A. Description of the Firm VestWealth was incorporated in July of 2021 as a Delaware corporation. The Firm is 100% owned by Vest, Inc. (the “Parent”), a Cayman Islands corporation. The Parent is owned by Aaron Polhamus (36%). The remaining ownership of the Parent is split between numerous investors, none of which own 9% or more of the Parent. Except for Mountain Nazca Cross Border Fund IV, LP, who has representation on the Parent’s Board of Directors (“ Board ”), none of the entities have representation on the Board of the Parent or the Firm, or have any ability to control the business of the Parent or the Firm. Information about VestWealth’s organizational and ownership structure is provided on Part 1 of VestWealth’s Form ADV, which is available online at www.adviserinfo.sec.gov . VestWealth is a registered investment adviser (“ RIA ”) which offers non-discretionary online Advisory Services to its advisory Clients (each a “ Client ,” and collectively, “ Clients ”) through an online web-based and mobile platform (the “ Platform ”). Alvaro Pereyra will initially serve as the Firm’s Chief Executive Officer and Chief Compliance Officer. B. Services PORTFOLIO SERVICES. VestWealth provides non-discretionary investment management and portfolio services (“ Advisory Services ”) to retail Clients. Advisory Services are offered to Clients solely through the Firm’s online investment platform (the “Platform”). VestWealth does not provide comprehensive financial or tax planning or legal services. VestWealth does not provide Advisory Services in person or over the phone or in any manner other than through the Website and App. Additional information about VestWealth’s products and services is provided in VestWealth’s Form ADV Part 1 available at http://www.adviserinfo.sec.gov . VestWealth encourages visiting the Website or the App for additional information. When a Client opens an account (“ Investment Account ”) with VestWealth, they will be able to access the Investment Platform through either vest.investments (the “ Website ”) or the Vest mobile application (“ App ”). The Platform provides Clients with investment advice in the form of certain recommended portfolios (“ Investment Portfolios ”) specifically tailored and designed for each Client based on the Client’s Suitability Questionnaire, as defined below. VestWealth uses passive strategies and modern portfolio theory to determine each Investment Portfolio’s asset allocation. VestWealth has determined optimal asset classes and exchange-traded fund (“ ETF ”) strategies that most efficiently tracks those asset classes. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information on how VestWealth creates portfolios. VestWealth recommends one or more non-discretionary Investment Portfolios to each Client based primarily on the Suitability Questionnaire (“ Suitability Questionnaire ”) completed by such Client. Once a Client has provided information on their risk tendencies and investment goals through their Suitability Questionnaire, VestWealth will use the information provided by the Client, along with VestWealth’s investment strategies, in order to create tailored Investment Portfolios that Clients may select to invest their assets in. Clients have the sole discretion to accept or reject the Investment Portfolio or make other choices regarding the recommendation including adjusting the recommended total portfolio solution, the asset allocation percentages, or choosing a different portfolio solution with different risk/return characteristics. The Platform currently relies on questions relating to suitability (i.e., age, income and liquid net worth, investment objectives, investment time horizon, and risk tolerance) in recommending Investment Portfolios, and these

questions are not weighted equally. Clients should understand the recommendation of any Investment Portfolio relies upon the information provided by each such Client, and VestWealth does not capture any additional information not covered in the Suitability Questionnaire in providing portfolio recommendations. Clients are advised to promptly update their financial information on the Suitability Questionnaire if there are any changes to their financial situation or financial goals, as the Investment Portfolios recommended to each Client are reliant upon each Client’s Suitability Questionnaire. When a Client initially completes their Suitability Questionnaire, they will be presented with a recommended Investment Portfolio. The Investment Portfolios will be generated and presented to Clients upon the initial completion of the Suitability Questionnaire. Additional Investment Portfolios may be generated if a Client makes changes to their Suitability Questionnaire, including to their risk tolerance, investment goals or timeline. Clients have the sole discretion to accept our recommended Investment Portfolio, or to reject our recommendation and select a different portfolio. Once the Client accepts an Investment Portfolio, VestWealth will be provided limited discretionary management authority. This limited discretionary authority is solely confined to monitoring investment performance and quarterly rebalancing or adjusting the portfolios to capture original target allocations. The Platform uses a simple algorithm that rebalances accounts automatically on a quarterly basis back to asset allocation targets. Clients may impose reasonable investment restrictions on the management of their Investment Account such as opting out of the automatic quarterly rebalancing of their Investment Portfolio. Clients should be aware that using algorithms to recommend portfolios and to rebalance accounts has inherent limitations, including the possibility of human error in the design, data input, or implementation process. The risk of errors, malfunctions and anomalies is inherent in each component of the programming process, how those components function together, and how the program absorbs data points provided by the Client and by us. Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for a more detailed description of some of the risks inherent in using algorithms and other technologic measures to manage Investment Accounts. INVESTMENT PRODUCT TYPES. VestWealth will use any of the following securities or other investment products in order to create a particular Client’s recommended Investment Portfolios for investment: ▪ Exchange listed securities ▪ Securities traded over-the-counter ▪ Securities issued by foreign issuers, including foreign sovereign debt instruments ▪ Corporate debt securities, including commercial paper ▪ Certificates of deposit ▪ U.S. government securities ▪ Exchange-traded funds (ETFs) Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for a description of the risks associated with each of the preceding investment asset classes. The investments in each Client’s Investment Account are held in a separate account in the name of the Client at an independent custodian, and not with VestWealth. All Investment Accounts managed through the Platform are required to use the custodian selected by VestWealth, Apex Clearing Corporation (the “ Custodian ” or “ Apex ”), as the independent custodian. Each account agreement with the Custodian will grant VestWealth the authority to manage each Client’s Investment Account on a non-discretionary basis, seeking a Client’s authorization for each trade, provided that VestWealth be given the limited discretionary authority to automatically rebalance and adjust portfolios. C. Assets Under Management As of March 29th, 2023, we were managing less than $159,000 on a discretionary basis.