A. Description of the Advisory Firm Wing Financial Inc. (hereinafter “WFI”) is a corporation organized in the State of Delaware. The firm was formed in November 2021, and the principal owners are John Sharpe and Sean Wing. B. Types of Advisory Services Tech Enabled Financial Planning Platform Services WFI provides tech enabled financial planning platform services through its mobile application and website. The base subscription includes: 1) automated financial guidance based on activated “life experiences”, 2) high-level guidance from a team of financial planning specialists who provide guidance through an in-app Q&A tab, and 3) member’s only content and education included within the application. Automated Financial Guidance Clients provide information about themselves, their investment goals, and their overall life goals. WFI will formulate financial planning guidance based on this information. WFI will consider the following aspects of a client’s situation: assets and liabilities, financial goals, lifestyle preferences, applicable time horizons, income-based scenarios, investment risk preferences, and personality traits. Proposed financial planning guides – which are furnished by WFI’s proprietary algorithm – will provide personalized guidance that adheres to a fiduciary standard, including guidance for savings, money management, asset allocation, and funding. Each planning guide provided by WFI is based solely upon information provided by the client. As a result, the planning guide relies on accuracy and completeness of the information provided by the client. Specialist Team The Specialist Team is a team of at least three licensed financial planners who are responsible for 1) answering general financial planning questions through the in-app “Ask The Team” module, 2) constantly updating and refining data for the WFI Experience Portfolio module, 3) creating occasional video or written content relevant to financial guidance for the benefit of members, and 4) working with the Executive Team to develop new experience topics that can be included within the WFI Experience Portfolio. Member Content In addition to tailored planning guides for each activated “experience”, members will occasionally

receive Insights that are based on activated experiences. Insights are delivered in the Home feed and within the Experience module. Additionally, subscribers (clients) can receive creative content, such as video interviews or updates, within their in- app Home feed. Written Acknowledgement of Fiduciary Status When we provide investment guidance to you regarding an activated Experience within your Experience Portfolio, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money may create some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment guidance (give prudent advice);
• Never put our financial interests ahead of yours when making guidance or recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions WFI will provide an in-app planning guide for each individual client. A set minimum amount of questions for each experience must be answered in order to generate a planning guide. WFI may use model allocations together with a specific set of guidance for each client based on their personal restrictions, needs, and targets. Clients may not impose restrictions in guidance or types of guidance in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the client pays one stated fee that includes management fees and transaction costs. WFI does not participate in wrap fee programs. E. Assets Under Management WFI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $0 December 2022