DESCRIPTION OF THE ADVISORY FIRM Portfolio Design Labs, LLC (hereinafter, with its subsidiaries, “Portfolio Labs”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in November 2021 and the principal owner is Jason Thomas. PORTFOLIO MANAGEMENT SERVICES – PARTNER ADVISORY FIRM CLIENTS Portfolio Labs offers investment advisory services, primarily to individuals through third-party investment adviser firms (referred to in this brochure as “Third Party Advisory Firms” or “TPAFs” and their client advisor representatives are referred to as “Third Party Financial Advisors” or “TPFAs”). The Fee schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimum schedule located at the end of this Brochure. TPFAs consult with their clients (“TP Clients”) to assess the TP Clients’ financial situation and identify investment objectives in order to identify investment solutions (“Solutions”) designed to meet the TP Client’s financial needs. In order to engage Portfolio Labs, the TP Client will enter into an Investment Management Contract (“IMC”) that outlines the services to be performed by Portfolio Labs. Portfolio Labs requires discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. The TPFA is responsible for determining the suitability of various investment solutions (“Solutions”) for the TP Client’s investment objectives and financial condition. Through its TPFA, the TPAF, not Portfolio Labs, recommends the Solution to the TP Client and monitors whether to recommend that the TP Client remain in the selected Solution. As described below, each of the Solutions uses one or more Investment Approaches (the “Investment Approaches”) in an attempt to achieve Investment Objectives (“Investment Objectives”) as described below. The TPFA and TP Client can customize a strategy by which each of the TP Client’s accounts will be managed or maintained. The specific Solution Type and the Investment Approaches selected for the Client’s Account(s) are referred to as the TP Client’s “Investment Strategy.” A TP Client will establish one or more investment accounts (each an “Account”) with a custodian, and the TP Client’s Accounts are collectively referred to as the TP Client’s “Investment Portfolio.” A TP Client will typically complete a questionnaire, or otherwise provide information to the TPFA to enable the TP Client and the TPFA to identify the TP Client’s rate of return objective, risk tolerance and other relevant information. The TP Client typically will provide the TPFA with information concerning the Client’s investment experience, anticipated need for liquidity, potential timing of the need for retirement funds, and other investment needs and parameters. The TPFA remains responsible for monitoring the Investment Strategy and recommending any changes to the TP Client. Portfolio Labs’ responsibility is to implement the Investment Strategy chosen by the TP Client and the TPFA. Portfolio Labs does not advise the TP Client about potential changes to the TP Client’s Strategy. For TP Clients of TPAFs, Portfolio Labs offers three Solutions, each implemented by a division of Portfolio Labs (Dynamic Wealth Management; Thematic Capital Management; and Direct Index Strategies) focused on Investment Solutions based on a particular Investment Approach. Dynamic Wealth Management Dynamic Wealth Management (“DWM”), a division of Portfolio Labs, offers an innovative, holistic, dynamic portfolio management service based on the individual goals, objectives, time horizon, and risk tolerance of each TP Client. The Dynamic Outcome Target Strategy (“DOTS”) offered by DWM is a customizable Investment Solution designed to be used in conjunction with a financial plan. The DOTS Investment Solution attempts to achieve a target rate of return, specified by the TPFA, over the time horizon of the financial plan (10 years or more) with the least amount of volatility. There can be no guarantee that any Investment Solution’s objectives will be achieved. All Investment Solutions involve the risk of investment loss. Thematic Capital Management Thematic Capital Management (“TCM”), a division of Portfolio Labs, offers focused thematic- and style-based separately managed accounts (“SMAs”) that can be used on a stand-alone basis Portfolio Labs Disclosure Brochure Page 7 of 21 or combined into a single unified managed account (“UMA”). Thematic investing is an approach that focuses on predicted trends rather than specific companies or sectors, enabling investors to efficiently pursue returns associated with structural shifts that can affect entire industries and economies. There can be no guarantee that any Investment Solution’s objectives will be achieved. All Investment Solutions involve the risk of investment loss. Direct Index Strategies Direct Index Strategies (“DIS”), a division of Portfolio Labs, offers portfolios of individual equites managed in a manner similar to popular funds and ETFs. DIS portfolios are available only as SMAs; multiple Investment Strategies cannot be combined in a UMA. Direct index investing is an approach which attempts to improve upon the overall client experience of investing in a commingled vehicle through the use of individual securities and sophisticated portfolio construction techniques. Potential benefits include increased tax efficiency, greater precision of investment allocation, and/or lower cost. There can be no guarantee that any Investment Solution’s objectives will be achieved. All Investment Solutions involve the risk of investment loss. PORTFOLIO MANAGEMENT SERVICES – DIRECT CLIENTS In select circumstances, Portfolio Labs may offer investment advisory services to an individual or institution directly (a “Direct Client”), with no intervening TPFA. The Fee schedules and fee rates for the various Investment Solutions are listed in the Fees & Investment Minimum schedule located at the end of this Brochure. In that case, Portfolio Labs will consult with the Direct Client about Investment Objectives in order to identify an appropriate Investment Solution. Portfolio Labs creates an Investment Policy Statement (“IPS”) for each client that outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. In order to engage Portfolio Labs, the Direct Client will enter into an IMC that outlines the services to be performed by Portfolio Labs. Portfolio Labs requires discretionary authority

