Plenty Financial RIA, LLC. (hereinafter “Plenty,” “we,” “us,” “our” or the “Firm”) is organized as a Delaware limited liability company with a principal place of business in San Francisco, CA. Plenty is principally owned by Plenty Financial, Inc. which is principally owned by Emily Luk and Christopher Allen. Plenty was founded to democratize access to financial products and tools that accelerate wealth building. Plenty Financial, Inc. provides an interactive web‐based personal financial management and educational platform to consumers through a fee‐based subscription. Wholly owned subsidiary Plenty Financial RIA, LLC leverages industry‐leading technology to provide advisory services (“Advisory Services” or “Services”) in the form of software‐first financial planning and investment advisory services for Subscribers (“Subscribers” or “Clients”). Our investment advice guidelines are discretionary and available to our Subscribers via ongoing fee‐based subscription. Program Description This Wrap Fee Program Brochure is provided to help Clients understand the nature of the services offered by the Firm, whether the services offered by Plenty are right for the Client, and the potential conflicts of interest associated with the Client’s participation in the Plenty Wrap Fee Program. Clients should review this Wrap Fee Program Brochure carefully. The discretionary investment management services are offered through a wrap fee program (the “Plenty Wrap Fee Program”) described herein. Plenty Financial, Inc. provides interactive educational financial planning tools to help individuals and couples create their own goals‐based financial plan and understand their cashflow. Plenty collects information about a Client’s age, family, financial condition, employment status, investment goals/objectives, time horizon, and risk tolerance exclusively through an interactive website. Clients are then guided through estimates of their financial goals and given the ability to use an interactive tool to understand the impact of different saving and investment plans for each of their goals. Once an individual has made a decision to move forward with a given plan, Plenty provides investment recommendations including money‐market funds or an algorithm‐generated stock/bond portfolio provided by its subadvisor. Typically, individual stocks or domestic exchange traded funds (“ETFs”) are utilized for domestic equity exposure and ETFs are utilized for international equity and treasury/bond exposure. This asset mix also may vary depending on the type of account a Client is using to invest (individual, joint, retirement, etc.). Client’s investment objectives, financial profile, and risk tolerance impact the options Clients are initially shown, though a Client may override recommendations at any point and select their own risk tolerance-based allocation for Plenty to implement. Once a Client decides to move forward, the investment accounts are managed by the subadvisor. Client accounts will have the ability to make reasonable restrictions for their account and the subadvisor’s software will monitor Clients’ accounts on an ongoing basis and periodically rebalance as changes in market conditions, additions, or withdrawals in the Client account and or a change in Client’s financial circumstances occurs. In general, wrap fee programs allow Clients to pay a single fee (the “Wrap Fee”) which covers advisory fees (including subadvisory fees), trading commissions, fees for brokerage, and other administrative and advisory services provided by an investment adviser, broker, and/or the custodian. Clients are generally not charged separate fees for each component of the total services. Because wrap fee program advisers typically absorb Client transaction fees, an incentive exists to limit trading activities in the wrap fee account. Depending on the wrap fee account, Clients may also pay more for using a wrap fee program than they would for using non‐wrap fee program services. Types of Advisory Services and Investment Strategy Plenty provides interactive web‐based financial planning and educational tools that allow individuals to visually see the impact of different investing and savings plans. Clients are given options between money market funds or stock and bond portfolios (sometimes represented by ETFs), and the ability to see the impact on risk and return. These stock and bond portfolio recommendations are made through the subadvisor’s proprietary algorithmic‐based technology to provide discretionary asset management services through a web application. A Client may update his or her risk profile at any time by updating the risk responses accessible through a Client’s account online. Clients also are able to set their

risk tolerance on a goal-by-goal basis. Client assets are used to purchase the securities that align to the Client’s corresponding target asset allocation within the recommended portfolio or Client selected portfolio. Investment services provided by Plenty and its sub-advisory partner are designed to encourage higher rates of saving and investing in non‐retirement and retirement accounts. At user onboarding, individual Clients undergo a financial situation review and risk assessment. Clients may optionally provide values‐preferences that lead to the inclusion / exclusion of different companies or industries in their stock-based portfolios. Clients have the option to additionally create individual investment goals with unique time horizons, risk tolerance, and liquidity needs that lead to the programmatic curation of a custom investment portfolio for each goal. For all investment portfolios, Clients may choose to override the algorithm‐based portfolios. Fees and Compensation The fees applicable to Clients are set forth in detail in each investment advisory agreement. A brief summary of such fees is provided below. Advisory Fees Plenty’s Clients pay a combination of: a) Subscription fee (“Subscription Fee”) to Plenty Financial, Inc. for non-advisory services including financial wellness and educational content. b) Wrap Fee based on amount of Assets under Management (“AUM”) in your account for the advisory services described in this Item 4. The Subscription Fee is $100 annually per Client. The asset‐based wrap fees are 0.20% of AUM and is billed in arrears and based on the Client’s average daily balance in the prior month. The Subscription Fee provides access to the personal financial management tools and financial educational tools and is collected by Plenty Financial, Inc. The wrap fee is collected by Plenty Financial RIA's subadvisor, Atomic Invest LLC. The wrap fee is based on the amount of assets in your account. As a general matter, the more money you invest with us the more fees you will pay; therefore, we have an incentive to encourage you to increase your assets in your account. The annual wrap fee includes investment advisory and subadvisory services (portfolio construction, rebalancing, and automated tax‐loss harvesting)1, custody services and brokerage commissions, and therefore may be higher than a typical asset‐based advisory fee that does not include the additional services described. Plenty reserves the right to waive or modify the Subscription Fee and/or the Wrap Fee for any Client, at its sole discretion. Other Types of Fees or Expenses The Firm is responsible for and shall pay, or cause to be paid, all of their own ordinary administrative and overhead expenses, including, without limitation, all costs and expenses related to rent, furniture, fixtures, equipment, office supplies, clerical expenses and all salaries, bonuses and benefits paid to, or on behalf of, personnel of the Firm. Neither the Firm nor its employees accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products. Plenty may charge additional fees to Clients for specifically requested services or irregular occurrences that are not included in the wrap fee program. [All such fees are outlined in the Advisory Agreement]. Personal Financial Management and Education Platform: Plenty Financial, Inc. provides an interactive financial planning and educational web platform to Clients to link their external accounts and see their financial lives in a single place. The tools enable individuals to explore potential future financial scenarios including having children, retirement, getting married, college funding and purchasing a home, and provide investment related services (provided through Plenty Financial RIA and its subadvisor) for reaching their goals. The software‐first experience enables individuals to forego a traditional interview‐based onboarding experience. Clients are empowered with the tools to understand the financial consequences of different decisions, and given the ability to create their own plans to reach their financial goals. Clients choose to implement decisions entirely at their own discretion, and should consult with tax or financial advisors if there are additional personal circumstances that are not captured by Plenty’s platform. While the data used in financial models is believed to be reliable, Plenty cannot ensure the accuracy or completeness of data provided by third parties (including the subadvisor) or Client s.