ADVISER DESCRIPTION Legion Global Capital Management LLC, d/b/a Legion Invest (hereinafter referred to as “Legion”, “Adviser”, “we”, “us”, “our”) is a Delaware corporation with its principal office located in New Jersey and is registered with the Securities and Exchange Commission (the “SEC”) as an investment adviser. Legion is a subsidiary of Legion Invest Co, a Delaware corporation. Mr. Steven Dong and Mr. Feras Abou Salim are co-founders of Legion. ADVISORY SERVICE Legion provides investment advisory services to retail individual investors, high net worth individuals, registered investment advisors, family offices and other business entities exclusively through a technology platform offered only through our application programming interface (the “Platform”). The Platform may be offered to our clients via unaffiliated third- party institutions with whom Legion has entered into agreements regarding the offering of advisory services by Legion (“Partners”). These individuals will be considered clients of Legion and will have access directly to the Platform. In certain cases, Legion may act as a sub-adviser to a third-party investment adviser. Legion is a technology company that owns and maintains the Platform through which advisory clients have access via our Partners. Our clients receive investment recommendations via the Platform for various quantitative investment strategies based on a detailed questionnaire that clients complete at onboarding (further described below). Our advisory services are offered as a wrap fee program to retail clients. Our wrap fee program provides our clients the opportunity to obtain professional portfolio management for an inclusive fee that is based upon the client’s assets under our management. This means clients are free to add or withdraw money from their Legion advisory accounts whenever they choose, with no additional fees, notwithstanding any fees assessed by a client’s own financial institution. Legion charges clients a single bundled fee that covers our investment advisory services as well as brokerage and custodial services associated with holding and trading securities provided by our custodian. Our investment strategies are offered and recommended to clients exclusively through our Partners who will provide investors with access to the Platform. Our investment recommendations are based on a detailed questionnaire that clients complete at onboarding. Our advisory service delivers discretionary portfolio management services through the strategies. Each strategy is designed to provide clients with an efficient way to invest in the capital markets based on each client’s individual investment time frame, risk tolerance, and liquid net worth. To get started, we ask prospective clients to respond to a sequence of interactive questions that are important to the development of their portfolios, such as investment objective, purpose for investing, risk/return tolerance, annual income, among others. Following responses, clients receive a recommended investment strategy developed to be appropriate for the client’s personal financial situation and that targets a client’s expected risk and return, investment objective and purpose for investing. The recommended investment strategies we offer are the Gold Tier or the Platinum Tier strategies. The investment recommendation is delivered for viewing over our application programming interface. If a client accepts our investment recommendation, clients are invested directly in the securities found within the recommended investment strategy and such investment is based on allocations produced by our proprietary algorithm. Otherwise, a client can elect to override Legion’s recommendation and choose strategies that they are eligible for. INVESTMENT STRATEGIES We seek to provide personalized, long‐term oriented investment portfolios that are invested in our strategies, either Platinum Tier or Gold Tier (further described below). Each strategy is comprised primarily of a concentrated basket of stocks, ETFs or ETNs which are selected via our proprietary and fully discretionary algorithmic research process and are actively managed. Clients are invested in a personalized blend of these strategies based on personal information provided during the onboarding process (see above). This information includes a client’s investment risk and goals, investment objectives and various financial parameters such as net worth. Our proprietary algorithm monitors clients’ portfolios that are invested in each strategy. The minimum deposit to a client’s account will be $100. PLATINUM TIER STRATEGIES Platinum Tier investment strategies have a higher minimum investment and a differentiated risk/return profile. A client must meet higher minimum eligibility requirements of employment status, annual income, and investment goals to receive a recommendation into the Platinum Tier. Prior to investing in the Platinum Tier clients will be provided with a description and objective of each recommended strategy including the number of days the strategy has been live, the type of securities the strategy invests in, the turnover rate, the drawdown rate and the CAGR rate. Additionally, a document displaying an overview of the recommended strategy will also be available for clients to view. The Firm, via its proprietary algorithm, may purchase whole or fractional shares within a client’s account. Through its discretionary authority the Firm will allocate and rebalance shares within a client’s account as necessary. Purchases are based on the mandate of the recommended Platinum Tier strategy and the amount invested by the client. The minimum deposit to a client’s account will be $100. GOLD TIER STRATEGIES Gold Tier investment strategies will have a wide range of risk/return profiles. A client must meet minimum eligibility requirements of employment status, annual income, and investment goals to be part of the Gold Tier. Prior to investing in the Gold Tier investment strategies, clients will be provided with a description and objective of each recommended strategy including the number of days the strategy has been live, the type of securities the strategy invests in, the turnover rate, the drawdown rate and the CAGR rate. Additionally, a document displaying an overview of the recommended strategy will also be available for clients to view. The Firm, via its proprietary algorithm, may purchase whole or fractional shares within a client’s account. Through its discretionary authority the Firm will allocate and rebalance shares within a client’s account as necessary. Clients approved to invest in the Platinum Tier will have access to both