This Disclosure Brochure describes the business of Adaptive. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Adaptive’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on Adaptive’s behalf and is subject to Adaptive’s supervision or control. Investment Management Services Adaptive Advisers, LLC (“Adaptive” or the “firm”) is an internet-based investment advisory firm headquartered in Boston, MA. Adaptive provides advisory services through its website using algorithmic technology developed by Adaptive Investment Solutions, LLC (“AIS”) a fintech affiliate of Adaptive and licensed to Adaptive (the “Licensed Technology”). Clients of Adaptive may import and store their securities portfolio information using Adaptive’s website. Based on that information, Adaptive will calculate a risk score for the portfolio based on the historical measure of volatility of the securities contained in the portfolio. Adaptive will also allow the Client to compare his or her portfolio risk with the level of risk in the marketplace. In addition, based on the input from the Client and using the Licensed Technology, Adaptive will project what it believes are likely ranges of future values of the portfolio and provide certain analyses and recommendations including: ● Portfolio risk analysis and forecasting ● Recommendations on option strategies to minimize risk ● Forecasting on option strategies to mitigate risk ● Backtesting of option strategies ● Actions that the Client may choose to take to implement strategy or mitigate risk These services are provided to Clients free of charge. Further, based on the Client’s securities portfolio and risk tolerance, Adaptive will provide the ability for Clients to protect against losses in their securities portfolios for a period of time by purchasing such protection from Adaptive’s affiliate, Adaptive Capital Management, LLC (“ACM”). ACM provides multiple downside risk management

products which offer to protect a securities portfolio against specified losses for a specified period of time. In the event that the value of the securities portfolio falls below the specified protection level during the period covered, ACM will pay the Client the difference between the actual value and the specified protection level. Adaptive is compensated by ACM each time a Client purchases downside protection and provides advice to ACM with respect thereto using the Licensed Technology. All clients are required to enter into one or more written (online) advisory agreements with Adaptive setting forth the terms and conditions under which Adaptive renders its services (collectively the “Agreement”). Adaptive’s Clients are those Clients who access Adaptive’s analysis through its website, enter into an Agreement with Adaptive and/or thereafter purchase the downside protection product from ACM. Any purchase of a downside risk management product will be made by a Client with direct payment to ACM by a link on Adaptive’s website. Pricing for the downside risk management product is determined solely by ACM based on the securities portfolio to be protected, and the scope and duration of protection sought. More information on the pricing/fee can be found in Item 5 Fees, below. Founded by Dazhen “Philip” Sun, Nathaniel Wice and Jonathan Wells as co-owners and Managers, the firm has been in business since 2022. The firm registered as an internet-only investment adviser with the Securities Exchange Commission in 2022. As of the filing of this Disclosure Brochure, Adaptive currently manages zero dollars ($0) of Client assets on a discretionary basis and zero dollars ($0) of Client assets on a non-discretionary basis, as further described below. The firm does not provide continuous and regular investment management services on a discretionary or a non- discretionary basis, but rather provides the investment advisory services set forth above. Adaptive does provide discretionary advisory services to ACM with respect to the downside risk management product. Adaptive does not participate in wrap fee programs.