DESCRIPTION OF THE ADVISORY FIRM Portfolio Design Labs, LLC (hereinafter, with its subsidiaries, “Portfolio Labs”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in November 2021 and the principal owner is Jason Thomas. PORTFOLIO MANAGEMENT SERVICES – PARTNER ADVISORY FIRM CLIENTS Portfolio Labs offers investment advisory services, primarily to individuals through third-party investment adviser firms (referred to in this brochure as “Third Party Advisory Firms” or “TPAFs” and their client advisor representatives are referred to as “Third Party Financial Advisors” or “TPFAs”). The Fee schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimum schedule located at the end of this Brochure. TPFAs consult with their clients (“TP Clients”) to assess the TP Clients’ financial situation and identify investment objectives in order to identify investment solutions (“Solutions”) designed to meet the TP Client’s financial needs. In order to engage Portfolio Labs, the TP Client will enter into an Investment Management Contract (“IMC”) that outlines the services to be performed by Portfolio Labs. Portfolio Labs requires discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. The TPFA is responsible for determining the suitability of various investment solutions (“Solutions”) for the TP Client’s investment objectives and financial condition. Through its TPFA, the TPAF, not Portfolio Labs, recommends the Solution to the TP Client and monitors whether to recommend that the TP Client remain in the selected Solution. As described below, each of the Solutions uses one or more Investment Approaches (the “Investment Approaches”) in an attempt to achieve Investment Objectives (“Investment Objectives”) as described below. The TPFA and TP Client can customize a strategy by which each of the TP Client’s accounts will be managed or maintained. The specific Solution Type and the Investment Approaches selected for the Client’s Account(s) are referred to as the TP Client’s “Investment Strategy.” A TP Client will establish one or more investment accounts (each an “Account”) with a custodian, and the TP Client’s Accounts are collectively referred to as the TP Client’s “Investment Portfolio.” A TP Client will typically complete a questionnaire, or otherwise provide information to the TPFA to enable the TP Client and the TPFA to identify the TP Client’s rate of return objective, risk tolerance and other relevant information. The TP Client typically will provide the TPFA with information concerning the Client’s investment experience, anticipated need for liquidity, potential timing of the need for retirement Accounts, and other investment needs and parameters. The TPFA remains responsible for monitoring the Investment Strategy and recommending any changes to the TP Client. Portfolio Labs’ responsibility is to implement the Investment Strategy chosen by the TP Client and the TPFA. Portfolio Labs does not advise the TP Client about potential changes to the TP Client’s Strategy. For TP Clients of TPAFs, Portfolio Labs offers three Solutions, each implemented by a division of Portfolio Labs (Dynamic Wealth Management; Thematic Capital Management; and Direct Index Strategies) focused on Investment Solutions based on a particular Investment Approach. Dynamic Wealth Management Dynamic Wealth Management (“DWM”), a division of Portfolio Labs, offers an innovative, holistic, dynamic portfolio management service based on the individual goals, objectives, time horizon, and risk tolerance of each TP Client. The Dynamic Outcome Target Strategy (“DOTS”) offered by DWM is a customizable Investment Solution designed to be used in conjunction with a financial plan. There can be no guarantee that any Investment Solution’s objectives will be achieved. All Investment Solutions involve the risk of investment loss. Thematic Capital Management Thematic Capital Management (“TCM”), a division of Portfolio Labs, offers focused thematic- and style-based separately managed accounts (“SMAs”) that can be used on a stand- alone basis or combined into a single unified managed account (“UMA”). Thematic investing is an approach that focuses on predicted trends rather than specific companies or sectors, enabling investors to efficiently pursue returns associated with structural shifts that can affect entire industries and economies. There can be no guarantee that any Investment Solution’s objectives will be achieved. All Investment Solutions involve the risk of investment loss. Direct Index Strategies Direct Index Strategies (“DIS”), a division of Portfolio Labs, offers portfolios of individual equites managed in a manner similar to popular Accounts and ETFs. DIS portfolios are available only as SMAs; multiple Investment Strategies cannot be combined in a UMA. Portfolio Labs Disclosure Brochure Page 7 of 17 Direct index investing is an approach which attempts to improve upon the overall client experience of investing in a commingled vehicle through the use of individual securities and sophisticated portfolio construction techniques. Potential benefits include increased tax efficiency, greater precision of investment allocation, and/or lower cost. There can be no guarantee that any Investment Solution’s objectives will be achieved. All Investment Solutions involve the risk of investment loss. PORTFOLIO MANAGEMENT SERVICES – DIRECT CLIENTS In select circumstances, Portfolio Labs may offer investment advisory services to an individual or institution directly (a “Direct Client”), with no intervening TPFA. The Fee schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimum schedule located at the end of this Brochure. In that case, Portfolio Labs will consult with the Direct