Platinum Tier investment strategies and Gold Tier investment strategies. This may change if the suitability information provided by the client is revised. The minimum deposit to a client’s account will be $100. INVESTING We use information from the initial questionnaire that all clients are required to complete at onboarding to create an investment portfolio that is customized to each clients’ risk tolerance, financial parameters and investment objectives. For each client’s portfolio we consider, through our proprietary algorithm, a client’s employment status, income, investment goals and reasons to invest, and net assets. Our proprietary algorithms evaluate the responses for each client and recommend investment strategies (described above). Our recommendations are based solely upon the information provided by each client via the Platform. As such, the suitability of our investment recommendations is limited by and relies on the accuracy and completeness of the information provided by each client. The only type of restrictions a client may impose on the portfolio is the degree of risk level (conservative, moderate and aggressive growth) and the amount of funds invested in each investment strategy. A client will not be able to restrict the purchase of specific securities, however clients will be able to change his/her risk profile or select (switch to) a portfolio with a different risk profile. Clients are obligated to update their information through the Platform as soon as there are changes to their financial situation, goals, objectives, personal circumstances, or if other relevant information changes or becomes available. Clients ultimately decide whether to accept and act upon our investment recommendations. Investing in securities involves risk of loss that clients should be prepared to bear. INVESTMENTS In the event we decide to remove a stock, exchange traded fund and/or note from any of our strategies, we will notify our clients and our Platform will show the removed or modified position. We will also algorithmically rebalance our clients’ portfolio to its original desired risk preference. Interested parties must access our secure Platform where clients are offered this current Form ADV brochure that describes our services, potential fees, etc., as well as any material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and objective advice. CLIENTS We currently offer investment recommendations and advisory services to retail individual investors, high net worth individuals, registered investment advisors, family offices and other business entities via our Partners which provide access to the Platform. We interact with investment advisory clients, as well as prospective clients, solely through our Platform. We do not offer financial planning services, tax, accounting, or legal advice. Clients can only invest in U.S. securities. Clients will not interact directly with investment advisory personnel. We reserve the right to deny any prospective clients access to the Platform and to terminate client accounts for reasons related, but not limited, to unsuitability and/or if clients fail to timely maintain financial and other information previously provided by the client on the Platform or update this information on at least an annual

basis. A client’s failure to timely update this information could materially impact the quality and applicability of Legion’s advice and recommendations. CLIENT ONBOARDING At account opening (“Client Onboarding”), the client will be prompted to complete a series of personal financial questions as well as suitability questions prior to investing. Some of these questions determine if the client can invest with Legion. For KYC purposes, clients will be required to disclose their employment status, occupation, annual income, address and citizenship status. Furthermore, clients are also required to disclose if the client or a family member is a senior executive or a 10% shareholder of a publicly traded company; if the client is related to a politically exposed person (PEP); and whether the client is employed by a broker-dealer. Client Onboarding is only complete once a client has (i) completed our initial questionnaire which includes personal financial questions as well as suitability questions; (ii) electronically accepted and countersigned our investment advisory agreement and brokerage agreement; (iii) electronically received and accepted our Form ADV Part 2A, Form CRS and privacy policy; and (iv) consented to electronic delivery of documents and written communication. Only when Client Onboarding is complete will we provide personalized investment recommendations in one or more of our Strategies. Clients have the availability to choose a strategy to purchase via the Platform. It is important to note that none of our staff will have access to a client’s bank account information or a client’s login credentials. ASSETS UNDER MANAGEMENT Legion does not currently have assets under management. We expect to update this brochure as soon as we start servicing clients. The Firm will have sole discretion over the assets we manage. The minimum deposit to a client’s account will be $100. ADVISORY FEES Client’s pay an investment advisory wrap fee which allows clients to pay a single fee for investment advisory services (the “Wrap Program Fee”), as described below. The Wrap Program Fee is a bundled fee, which includes the cost for advisory services, execution, clearance, custody and account reporting. Legion charges clients a Wrap Program Fee based on the total net deposits in their account and the investment strategy the client is invested in. The Wrap Program Fee is separate from fees imposed by a client’s separate relationship with a Partner. For clients with less than $5,000 in net deposits, Legion charges a Wrap Program Fee of $5.00 per month (fixed fee). For clients with greater than $5,000 in net deposits, Legion charges a Wrap Program Fee based on the assets under management that clients have invested in one of our two investment strategies. Legion charges clients who are invested in the Legion Gold Strategies (and have $5,000 or more in net deposits) a 1.00% advisory fee, per annum, for the assets they have invested in Legion Gold Strategies. Clients invested in Legion’s Platinum Strategies (and have $5,000 or more in net deposits) are charged a 2.00% advisory fee, per annum, for the assets they have invested in Legion Platinum Strategies. We reserve the right, in our sole discretion, to negotiate, reduce, or waive the advisory fee. Our fees are billed monthly, in arrears. The asset-based fee is assessed based on the daily market value