A. Pave Investment Advisors, LLC’s (“Pave”) is a Limited Liability Company formed on November 30, 2022, in the State of Delaware. Pave is wholly owned by Pave Finance, Inc., a Delaware C Corporation. B. As discussed below, Pave offers discretionary and non-discretionary investment management to clients. Pave does not provide financial planning services. Risks Associated with Providing Non-Discretionary Advice Pave provides certain advice on a discretionary and non-discretionary basis in the form of separate accounts or consulting services. Such services are highly tailored pursuant to the request or needs of each client. Although Pave does not provide recommendations regarding specific securities on a security by security basis, it is possible that a client may rely on the market analysis or economic views of Pave in a way that was not intended or envisioned by Pave and to the detriment of the client. Any security Pave recommends is only on a discretionary or non-discretionary basis and in the context of asset allocation, portfolio management with an objective to manage and mitigate single stock risk the client may already have in their portfolio. Pave has taken and will take action to mitigate the risk associated with any unintended use of its non- discretionary advice through the use of appropriate disclosures in its arrangements with such clients. Clients who use Pave’s non-discretionary advice shall accept or reject Pave’s recommendations in Client’s sole discretion. Discretionary Advice Clients that engage Pave on a Discretionary basis will appoint Pave as a Discretionary Investment Adviser (CLIENT HAS TURNED ON AUTOMATIC UPDATES IN THE APPLICATION) to perform the services hereinafter described, and Pave accepts such appointment. Pave shall be responsible for the investment recommendations of those assets designated by Clients to be subject to Pave’s discretionary management. Client understands and acknowledges that in the event it is receiving discretionary investment advice from Pave, the Client grants all of authority and power with regard to the investment and reinvestment of the Assets in Pave’s name for the Account. Client grants Pave the authority, to execute any transactions in Client’s Account. Client appoints Pave to maintains all rights, to buy, sell, trade and allocate in and among stocks, bonds, mutual funds and exchange traded funds on margin (only if written authorization has been granted in the account opening process) or otherwise, and to give instructions in furtherance of such authority to any registered broker-dealer and/or the custodian of the Assets. Unless the Client has advised Pave to the contrary in writing, there are no restrictions that the Client has imposed upon Pave with respect to the discretionary recommendations related to the Assets. Client agrees to provide information and/or documentation requested by Pave in furtherance of this Agreement as pertains to Client’s objectives, needs and goals, and maintains exclusive responsibility to keep Pave informed of any changes regarding same. Client acknowledges that Pave cannot adequately perform its services for the Client unless the Client diligently performs his responsibilities under this Agreement.

Pave shall not be required to verify any information obtained from Client, Client’s attorney, accountant or other professionals, and is expressly authorized to rely thereon. Pave does not support discretionary management of retirement plan sponsored accounts of a Client’s employer and will not accept such appointment. INVESTMENT MANAGEMENT SERVICES Clients can engage Pave to provide discretionary or non-discretionary investment management advice. Pave manages client recommendations using quantitative and algorithmic methods. Pave generally updates the quantitative and algorithmic models in the Pave application weekly, but we recommend Clients review their portfolio monthly. Pave generally will recommend clients to purchase individual securities among global equities but in rare circumstances may also recommend exchange-traded funds (“ETFs”), and cash as may be appropriate for each client. In performing its discretionary or non-discretionary investment services, Pave does not verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on information provided by the client when providing investment recommendations. Each client is responsible for promptly notifying Pave if there is ever any material change in their financial situation or investment objectives so that Pave can review, and if necessary, revise its previous non-discretionary recommendations. Pave does not provide financial planning and related consulting services, such as estate, tax and insurance planning. Pave and its agents do not serve as attorneys, accountants, or insurance agents. Pave will not recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance agents). C. Pave shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, Pave requests that clients provide accurate current holdings and indicate a willingness to sell any of the current holdings and available cash client wants to be included in the analysis. Additionally, Pave will receive the client’s particular investment objectives before making the discretionary or non-discretionary recommendation. Pave will make each client’s discretionary or non-discretionary investment recommendation consistent with their designated investment objectives. Clients may, at any time, impose certain restrictions, on Pave’s recommendations within the client questionnaire on Pave’s application. Pave has NO discretion in determining whether any restriction request is reasonable or appropriate. D. In the event of the non-discretionary advice, Client is responsible for following through on Pave’s entire portfolio recommendation in the specific allocation Pave recommends. If the Client does not implement the specific recommendation in a timely manner or in whole, the Client will likely create undue risk and unintended consequences in their investment portfolios. This could result in significantly more volatility and the risk of loss that was not tested or contemplated with the entire recommendation. E. Pave does not currently participate in a wrap fee program.