Client about Investment Objectives in order to identify an appropriate Investment Solution. Portfolio Labs creates an Investment Policy Statement (“IPS”) for each client that outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. In order to engage Portfolio Labs, the Direct Client will enter into an IMC that outlines the services to be performed by Portfolio Labs. Portfolio Labs requires discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each Direct Client. For Direct Clients, Portfolio Labs offers Investment Solutions from Thematic Capital Management and Direct Index Strategies, as described above. ADDITIONAL INFORMATION ABOUT PORTFOLIO MANAGEMENT SERVICES With respect to services offered to TP Clients and Direct Clients (together “Clients”), Portfolio Labs seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its Clients and without consideration of Portfolio Labs’ economic, investment or other financial interests. To meet its fiduciary obligations, Portfolio Labs attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Portfolio Labs’ policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Portfolio Labs’ policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Account Implementation Each Investment Solutions offered by Portfolio Labs has a minimum investment amount (“Account Minimum”). The Account Minimum for each Investment Solution is listed in the Fees & Investment Minimum schedule located at the end of this Brochure. A Client must deposit the Account Minimum into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a managed Account until the Account balance reaches the required minimum. A Client’s Account will be held by the Custodian in cash or in the assets transferred in- kind until such time as the value of the deposits to the Account reaches the required minimum for investment. Clients should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets, and Portfolio Labs will not be held liable for losses or missed gains due to market value fluctuations during the time taken for these transactions. Account Liquidity Reserve To properly maintain cash flows for Client needs, a portion of all Client Accounts invested in a Strategy is maintained in a short-term investment vehicle. This liquidity reserve or cash allocation is typically 2% and may be invested by Portfolio Labs in what is generally referred to as the Custodian’s cash “sweep” vehicle or a money market mutual Account

or other short-term pooled investment vehicle. Services Limited to Specific Types of Investments Portfolio Labs generally limits its investment advice to equities, fixed income securities, mutual Accounts and ETFs. Portfolio Labs may use other types of securities as well to help diversify a portfolio when applicable. Short-Selling Portfolio Labs recommends that, where available, allowed and appropriate, Clients establish Accounts allowing the short sale of equity securities. Clients permit Portfolio Labs to sell securities short via an Addendum to the IMC. The use of options is not suitable for all Clients. Clients should consider the risks and discuss with their TPFA their financial position and objectives and whether using short-selling is appropriate. Short Selling Risk: An Account enters into a short sale by selling a security it has borrowed (typically from a broker or other institution). If the market price of that security increases after an Account borrows the security, an Account will suffer a (potentially unlimited) loss when it replaces the borrowed security at the higher price. There is the risk that the security Portfolio Labs Disclosure Brochure Page 8 of 17 borrowed by an Account in connection with a short sale would need to be returned to the lenders on short notice. If such request for return of a security occurs at a time when other short sellers of the same security are receiving similar requests, a "short squeeze" can occur, wherein an Account might be compelled, at the most disadvantageous time, to replace the borrowed security previously sold short with purchases on the open market possibly at prices significantly in excess of the proceeds received earlier in originally selling the security short. Purchasing securities to close out the short position can itself cause the price of the security to rise further, thereby exacerbating any loss. In addition, an Account may not always be able to borrow the security at a particular time or at an acceptable price. Before an Account replaces a borrowed security, it is required to designate on its books cash or liquid assets as collateral to cover a Account’s short position, marking the collateral to market daily. This obligation limits an Account’s investment flexibility, as well as its ability to make distributions. Short sales also involve transaction and financing costs that will reduce potential Account gains and increase potential Account losses. Use of Borrowing Portfolio Labs recommends that, where available, allowed and appropriate, Clients establish Accounts with some form of flexible borrowing capacity (e.g., margin, asset-backed line of credit, etc.). Clients permit Portfolio Labs to use borrowing on a tactical (short-term) basis via an Addendum to the IMC. The use of borrowing is not suitable for all Clients. Clients should consider the risks and discuss with their TPFA their financial position and objectives and whether using borrowing is appropriate. Borrowing Risk: An Account borrows for investment purposes by pledging Account assets as collateral for the borrowing of capital (typically from a broker or other institution). If the borrowed capital is invested in securities that decline, an Account will suffer a larger loss than it would