invest is to provide investment advisory services to Beagle Invest’s clients (“Client” or “Clients”) as well as to prospective clients via a web-based and mobile-compatible solution. Beagle Invest helps and encourages its Clients to contribute to and grow their retirement savings by offering low-cost, well-diversified portfolios through multiple types of retirement accounts. However, Beagle Invest does not offer tax or financial planning advice. INVESTMENT ADVISORY SERVICES Beagle Invest specializes in quantitative and fundamental analysis to determine what investments are in favor of Beagle Invest’s investment models. Investment opportunities are designed for Clients to make long-term investments in diversified portfolios. Beagle Invest assesses Clients’ holdings and ensures alignment with both short- and long-term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure to align with Clients’ profiles and takes into consideration market conditions. Accordingly, the Firm is authorized to perform various functions without further approval from the Clients, such as the determination of securities to be purchased or sold without prior permission from the Clients for each transaction. Any and all trades are made in the best interest of the Clients as part of Beagle Invest’s fiduciary duty. However, risk is inherent to any investing strategy and model. Therefore, Beagle Invest does not guarantee any results or future returns. Beagle Invest interacts with Clients primarily through a technology platform developed and maintained by Beagle Invest’s parent company, Beagle Financial, Inc. (doing business as “Beagle”), that is available through Beagle’s website and mobile application. Clients of Beagle Invest also use Beagle’s website to access account details including account balances, portfolio holdings, transaction history and account documents. Beagle Invest does not generally provide investment advice in person, over the phone, live chat, or in any other manner other than through the advisory services available on Beagle or through automated email communications. Beagle provides technology and back-office support for Beagle Invest. Beagle Invest is a subscription-based fee investment management firm. The firm does not receive fees based on assets or commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned products for clients. Prior to engaging Beagle Invest to provide any investment advisory services, Beagle Invest requires Clients to enter into Customer Agreements with Beagle Invest. The Customer Agreements will outline services to which the client is entitled and fees the Clients will incur. Beagle Invest does not act as a custodian of Clients’ assets. The Clients always maintain asset control of their own Beagle Invest account (“Account” or “Accounts”). Beagle Invest places trades for Clients under a limited power of attorney through a qualified custodian and clearing broker. Under the terms of the Customer Agreements, the Clients authorize Beagle Invest to conduct all trades and transactions from Beagle Invest to the qualified custodian and clearing broker and carry the Clients’ accounts that holds the Clients’ securities and cash as well as to record the Clients’ transactions under Beagle Invest’s direction. Orders for purchases or sales for multiple advisory accounts may be combined by Beagle Invest and the qualified custodian and clearing broker to reduce any trading and transaction costs that Beagle Invest may have to incur. Clients are not charged any trading or transaction fees for the purchase and sales of securities in their Accounts. Beagle Invest offers multiple types of retirement investing account types: (1) Individual Retirement Accounts sometimes referred to as “Beagle IRAs,” and (2) Individual 401(k) Accounts sometimes referred to as a “Beagle Individual 401(k)s” or “Beagle Solo 401(k)s”. Beagle Invest provides investment advice to each of the Accounts through model portfolios, each consisting of a mix of individual ETFs that are

managed by third-party investment adviser(s) and that reflect target asset allocations across various chosen asset classes, including domestic and international stocks (equities), short and long-term bonds and treasury securities (fixed income) and real estate. Beagle offers six (6) diversified model portfolios to match Clients’ investment time horizons and risk tolerances, with model portfolios ranging from ‘max growth’, ‘growth’, ‘growth income’, ‘balanced’, ‘income’ to ‘capital preservation’. Based on the information that each of the Clients enters on Beagle’s mobile or web-based application (www.meetbeagle.com) during the account opening process, Beagle Invest will utilize its proprietary software algorithm to match each Client with the initial portfolio best suited to meet the individual Client’s investment goals. Each Client, upon being onboarded into Beagle, is asked a set of questions. These questions may include behavioral questions such as how a Client views risk to assess their tolerance for risk. The algorithm then balances that analysis with the Client’s expectations for portfolio growth. Combined with additional Client feedback on when the Client expects to reach retirement age, Beagle’s algorithm then categorizes the Client into an initial portfolio that is suitable for their individual investment time frame. Beagle Invest’s algorithm will rebalance an Account’s holdings, no less frequently than quarterly, if it finds that the holdings deviate by 5% or more from the target portfolio allocation prescribed for the Client. Depending on market fluctuations and volatility level, as well as deposits and withdrawals of funds into and out of the account, this may result in multiple rebalancing transactions throughout the year for an Account. All rebalancing transactions are made automatically without the Client’s input. Also, dividend payments produced from any ETFs in each portfolio are reinvested automatically to fit the appropriate asset allocation mix. As part of the investment process to get each Account to its matched targeted portfolio, Beagle purchases ETFs through a qualified custodian and clearing broker. As Clients make further deposits into or withdrawals from their Accounts, the corresponding transactions made by Beagle are designed to maintain each Account’s target allocation. Upon a Client’s request to contribute or withdraw assets from its Accounts, purchases or sales of the ETFs underlying a Client’s portfolio are executed in a manner designed to maintain the target allocation of the specific portfolio. The set of ETFs selected include investment fees charged by their third-party investment managers and are incremental to Beagle Invest’s fee. Usually, these investment fees are priced into each of the ETFs. Beagle Invest does not receive any fee from these investment fees charged by ETF investment managers. The qualified custodian and clearing broker may charge ancillary fees for ACH withdrawals, wire transfers, checks, paper documents, or Account closing fees. These fees are disclosed in the Customer Agreements with each Client and are passed on to the client by Beagle Invest.
Beagle will review a Client’s portfolio allocation whenever any material changes are made to that Client’s investment profile. Beagle periodically sends requests, at least annually, to Clients to make any necessary updates to their Client profiles so that their risk profiles are kept up to date. C. SERVICES TAILORED TO CLIENTS’ NEEDS Services are provided based on a Client’s specific needs within the scope of the services provided as discussed above. Beagle Invest’s algorithm utilizes the information provided by each Client regarding the Client’s current financial situation, goals, and risk tolerances and then allocates their assets into one of six (6) customized portfolios consisting of different asset mixes. Each portfolio is comprised of multiple ETFs to provide for proper diversification of assets and to reduce any risks associated with investing in individual stocks, bonds or real estate assets. D. WRAP FEE PROGRAM VERSUS PORTFOLIO MANAGEMENT PROGRAM Beagle Invest does not offer a Wrap Fee Program. E. ASSETS UNDER MANAGEMENT As of February 28, 2023, the Firm has the following assets under management: Discretionary assets: $7,987,598 Non-discretionary assets: $0