Investment Recommendation Services X1 Wealth LLC is an internet investment adviser and provides investment advisory services to individual clients who reside in the USA, through an app that X1 Inc. (X1 Wealth LLC’s parent company, also referred to as “Parent Company”) owns and operates (the “App”). X1 Wealth has a licensing agreement with X1 Inc. for the investment module within the App and X1 Wealth manages and controls the features available in this portion of the App. The investing features in the App allow users to buy a limited universe of stocks and exchange-traded funds (“ETFs”) using credit card reward points instead of cash. By offering this service, X1 Wealth provides clients an alternative method to investing in fractional shares of publicly traded companies and ETFs. X1 Wealth considers a client’s investment objective when recommending individual stocks and ETFs to purchase. A client’s investment objective is determined using a risk profile questionnaire that must be completed for each account before making any investments through the App. Based on these responses, we will place the client into an appropriate risk category. Although we review client risk profiles before recommending investments, we do not guarantee nor ensure the success of any of the recommended investments. We rely on the individual responses to the risk profile questions to provide investment recommendations to our clients. Clients must provide accurate, complete, and truthful answers to the risk profile questions. X1 Wealth does not have discretion over Client trades and Clients can choose to use the App to trade certain individual equities and ETFs that were not recommended based on their risk profile. We monitor our Clients’ account holdings against each individual Client’s risk profile and on a quarterly basis will provide trade recommendations to clients whose holdings are out of line with their risk profile. Additionally, we evaluate our recommendations for Clients on at least a monthly basis, and advise our Clients when those recommendations have changed. We also advise Clients as to whether individual equities or ETFs that we have evaluated are within the Client’s risk profile. From time to time, we may provide additional investment advice in the form of educational material or specific buy or sell recommendations that arise due to changing market conditions. X1 Wealth engages DriveWealth, LLC (“DriveWealth”), an SEC registered broker-dealer and member of FINRA, to provide execution and clearing services to its clients. All client trades, including buying or selling a select universe of investments that were not recommended and were selected by the client, are placed through DriveWealth. Clients can only access our investment advisory services through the App; however, clients can use other areas of the App for non- investment advisory services that are provided and managed by our Parent Company. X1 Wealth does not offer any legal or tax advice with respect to its investment recommendations, and accordingly, the Adviser strongly urges individuals to work with their attorneys, accountants, or other professionals regarding their financial and personal situations. Investments in ETFs, equities, and other types of securities are not insured by the Federal Deposit Insurance Corporation or by any other federal government agency. ETFs and equities are not deposits or other obligations of, or guaranteed by, X1 Wealth or any affiliate. Investments may lose value, including possible loss of principal. X1 Wealth LLC, a Delaware limited liability company and wholly owned subsidiary of X1 Inc, was founded in 2022. The Adviser’s principal place of business is in San Francisco, California. Fees and Compensation X1 Wealth does not directly bill Clients for the investment advisory services we provide. Rather, our Parent Company will compensate X1 Wealth for the investment advisory services X1 Wealth provides to clients who are X1 Cardholders. X1 Cardholders are not charged any additional fees for becoming X1 Wealth clients and receiving X1 Wealth’s investment advisory services. In the X1 Wealth Wrap Program, the fee paid by the Parent Company to X1 Wealth on behalf of our mutual clients is a single advisory fee that covers both investment advice and the execution of transactions. The Parent Company currently pays X1 Wealth an annual wrap fee of $0.10 for each account that X1 Wealth provides its investment advisory services. Neither X1 Wealth nor our Parent Company receives any compensation that is tied to the transactions that take place in a Client’s account. Our Parent

Company is not an investment adviser and does not receive any compensation related to the investment advice provided by X1 Wealth. At no time will the wrap fee be charged to clients of X1 Wealth. Additional Fees Clients are responsible for some additional fees that may be charged by DriveWealth. These fees are called Pass-through Fees, and they are: an SEC fee (sell side only), TAF Fee (sell side), and ADR Fee. DriveWealth may also charge other fees (different from the Pass-through Fees) for providing additional services to Clients. Clients will pay those other fees directly to DriveWealth. Other fees may include fees for transferring a brokerage account from DriveWealth to another brokerage firm, charges for miscellaneous requests such as requesting a physical copy of a trade confirmation or requesting a tax document to be faxed or sent by regular mail, as well as charges for withdrawal or other administrative requests, such as ACH transfers (outgoing) and wire transfers. To learn more about the different fees that could be charged to Clients, please see the fee disclosures DriveWealth provides upon opening a brokerage account with them. Clients who invest in ETFs may also indirectly pay management fees or other expenses to the purchased ETF. ETFs pay their own management, transaction, and administrative fees and expenses, and those fees and expenses are indirectly borne by the shareholders in those investment vehicles. Depending on the activities or services (e.g., transferring an account to another broker, requesting physical copy of a trade confirm, and so on), the broker could also charge you other fees. These additional fees are deducted directly by the ETF and reflected in its net asset value. DriveWealth does not allow clients to maintain accounts directly with DriveWealth. In the event that your X1 credit card account is closed, you may choose to hold, liquidate, or transfer the investments in your X1 Wealth account. If you choose to liquidate, the proceeds will be transferred to your connected bank account. Any fees that a connected bank account charges will be borne by you. If you choose to transfer the investments and assuming that transfer instructions are received in good order by DriveWealth, the transfer will occur within 30 business days. Clients can only transfer whole shares to other brokerages; fractional shares must be liquidated. Any fees charged by DriveWealth or the receiving institution in connection with a transfer will be borne by you. Other Important Considerations ▪ The investment products available for purchase with X1 Wealth can generally be purchased by you outside of your X1 Wealth account, through broker-dealers or other investment firms not affiliated with our Parent Company. ▪ Because you will pay to purchase equity securities and ETFs based on a point-to-dollar value conversion of your X1 Card credit card points, the percentage of a share that you will receive for those points is highly variable. Because the point value is static while the value of equity securities and ETFs fluctuates, the fraction of a share that a point will purchase in each transaction will vary. Details on our point conversion rates can be found below: X1 Rewards Points Conversion Rate Cash Value 1 $0.007 $0.007 1,000 $0.007 $7.00 10,000 $0.007 $70.00 ▪ As an X1 Cardholder, you receive a more favorable point conversion rate of $0.01 per point when you redeem your points for credit with eligible merchants. This is because our Parent Company fully bears the cost of point redemptions, and through business partnerships with its selected merchants, is able to work with that merchant and attempt to negotiate more favorable rates. When points are redeemed for cash back options, the conversion rate is lower because our Parent Company bears the full cost associated with these redemptions and is unable to pass any of the cost on to its merchant partners. Our Parent Company offers its clients the same conversion rate for equity and ETF purchases through X1 Wealth as it offers for its cash back program. Since our Parent Company must also pay the wrap fee to us when cardholders choose to redeem their points for investments rather than for cash back, our Parent Company has no financial incentive to encourage clients to invest with X1 Wealth over the cash back program. X1 Wealth has no control over the point conversion rates that are set by our Parent Company and X1 Wealth does not receive any benefit nor cost savings tied to the different conversion rates that our Parent Company offers to its cardholders.