otherwise. If the Account value declines sufficiently, the Account may face a “margin call” requiring the sale of assets or the addition of capital to the Account. In that situation, an Account might be compelled, at the most disadvantageous time, to sell securities. Selling securities to close out the margin position can itself cause the price of the security to fall further, thereby exacerbating any loss. The margin requirement may limit an Account’s investment flexibility, as well as its ability to make distributions. Accounts must also pay interest to borrow, which will reduce potential Account gains and increase potential Account losses. Options Portfolio Labs recommends that, where available, allowed and appropriate, Clients establish Accounts allowing the purchase and sale of equity options. Clients permit Portfolio Labs to use options via an Addendum to the IMC. The use of options is not suitable for all Clients. Clients should consider the risks and discuss with their TPFA their financial position and objectives and whether using options is appropriate. Options Risk: An option is an agreement that, for a premium payment or fee, gives the option holder (the purchaser) the right but not the obligation to buy (a “call option”) or sell (a “put option”) the underlying asset (or settle for cash an amount based on an underlying asset, rate, or index) at a specified price (the “exercise price”) during a period of time or on a specified date. Investments in options are considered speculative. The prices of options are volatile and are influenced by, among other things, actual and anticipated changes in the value of the underlying instrument, or in interest or currency exchange rates, including the implied volatility, which in turn are affected by fiscal and monetary policies and by national and international political and economic events. When an Account purchases an option, it may lose the total premium paid for it if the price of the underlying security or other assets decreased, remained the same or failed to increase to a level at or beyond the exercise price (in the case of a call option) or increased, remained the same or failed to decrease to a level at or below the exercise price (in the case of a put option). If a call or put option purchased by an Account were permitted to expire without being sold or exercised, its premium would represent a loss to an Account. By writing put options, an Account takes on the risk of declines in the value of the underlying instrument, including the possibility of a loss up to the entire exercise price of each option it sells but without the corresponding opportunity to benefit from potential increases in the value of the underlying instrument. When an Account writes a put option, it assumes the risk that it must purchase the underlying instrument at an exercise price that may be higher than the market price of the instrument. If there is a broad market decline and an Account is not able to close out its written put options, it may result in substantial losses to an Account. By writing a call option, an Account may be obligated to deliver instruments underlying an option at less than the market price. In the case of an uncovered call option, there is a risk of unlimited loss. When an uncovered call is exercised, an Account must purchase the underlying instrument to meet its call obligations and the necessary instruments may be unavailable for purchase. An Account will receive a premium from writing options, but the premium received may not be sufficient to offset any losses sustained from exercised options. By writing call and put options on underlying instruments, the returns of the options writing strategy will be determined by the performance of the underlying instrument. If the underlying instrument appreciates or depreciates sufficiently over the period to offset the net premium received by an Account, an Account may incur Portfolio Labs Disclosure Brochure Page 9 of 17 losses. Increases in implied volatility of options may cause the value of an option to increase, even if the value of the underlying instrument does not change, which could result in a reduction in an Account’s value. In unusual market circumstances where implied volatility sharply increases or decreases causing options spreads to be significantly correlated to the underlying instrument, an Account’s option writing strategy may not perform as anticipated. Prior to the exercise or expiration of the option, an Account is exposed to implied volatility risk, meaning the value, as based on implied volatility, of an option may increase due to market and economic conditions or views based on the sector or industry in which issuers of the underlying instrument participate, including issuer-specific factors. CLIENT TAILORED SERVICES AND CLIENT- IMPOSED RESTRICTIONS Clients may request that Portfolio Labs customize an Investment Solution via an Addendum the IMC. Portfolio Labs may use security-specific analysis and/or model allocations together with a specific set of recommendations for each client based on his/her personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Portfolio Labs from properly servicing the client account, or if the restrictions would require Portfolio Labs to deviate from its standard suite of services, Portfolio Labs reserves the right to reject the request or end the investment relationship. WRAP FEE PROGRAMS A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. Portfolio Labs does not participate in wrap fee programs. ASSETS UNDER MANAGEMENT Portfolio Labs had the following assets under management as of December 30, 2022: Discretionary Amounts: Non-discretionary Amounts: $102,921,542 $0