Envel provides a mobile- and web-based investment advisory application where clients can gain investment exposure to publicly traded stocks and an Exchange Traded Fund (“ETF”). Envel Investments, LLC opened its doors in 2021. Our principal owner is Stephen Le Roux and our Chief Compliance Officer is Clay Resnick. Our clients use the Envel-issued debit card to make purchases. Once subscribed to Envel’s advisory service and fractional round-up strategy, each client will complete an investment profile that is used to scope individual investment objectives and risk tolerance for the advisory account assets. The account is then funded through “rounding-up” purchases of goods and services to the nearest dollar for investment. The amount rounded-up can be as small as five cents ($.05) or as large as one dollar ($1), as determined by each purchase. It must be noted that Envel’s fractional round-up strategy invests primarily in equities (i.e., common stock) issued by major U.S. retailers and merchants. Envel developed and uses a proprietary, automated software to facilitate investment of client assets in fractional shares (including micro-shares) of specific equity securities or an ETF. Specifically, the software attempts to correlate the merchant information returned by Visa, Mastercard, or other card issuer to purchase fractional shares of common stock in publicly traded companies. If the software can’t accurately match a client’s debit card purchase to a common stock, then the assets will be used to purchase a fractional share of an ETF. The ETF primarily consists of common stock in a blend of publicly traded U.S. corporations. The list of merchants that Envel’s software consistently matches to common stock using the fractional round-up strategy can be found on this website: www.envel.ai Envel’s core banking clients become eligible to participate in advisory services offered by Envel Investments, LLC only after a banking relationship has been established with Envel, Inc. and accounts have successfully been opened at nbkc Bank, Member FDIC. Upon successful completion of customer identification and due diligence requirements imposed by nbkc, Envel’s clients will be provided with the option to establish an advisory relationship with Envel Investments, LLC and brokerage account with DriveWealth, LLC, an independent broker-dealer further described in Item 12 below (“DriveWealth”). Clients can accept the full suite of advisory disclosures and agreements, and the fractional round-up feature can then be toggled on and off within the mobile app. Envel facilitates the flow of funds between nbkc Bank and DriveWealth via ACH transfers to settle buy and sell orders. Both buy and sell orders are sent by Envel’s software to DriveWealth in real-time as live market orders, and confirmation is provided by DriveWealth to Envel upon completion of each trade. It must be noted that trades are only executed and confirmed by DriveWealth during market hours, and Envel will provide clients with the status of pending trades

in-app. Envel’s clients must have available cash to facilitate trades in their Envel Cash Envelope account at nbkc Bank in order to participate in Envel’s advisory strategy; otherwise, buy orders will not be submitted. The purchases and sales of investments for each client’s account are placed by Envel with DriveWealth. DriveWealth maintains all client accounts as custodian. In addition, DriveWealth charges a monthly account fee for each client holding securities. DriveWealth also charges other various fees to Envel to cover account opening, monthly and yearly statements, and other general account costs. Envel bears all of the foregoing fees and expenses charged by DriveWealth and only charges its clients the monthly subscription fee of $1.99. The full complement of Envel’s advisory services includes basic investment data that is provided in-app, including cost basis (i.e., how much you’ve invested in each stock or ETF), the current value of each investment, and the charts and/or graphs that show historic performance of each security over a selected period of time. This information is obtained by Envel directly from DriveWealth and presented to clients in-app. Envel does not provide custom analytic or technical analysis to clients, nor does Envel’s customer support team provide customized investment advice or investment recommendations in any way. While we obtain, review, and update your profile once you complete it, all decisions to invest are made by each client and we do not monitor your account or individual investments, except as noted below under Item 13. We do not currently provide comprehensive financial planning services, and the investment advisory services provided by Envel are not a complete investment, estate planning, or wealth management program. We are not aware of your aggregate investable and invested assets. Therefore, we encourage you to consider additional asset classes, strategies, and investments to supplement your overall investment plan if appropriate for your investment goals. You may find it beneficial to incorporate other platforms or investments into your investment portfolio outside of the services provided by Envel. Envel's investment advisory services are exclusively available through the web (envel.app) or mobile app, which is publicly available for download in both the U.S. Apple and Google play stores. Envel does not accept or perform any buy or sell trade orders outside of these channels, nor does it accept trade orders through any customer support channel. Clients should contact [email protected] for any concerns, questions, or support requests. As of March 23, 2023, Envel Investments had $35,867.63 in total Assets Under Management (“AUM”). In addition, Envel plans to develop additional advisory strategies in 2023-4 beyond what is described above, which includes:
• Increased round-up amounts
• Risk-based ETF selections
• Money market offerings
• Conversion of long-term cash savings into fixed income (e.g., bond fund) strategies