of a client’s portfolio summed over the previous month. For the initial period of an engagement, the Wrap Program Fee is calculated on a pro rata basis. In the event the Investment Advisory Agreement is terminated by either party, the Wrap Program Fee for the final billing period is prorated through the effective date of the termination and the outstanding portion of the Wrap Program Fee is charged to the client. Clients authorize Legion to deduct fees directly from their client account custodied at our custodian or from an external funding source provided by the client. Legion will have no access to the client’s account or to a client’s external funding source except only to debit investment advisory fees. Although we have a financial incentive to encourage you to increase your assets under our management, as part of our fiduciary duty as a registered investment adviser we endeavor at all times to put the interests of our clients before our own. Furthermore, as a registered investment adviser we have the utmost duty to provide investment advisory services in good faith, honesty and loyalty to our clients. Legion has entered into agreements with its Partners whereby Legion compensates its Partners via a revenue sharing structure for referring Clients to Legion, however, there is no differential in the Wrap Program Fee charged to the Client as a result of these agreements. For additional information regarding this arrangement, please see Item 14, below. DIRECT FEE DEBIT OF LEGION’S FEE Clients authorize and direct Legion to instruct the custodian to deduct the Wrap Program Fee directly from the client’s custodial account at our custodian or linked funding source and pay those fees to Legion. Legion may also take the Wrap Program Fee from a client’s account by instructing our broker to deduct such fee from the assets in the client’s account, including by selling (liquidating) a sufficient amount of holdings to cover the Wrap Program Fee. Each time a client uses our advisory services, they reaffirm their agreement that Legion may charge the client’s account, as applicable. In the event Legion cannot withdraw fees from the client’s account or the client’s funding source, Legion reserves the right to terminate a client’s access to its advisory services. We will notify clients in writing via the email the client has on file with their account of the potential of termination of our advisory services. Termination of accounts will be undertaken at Legion’s sole discretion with prior written notice to the client. Each client may also terminate their account at any time. Upon full termination of a client’s account by the client, assets are liquidated as soon as practicable, and money is returned to the client via the client’s funding source less any Wrap Program Fee due and owing, if applicable. However, with prior written notice, we may accommodate a client and transfer the client’s holdings to another custodian. Clients are advised that transferring their holdings to another custodian may generate fees that client should be prepared to pay. Once the account termination process is initiated, Legion will receive the Wrap Program Fee from the client with respect to the client’s account, which will be deducted from the transferring proceeds. PAYMENT OF FEES Fees are billed monthly in arrears and fee payments are generally withdrawn from the client’s account within the first ten days of each month. Legion does not accept cash, money orders or similar forms of payment for any of its engagements, nor do we allow for direct billing. The client’s first billing cycle begins once the Advisory Agreement is virtually executed with Legion at onboarding and assets have been invested. Fees for partial months are prorated based on the remaining days in the reporting period in which Legion services the account. All fees deducted will be clearly noted on account statements that the client receives from the custodian. Please note that each client shares in the responsibility to verify the accuracy of fee calculations; the custodian may not necessarily verify billing accuracy for each client. Clients will receive statements directly from our custodian at least quarterly. We urge clients to carefully review those statements and compare the custodial records to the reports that we provide them. The information in our reports may vary from custodial statements due to accounting procedures, reporting dates or valuation methodologies of certain securities. TERMINATION OF SERVICES Either party may terminate the Investment Advisory Agreement at any time, which should be done in writing. If a client orally notifies Legion of the termination and if, within two business days following this notification Legion has not been sent the written notice by the client, Legion will prepare and send a written notice of the termination to the client. Upon receipt of a termination notice or when a termination is sent to a client, Legion will not be responsible for future investment allocation, advice or transactional services (except for limited closing transactions). Legion will inform our broker/custodian that the Investment Advisory Agreement has been terminated and our broker/custodian will close the account within seven days of termination. ADDITIONAL CLIENT FEES There are no sales loads, brokerage fees, mark-ups, mark-downs, spreads paid to market makers, or brokerage termination or account surrender fees associated with our programs. A client may, however, incur certain separate charges imposed by their separate relationship with a Partner or the broker or custodian, such as: wire transfer and electronic fund fees, retirement plan custodial fees, or account termination fees, in addition to certain taxes on non- retirement brokerage accounts, which are described in the fee schedule that is provided to the client prior to account inception. SERVICES PURCHASED SEPARATELY The total costs associated with our Wrap Fee Program may be more or less than separately purchasing brokerage and advisory services by our clients. The factors that bear upon the relative costs of our Wrap Fee Program includes the number and timing of transactions, referral fees (if any), portfolio management and custody fees, regulatory, compliance, and administrative charges, research costs, and promotional materials, among others. These and other factors may affect the cost of obtaining these services separately from another provider. Clients should always consider other programs offered by other firms, as well as whether paying separately for investment advice, brokerage, and other services is more appropriate for their personal situation.