General Smartadvisor LLC (“BUNKER”, or the “Adviser” or “we”) is a limited liability company organized in the State of Delaware and registered at the US Securities and Exchange Commission to conduct business as a Registered Investment Adviser. BUNKER is wholly owned by Smartadvisor Holdings Inc., a privately held company incorporated under the laws of Delaware. For more information, we encourage you to visit: Part 1 of Smartadvisor LLC’s Form ADV which is available online at www.adviserinfo.sec.gov . Description of Advisory Services BUNKER is an online wealth management service that provides automated, algorithm based portfolio management advice without the direct use of human financial planners. This Brochure is meant to help you understand the nature of your investments, you should review it carefully. As an online investment adviser, BUNKER offers investment management services on a discretionary basis, according to the investment goals and risk profile of the client. BUNKER manages several investment portfolios of Exchange Traded Funds (commonly known as “ETFs” as well as those issued under the Undertakings for Collective Investment in Transferable Securities “UCITS”, hereinafter collectively referred as “ETFs” ), and diversifies the investment among asset classes within these portfolios according to the client’s risk and investment profile. BUNKER utilizes proprietary algorithms and methodologies for developing and implementing various portfolios with differing risk criteria/thresholds comprised of ETFs. The Adviser utilizes the services from APEX Clearing Corporation (“APEX”) and Interactive Brokers (“IBKR”) (both APEX and IBKR members of FINRA/SIPC, hereinafter, the “Broker” or “Brokers”) for all the brokerage and clearing services. Our strategy is a passive investment strategy with portfolio allocations determined using Modern Portfolio Theory methodologies and the Capital Asset Pricing Model. Given a customer’s specific risk profile, which we determine through an online interview process, our algorithms will assign an optimized allocation which aims to maximize potential return while maintaining an appropriate level of expected volatility for the overall portfolio. Our methodology advises clients to invest in well-diversified securities portfolios, with the continued belief in the success of long-term compounding of passive investing.

We implement this methodology through our online platform, by recommending a portfolio of ETFs that matches clients’ individual needs. We choose low-cost ETFs as the investment vehicle to represent each asset class to add to the compounding effect that maintenance and transactional costs can have over the returns of a portfolio overtime. The investments offered by BUNKER are integrated in a platform, where clients answer a series of personal and investment related questions, thus setting a recommended allocation between portfolios available through the program. When clients transfer funds to their BUNKER account, they will be initiating transactions for the purchase of proportional interests in the available portfolios of ETFs, in an amount that corresponds to their asset allocation. When clients withdraw money from their BUNKER account, they are initiating transactions for the sale of proportional interests in the available portfolios of ETFs. Similarly, when clients adjust their allocation they are initiating transactions to ETFs for one another to reflect the updated allocation. BUNKER offers an automatic ‘rebalancing’ tool of client portfolios so that in the face of fluctuating market prices each client’s portfolio remains controlled within a narrow range of their allocation. Certain BUNKER clients may choose to separate a given amount of cash to remain un-invested within a Cash Reserve Feature. Uninvested cash in a client’s account using the Cash Reserve Feature is automatically deposited to the APEX FDIC Sweep Program (“Sweep Program”), an interest-bearing deposit program insured by the Federal Deposit Insurance Corporation (FDIC). Therefore, certain BUNKER customers may have their cash balances in their brokerage accounts “swept” into an interest-bearing FDIC-insured deposit account opened by APEX at a participating bank, where it will earn interest paid into their brokerage account. The interest rate is based on several factors, including the current interest rate environment, and is subject to change without notice. Deposits to the FDIC Sweep Program are covered by FDIC insurance. For complete information, please read the Terms and Conditions to learn more details. You may access the list of banks participating in the Program by accessing the Program Bank List. BUNKER clients may opt out of the Sweep Program by notifying BUNKER at any time.