Introduction Stackwell Capital Advisers, LLC, doing business as Stackwell, (“Stackwell” or “Firm”) provides automated discretionary investment advisory services to Clients via the Stackwell investment program (the “Program”). The Firm also provides impersonal Financial Counseling Services. Stackwell helps Clients build smart financial habits and manage wealth by providing financial education, tools, and guidance, and simplifying the way Clients save and invest. Stackwell is registered with the United States Securities and Exchange Commission (“SEC”) and provides all investment advisory services exclusively through virtual interaction conducted over the Internet. Stackwell does not offer tax, accounting, or legal advice. Client Contact Clients may contact Stackwell’s customer support team via email at [email protected] with respect to technical questions and service issues regarding the Platform (as defined below). However, Stackwell does not provide investment advice in person, over the phone, live chat, or in any other manner other than through the advisory services available on the Platform. Discretionary Investment Program Stackwell interacts with Clients primarily through a technology platform developed and maintained by Stackwell’s parent company, Stackwell Capital (as defined below), that is available through Stackwell Capital’s mobile application (“Platform”). The Firm provides automated discretionary investment advice (both personal and impersonal) and delivers advisory services to Clients through the Platform. Stackwell does not provide investment advice in person, over the phone, live chat, or in any other manner other than through the Platform. The Program is an automated, web-based algorithmic system designed to help Clients invest regularly, diversify, and think long-term about their financial futures. Clients are required to input personal information via the Client registration process (“Suitability Questionnaire”), which may include, but is not limited to, information about a Client’s identity, liquidity needs, age, e-mail address, physical address, location, citizenship, financial situation, or other information as requested on the Platform (“Client Information”). Stackwell provides investment advice and recommendations based solely on Client responses to the Suitability Questionnaire. Stackwell will periodically remind you to review and update your Suitability Questionnaire. Clients agree to promptly update any Client Information provided to Stackwell that is no longer accurate using the Platform. Based on the information the Client provides on the Platform, Stackwell uses the Platform to provide the Client with automated investment advice in the form of (i) discretionary managed accounts utilizing one of the Firm’s three model portfolios, and (ii) Financial Counseling Service. Each of the discretionary managed models consists of publicly traded exchange traded funds (“ETFs”). The three models are designed to represent an Aggressive, Moderate and Balanced investing approach. The model recommendation is based solely on Client provided responses to the Suitability Questionnaire. Although the Platform recommends the model portfolio the algorithm believes is best suited for the Client based on Suitability Questionnaire responses, Clients may opt to invest in a more conservative model than recommended if they choose to do so. Clients may not opt to invest in a more aggressive model. Clients may impose reasonable investment restrictions on the management of the Client’s Stackwell Account. Such restrictions may result in a Client’s Stackwell Account being concentrated in one or a few sectors, industries, or securities. Concentrated positions typically increase the risk and volatility of the Stackwell Account and may result in a decrease in diversification. Clients who implement an investment decision that is outside the scope of the recommendations should understand that such a decision may not be appropriate based on the Client’s risk profile and that the Client’s portfolio may perform worse over any time horizon than a portfolio designed according to recommendations or any other investment strategy. Clients who want to implement the Program’s recommendation and invest utilizing one of the Firm’s three model portfolios are required to enter into an investment advisory agreement (“Advisory Agreement”) with Stackwell and a brokerage agreement (“Brokerage Agreement”) with Apex Clearing Corporation, a New York corporation and registered broker-dealer unaffiliated with Stackwell (“Apex”). The Advisory Agreement discusses the advisory services the Client will receive, the fees charged to the Client, and the conditions of the Client’s discretionary relationship with Stackwell. Our advisory relationship begins upon the Firm’s acceptance of the Advisory Agreement. Any preliminary information provided to the Client before the Firm accepts the Advisory Agreement does not constitute investment advice under the Investment Advisers Act of 1940, as amended (“Advisers Act”), and should not be relied on as such. The Brokerage Agreement describes how Apex, will act as the clearing broker and qualified custodian for the Client’s Account. Under the terms of the Brokerage Agreement, the Client authorizes Apex to establish and carry the Client’s Account that holds the Client’s securities and cash and records the Client’s transactions in the Program. Assets Under Management As of March 28, 2024, Stackwell has $1,495,172 in discretionary assets under management. Impersonal Financial Counseling Service Stackwell also provides certain educational tools to Clients (“Financial Counseling Service”). The Financial Counseling Service includes a range of financial information, education and analysis offered on a limited scope basis. The Financial Counseling Service is impersonal in nature, which means that the advice is not tailored to a Client’s, or group of Clients, individual needs and does not purport to meet the objectives or needs of specific Clients or accounts. Consequently, Stackwell does not rely on Suitability Questionnaire information that the Client inputs into the Platform

