A. General description of the firm Frec Advisers is an SEC-registered investment adviser providing clients software-based advisory and portfolio management services through a web-based platform, "the Frec platform." Frec Advisers does not provide investment advice in person, over the phone, or in any manner other than through the Frec platform. Frec Advisers is a limited liability company formed under the laws of the state of Delaware in March 2023. It is principally owned by Mohammad Al Adham through his ownership of Frec Markets. Inc. Frec Advisers offers automated discretionary investment advisory services to clients of its affiliate, Frec Securities LLC (“Frec Securities”). Specifically, Frec Advisers offers US direct indexing, tax-loss harvesting, hedging strategies, and cash management services to Frec Securities brokerage retail individual and entity clients through the Frec platform. Each client of Frec Securities opens a margin brokerage account and is offered the opportunity to enroll in the Firm’s services. All clients of Frec Advisers must first become a client of Frec Securities to use its services. We encourage you to visit our website www.frec.com for additional information about Frec Advisers and the Frec platform. To enter into an advisory relationship, a client is required to agree to an investment advisory agreement with Frec Advisers (“Investment Advisory Agreement”), which discusses the services the client will receive, the fees charged to the client (as applicable), and the conditions of the client’s relationship with Frec Advisers. The Firm’s advisory relationship with a client begins upon the effective date of the Investment Advisory Agreement with a client. Any preliminary information provided to a client before the Firm accepts the Investment Advisory Agreement does not constitute investment advice under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and should not be relied on as such. B. Summary of Frec Advisers’ advisory services Frec Advisers’ services are exclusively provided through the Frec platform, which is an online web and mobile platform. The Firm offers clients tax-loss harvesting, automatic direct index investing, and hedging protection. The Firm also offers cash management services to its Clients. Clients will have the choice of participating in either full discretionary authority permitting the Firm to manage the client’s assets and effect transactions for their assets without their prior approval or consent. Alternatively, the client may authorize limited discretionary authority, whereby clients retain authority to select particular securities to be held in their portfolios, but authorize the Firm to effect transactions for their assets for certain purposes (i.e., tax-loss harvesting and hedging) without their prior approval or consent. Frec will offer tax-loss harvesting (“TLH”) strategies for clients that grant full discretionary authority. The TLH strategy is designed to assist in lowering a client’s taxes while maintaining the expected portfolio investing strategies. TLH harvests previously unrecognized investment losses to offset taxes due on a client’s portfolio gains and income by selling securities in their portfolio at a loss to accelerate the realization of capital loss and investing the proceeds in securities with closely correlated risk and return characteristics or in securities that align with the client’s portfolio and do not cause a wash sale. The client’s realized loss can be applied to lower

their tax liability and the tax savings can be reinvested to grow the value of their portfolio. Frec intends to offer TLH within its US Direct Indexing portfolio investment strategies. Frec’s US Direct Indexing strategies invest in underlying securities of the S&P index and invest in underlying securities that replicate the index while permitting certain personalization by investors, such as removing companies not aligned with their interests. Clients will also have the ability to purchase Frec’s hedging product to protect his or her account from significant loss for a specific duration of time. The Firm separately offers a cash management strategy to its Clients. This strategy invests cash into certain money market funds based on the Client’s needs. This offering is separate from Frec’s TLH and US Direct Indexing portfolio investment strategies. Finally, the Firm separately offers a tax basis monitoring service to its Clients, whereby the Firm monitors the tax basis of specific securities that Clients designate to the service (self- directed securities transferred into or otherwise held in Clients’ accounts) and, pursuant to the Firm’s discretionary authority, sells securities that are at a tax loss for the specific percentage specified by the Client. Thereafter, the Firm invests the proceeds within the Client’s US Direct Indexing portfolio. The Firm’s monitoring is generally limited to the tax basis of the securities; except as otherwise agreed with Clients in writing, the Firm does monitor other information about the securities designated to it as part of this service. C. Tailored services and investment restrictions Frec Advisers tailors its software-based investment advisory services to the individual needs of each client. The Firm gathers information about a client when the client signs up for Frec Adviser’s services by having the client complete a client profile ("Client Profile") designed to determine the client’s financial situation, level of financial sophistication, investment experience, and financial goals. Such financial information includes your risk tolerance, investing interests, and length of time you expect to hold your investments, Based on the client’s responses to the Client Profile and other demographic information the client has provided to Frec Advisers or Frec Securities, Frec Advisers will provide a specific recommendation for their portfolio allocation and spending. Frec Advisers clients still have control of their portfolios and can make adjustments to the Firm’s recommendations at any time. Clients can still trade individual securities on the platform outside of the TLH and Direct Index and cash management offerings. Additionally, clients will be permitted to exclude certain securities from the direct indexing strategies, such as securities that do not offer dividends. D. Wrap Fee Programs Wrap fee programs are arrangements between broker-dealers, investment advisors, banks and other financial institutions and affiliated and unaffiliated investment advisors through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. The Firm does not participate in and is not a sponsor of wrap fee programs. Any fee that a client is required to pay will be charged in the client's account. E. Assets Under Management As of the date of this Brochure, the Firm does not have any assets under management.