Bluevine Advisory is an SEC registered investment adviser offering automated, web-based advisory services to corporations and other business entities (each a “Client,” and collectively, “Clients”) through a website and mobile application (“the Platform”). Bluevine Advisory provides investment advice to Clients through a software application that is available in the Platform. The Firm does not provide investment advice in person, over the phone, in live chat, or in any manner other than through the Platform. Bluevine Advisory was formed in March 2023 and is wholly owned by Bluevine Inc. As of the date of this Brochure, the Firm had approximately $651,747 in assets under management, all of which it manages on a non-discretionary basis. Bluevine Advisory recommends and manages portfolios containing high-interest, liquid cash alternatives. The portfolios will consist of one or more of the following asset types: fixed income (debt) securities, commercial bonds, certificates of deposits, and mutual funds and exchange traded funds (ETFs) that invest in the foregoing. Clients select a portfolio based on the Firm’s recommendations, which the Firm implements, then manages on a limited discretionary basis. Specifically, the Firm has the authority to buy, sell, and otherwise effect investment transactions for a Client’s funds and securities without the Client’s prior consent or approval to rebalance the portfolio on a periodic basis and based on deposits to the Client Account. Bluevine Advisory monitors Client Accounts on an ongoing basis, and recommends changes, as appropriate. The Firm recommends securities that are consistent with each Client’s investment needs and objectives, based upon information the Client submits via one

or more questionnaires (together, the “Client Profile”). The Client Profile confirms, among other information, the Client’s investment objectives and risk tolerance (together, “Investment Needs”). Bluevine Advisory does not verify the information it receives from Clients or their agent(s) in their Client Profile for accuracy, and it will rely on the information Clients provide therein. It is each Client’s responsibility to promptly update its Client Profile in the event of a change. The Firm manages the Client’s portfolio in a securities brokerage account (“Client Account”) established by the Client at a to-be determined custodian and broker-dealer (“Custodian”), an unaffiliated SEC-registered broker-dealer and Financial Industry Regulatory Authority (“FINRA”) member, which provides brokerage related services to Bluevine Advisory and its Clients. The Custodian provides custody, clearing, and settlement services for transactions effected by Bluevine Advisory in Client Accounts. The investments of each Client are held in a separate Client Account in the name of the Client at Custodian, and not with Bluevine Advisory. Clients open Client Accounts at Custodian via the application program interface (“API”) in the Platform. Bluevine Advisory’s services do not include comprehensive financial or tax planning or legal advice, and Clients are advised to seek the advice and counsel of the Client’s own tax, financial, and legal advisers. Furthermore, neither Bluevine Advisory nor any of its affiliates is responsible for withholding any tax penalties that may apply to Client Accounts or for any state or federal income tax withholding, except as may otherwise be required by applicable law. The Firm does not participate in wrap fee programs.