from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each Direct Client. For Direct Clients, Portfolio Labs offers Investment Solutions from Thematic Capital Management and Direct Index Strategies, as described above. ADDITIONAL INFORMATION ABOUT PORTFOLIO MANAGEMENT SERVICES With respect to services offered to TP Clients and Direct Clients (together “Clients”), Portfolio Labs seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its Clients and without consideration of Portfolio Labs’ economic, investment or other financial interests. To meet its fiduciary obligations, Portfolio Labs attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Portfolio Labs’ policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Portfolio Labs’ policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Account Implementation Each Investment Solutions offered by Portfolio Labs has a minimum investment amount (“Account Minimum”). The Account Minimum for each Investment Solution is listed in the Fees & Investment Minimum schedule located at the end of this Brochure. A Client must deposit the Account Minimum into their Account, and if multiple deposits are made into such an Account, the Account will not be invested and will not be considered a managed Account until the Account balance reaches the required minimum. A Client’s Account will be held by the Custodian in cash or in the assets transferred in-kind until such time as the value of the deposits to the Account reaches the required minimum for investment. Clients should be aware that a reasonable amount of time will be needed to purchase, redeem and/or transfer assets, and Portfolio Labs will not be held liable for losses or missed gains due to market value fluctuations during the time taken for these transactions. Portfolio Labs Disclosure Brochure Page 8 of 21 Account Liquidity Reserve To properly maintain cash flows for Client needs, a portion of all Client Accounts invested in a Strategy is maintained in a short-term investment vehicle. This liquidity reserve or cash allocation is typically 2% and may be invested by Portfolio Labs in what is generally referred to as the Custodian’s cash “sweep” vehicle or a money market mutual fund or other short-term pooled investment vehicle. Services Limited to Specific Types of Investments Portfolio Labs generally limits its investment advice to equities, fixed income securities, mutual funds and ETFs. Portfolio Labs may use other types of securities as well to help diversify a portfolio when applicable. Short-Selling Portfolio Labs recommends that, where available, allowed and appropriate, Clients establish Accounts allowing the short sale of equity securities. Clients permit Portfolio Labs to sell securities short via an Addendum to the IMC. Use of Borrowing Portfolio Labs recommends that, where available, allowed and appropriate, Clients establish Accounts with some form of flexible borrowing capacity (e.g., margin, asset-backed line of credit, etc.). Clients permit Portfolio Labs to use borrowing on a tactical (short-term) basis via an Addendum to the IMC. The discretionary, short-term use of such borrowing by Portfolio Labs may have a number of benefits by separating (i) the timing of the Clients’ need for a cash distribution from an Account or expected contribution to an Account from (ii) the sale or purchase of securities. Clients may also establish a strategic (long-term) borrowing in an attempt to increase long-term returns. Clients permit Portfolio Labs to use borrowing on a strategic (long-term) basis via an Addendum to the IMC. The use of borrowing related to an Account is not suitable for all Clients. Securities-backed borrowing involves a number of risks, including the risk of a market downturn, tax implications if pledged securities are liquidated, and the potential increase in interest rates, and other risks. If the value of pledged securities drops below certain levels, the borrower can be required to pay down the loan and/or pledge additional securities. Clients must consider these risks and whether securities-backed borrowing is appropriate. Clients should consider these issues and discuss with their TPFA their financial position and objectives and whether using their investments as collateral for a loan is appropriate. Options Portfolio Labs recommends that, where available, allowed and appropriate, Clients establish Accounts allowing the purchase and sale of equity options. Clients permit Portfolio Labs to use options via an Addendum to the IMC. The use of options is not suitable for all Clients. Options investing involves a number of risks, including the risk of a market downturn, reduced liquidity relative to equity securities and tax implications. Clients must consider these risks and whether options investing is appropriate. Clients should consider these issues and discuss with their TPFA their financial position and objectives and whether using options is appropriate. CLIENT TAILORED SERVICES AND CLIENT- IMPOSED RESTRICTIONS Clients may request that Portfolio Labs customize an Investment Solution via an Addendum the IMC. Portfolio Labs may use security-specific analysis and/or model allocations together with a specific set of recommendations for each client based on his/her personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Portfolio Labs from properly servicing the client account, or if the restrictions would require Portfolio Labs to deviate from its standard suite of services, Portfolio Labs reserves the right to reject the request or end the investment relationship. WRAP FEE PROGRAMS A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. Portfolio Labs does not participate in wrap fee programs. ASSETS UNDER MANAGEMENT Portfolio Labs was established in November 2021 and had the following assets under management as of December 31, 2023: Discretionary Amounts: Non-discretionary Amounts: $276,199,398 $0 Portfolio Labs Disclosure Brochure Page 9 of 21