to provide the Financial Counseling Service. The Financial Counseling Service is available to all Stackwell Clients. The Financial Counseling Service will either supplement other investment advisory services made available to Clients or will be offered separately from the investment advisory services made available through the Platform. The Financial Counseling Service constitutes impersonal investment advice and does not require the establishment of a Stackwell Account. Cash Sweep Program Free credit balances, including any cash balances and funds pending for investment, in a Client Brokerage Account are automatically invested or “swept” daily, or at such other interval as determined by Apex, into one or more bank deposit accounts in accordance with the Sweep Program described in Apex’s Sweep Program Terms and Conditions Pursuant to the Brokerage Agreement with Apex, Client cash would be held in an FDIC-insured interest-bearing bank account at one or more banks participating in the Sweep Program. As described in the Advisory and Brokerage Agreements, Clients are automatically enrolled in the Sweep Program. This creates a conflict of interest. Stackwell may receive a portion of interest revenue earned in the Cash Sweep Program under its clearing agreement with Apex. This additional economic benefit gives Stackwell a financial incentive to have clients participate in the Cash Sweep Program and to maintain cash balances in the Cash Sweep Program. In order to avoid this potential conflict of interest, any funds that Apex sends us for Cash Sweeps will automatically be rebated back to you, and Stackwell would not receive any economic benefit from the Cash Sweep Program. If the Client has questions relating to the Sweep Program, please email us at [email protected]. Dividend Reinvestment The Program automatically reinvests dividends paid by the ETFs in the model portfolios back into the Client account. This reinvestment will trigger tax liability for Clients without any corresponding payment to offset such tax liability. Clients will either have to pay their tax liability for the dividend reinvestments with separate money or withdraw money from their account to satisfy any applicable tax liability. There exists no opt-out for such reinvestment. Model Portfolios Stackwell currently offers three models designed to represent an Aggressive, Moderate and Balanced investing approach. The Stackwell Aggressive Portfolio is designed to seek total return through exposure to a diversified portfolio of primarily equity ETFs, and to a lesser extent fixed income ETFs with a target asset class allocation of 90% equities and 10% fixed income. The Stackwell Moderate Portfolio is designed to seek total return through exposure to a diversified portfolio of primarily equity ETFs, and to a lesser extent fixed income ETFs with a target asset class allocation of 70% equities and 30% fixed income. The Stackwell Balanced Portfolio is designed to seek total return through exposure to a diversified portfolio of equity and fixed income ETFs with a target asset class allocation of 50% equities and 50% fixed income. Stackwell’s ETF selection process is more fully described in Item 8 Methods of Analysis, Investment Strategies and Risk of Loss – Investment Philosophy below. As part of the portfolio analysis and review process, Stackwell may add, remove, re-categorize or replace Investments available under the Program. In the event an Investment is removed, it will no longer be available for additional investing. In the event an Investment is removed and replaced with another substantially similar Investment, Stackwell may liquidate Client positions to cash and reinvest in the replacement Investment. Stackwell’s Recommendations are designed to help promote diversification and long-term growth as appropriate within the context of Client-specific age, risk tolerance and investment time horizon. Rebalancing of Model Portfolios Stackwell manages Client Accounts on a discretionary basis. This means that Stackwell is authorized to trade on the Client’s behalf to maintain the target investment allocation within each model portfolio. The Program utilizes software to conduct this trading to invest Client deposits, fund Client withdrawals and perform rebalancing to maintain the target portfolio allocation in each model portfolio. An account will be automatically rebalanced by Apex when withdrawals or deposits are made into the account. Apex will also provide a daily rebalancing recommendation to Stackwell if the holdings deviate from the model’s target asset allocation. Stackwell rebalances with each trade in Client Accounts. In this way, Stackwell seeks to maintain the client’s target asset allocation through market fluctuation, withdrawals, deposits, and other events that may cause deviations while seeking to minimize the transaction costs of frequent portfolio rebalancing. Rebalancing transactions are automatic, as are dividend reinvestments. The rebalancing and reinvestment processes are automated and not limited in terms of frequency. As a result, Stackwell will sell over-concentrated ETFs and use the proceeds to buy under- concentrated ETFs to bring Portfolios in line with their target allocations regardless of market or other dynamics. The risks and limitations of the automated process could result in the continued purchase of underperforming ETFs and the sale of better performing ETFs to achieve the targeted allocation. Stackwell does so on a best-efforts basis and does not take into account individual tax, market, or legal circumstances. In some market conditions, this may create capital gains and potentially other tax liabilities. All transaction costs are rolled into the Stackwell Fee paid by the customer. Any costs imposed by the manager of the ETF would be expressed through the pricing of the ETF. Clients are responsible for logging in to their Account(s) regularly to review performance and access trade confirmations, periodic account statements, and other information available to Clients. If the Client identifies any discrepancies, the Client should promptly report them to Stackwell by emailing Stackwell at [email protected].