A. Description of the Advisory Firm Borderless was founded on December 3, 2021. Additional information about Borderless is available on the SEC’s website at www.adviserinfo.sec.gov. The CRD number for Borderless is #318077. The SEC’s website also provides information about any persons affiliated with Borderless who are registered, or are required to be registered, as investment adviser representatives of Borderless. Borderless is a privately held company headquartered in Bangalore, Karnataka, India. Borderless is wholly- owned by Borderless Investing Inc., whose principal shareholders are Sitashwa Srivastava, Chief Executive Officer and Vinay Bharathwaj (together, the “Principals”). Sitashwa Srivastava will initially serve as Borderless’ Chief Compliance Officer (“CCO”). Information about Borderless’ organizational and ownership structure is provided on Part 1 of Borderless’ Form ADV. Borderless is a registered investment adviser (“RIA”) which offers non-discretionary advisory services to its advisory clients (each a “Client,” and collectively, “Clients”) through an online web-based platform (the “Platform”). This business model, also referred to as a “robo-adviser” model, makes use of algorithms to automate (or to assist in making) investment recommendations. Clients create and manage their investments with limited, if any, human interaction. Borderless operates an investment Platform available at https://borderlessinvestmentadvisors.com (the “Website”). When a Client opens an account (“Investment Account”) with Borderless, they will be able to access the investment Platform through the Website. The Platform provides Clients with investment advice in the form of a portfolio recommendation (“Portfolio Recommendation”) designed to meet each Client’s self-identified financial goals. The investments recommended through the Platform include only exchange trades funds (“ETFs”) and publicly traded equities. Advisory services are delivered solely through the Platform. Borderless does not provide investment advice in person or over the phone or in any manner other than through the Platform. Additional information about Borderless’ products and services is provided in Borderless’ Form ADV Part 1. Borderless encourages visiting the Website for additional information. B. Description of the Advisory Services Equities and ETF Portfolio Recommendations Borderless provides purely non-discretionary advisory services through the Platform. The Platform makes a Portfolio Recommendation to meet each Client’s self-identified financial goals based on a Suitability Questionnaire (“Suitability Questionnaire”) completed by each Client. The Platform currently relies solely on questions relating to suitability (i.e., age, income and liquid net worth, investment objectives, investment time horizon, and risk tolerance) in making a Portfolio Recommendation, and these questions are not weighted equally. Clients should understand Borderless’ Portfolio Recommendation relies upon the information provided by each Client, and Borderless does not capture

any additional information not covered in the Suitability Questionnaire in making a risk assessment and providing investment advice. Prior to implementation, Borderless, tested all algorithms to confirm that the results are consistent with expected outcomes. Borderless will also conduct back-testing to ensure the algorithms continue to produce the intended results. Testing will be conducted on a periodic basis. Borderless is responsible for maintaining the algorithms. However, Borderless does not override the algorithm to provide alternative recommendations to any particular Client, whether based on any additional criteria provided by the Client, market and/or economic conditions, or otherwise. Clients should be aware that the algorithms rely upon Borderless Investment Advisors LLC Brochure March 2024 Page 5 of 27 their answers to questions relating to their risk tolerance, investment objectives, and investment time horizon provided through the Suitability Questionnaire, and that such answers serve as inputs to the algorithms. Borderless has implemented its Portfolio Recommendations for Clients’ Investment Accounts beginning in the first quarter of 2023. When implementing Portfolio Recommendations for Client Investment Accounts, the Portfolio Recommendation will be rebalanced on an ongoing basis, as determined by Borderless. If the holdings of a Client’s Investment Account significantly deviate from the existing target asset allocation, Borderless will initiate a rebalancing to bring the holdings within an acceptable range of the target asset allocation. The rebalancing process is not limited to the number or frequency of rebalances and is driven by Borderless’ decisions on the composition and holdings. As a result, there is a possibility that Borderless may sell overrepresented equities and ETFs and use the proceeds to buy underrepresented equities and ETFs to bring portfolios towards their target allocation without taking into account individual tax consequences or market circumstances. As set forth above, Borderless has implemented its Portfolio Recommendations for Clients’ Investment Accounts beginning in the first quarter of 2023. When implementing Portfolio Recommendations for Client Investment Accounts, the investments in each Client’s Investment Account will be held in a separate account in the name of the Client at a to-be-determined an independent custodian (the “Custodian”), and not with Borderless. All Investment Accounts managed through the Platform are required to use the Custodian selected by Borderless. Each account agreement with the Custodian will grant Borderless the authority to manage each Client’s Investment Account on a non-discretionary basis, seeking a Client’s authorization for each trade except for rebalancing in the same portfolio, where Borderless maintains discretionary authority to complete the rebalance without Clients’ prior approval. Borderless does not participate in wrap fee programs. C. Assets Under Management As of the date of this filing, Borderless has initiated the process of managing client assets. Borderless Investment Advisors LLC Brochure March 2024 Page 6 of 27