Description of the Firm SocialTrader.ai Inc. is a California domiciled Delaware limited liability company formed in March of 2023. We operate under the trade name SocialTrader. Our firm is not a subsidiary of, nor does it control, another financial services industry entity. Alfonso Rodriguez-Arana serves as our Chief Executive Officer and Chief Compliance Officer and maintains controlling interest in the firm. Description of Advisory Services Interested parties must access our secure online application where they are offered our current firm brochure and Customer Relationship Summary (Form ADV Part 2A and Form CRS, respectively) that describes our advisory firm, its services, fees, etc., as well as any material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and objective advice. The firm’s brochure, customer relationship summary, and privacy policy statement are available online to our clients/prospective clients in either portable document format (PDF) for their download and/or may be printed on their own local printer. If the prospective client wishes to then engage SocialTrader for its services, they must first enter into a written, electronically delivered agreement with our firm to initiate the process. We ask clients to respond to interactive questions we believe are important to the design of their customized investment portfolio, including their age, family composition, job status and employment type, investment time horizon, income, net worth, and investment knowledge or risk comfort level, among others. The accuracy of data provided by the client is important to their recommendation; however, we will not be required to verify any information received from the client and SocialTrader is expressly authorized to rely on said client thereon. Financial Plans The financial plan the client receives is oriented toward funding an education, retirement planning, and/or risk management. The financial plan is customized and provides a basic overview of the client’s situation. Clients are free to accept or reject our planning suggestions. Portfolio Management Following responses to a series of online questions, the client receives a recommendation of an investment strategy and allocation that is weighted depending on the client’s risk tolerance and investment time horizon. The recommendation will be delivered for viewing via our secure web-based, mobile application, and the client may choose to locally save, email, or print a copy for their consideration. The client is asked to provide information which assists selecting a portfolio that is appropriate for that person and comprised of national market securities (“listed securities”), such as stocks, exchange-traded funds (ETFs), mutual funds, etc. Note that SocialTrader does not take an investor’s personal tax situation into consideration when designing portfolios, and clients are encouraged to consult with a professional tax adviser prior to investing. Item 8 provides details about the range of investment strategies, investment vehicles and their associated risks. SocialTrader clients retain discretion over which portfolio model recommendation is implemented for their account. Once the client selects a suggested portfolio allocation, they will proceed through a secure account opening process and the initial portfolio will be established in line with the selected strategy. SocialTrader Page 5 of 27 systems will monitor the accounts and auto-rebalance the portfolio driven by time (e.g., semiannually, quarterly, etc.), portfolio drift, deposits, and withdrawals, or if underlying models require modification. While our firm has discretionary trading authority (see Item 16 for an explanation), it does not have the authority to remove funds or securities and may only request the withdrawal of its advisory fees as described in Item 5 of this brochure. It remains each client’s ongoing responsibility to promptly update their information within our system when there is a material change to their situation and/or investment objective for evaluating or revising previous account restrictions or portfolio recommendations. Account holdings that are not part of our recommended portfolio that the client has previously selected will not be monitored. To more appropriately manage risk and exposure, we suggest (but do not require) that the client liquidates those holdings and invests all proceeds into their selected SocialTrader strategy. There may be additional fees charged by their custodian to liquidate or transfer those securities. If the client decides to liquidate the securities, the cash from that sale may be invested in the model. Our firm does not sponsor or serve as a portfolio manager in an investment program involving wrapped (bundled) fees. We manage $400 in assets under management1 on a discretionary basis as of January 31, 2024. We provide our platform services to retirement plan sponsors and are deemed to have discretion as defined in § 3(38) of the Employee Retirement Income Security Act of 1974 (ERISA), as well as on a non-discretionary basis as defined in ERISA § 3(21). Our level of account authority is defined in Item 16 of this firm brochure. We do not serve as an ERISA § 3(16) plan third-party administrator (TPA), nor do we assist plan sponsors in identifying a TPA. Accredited Investors Interested parties who are deemed “accredited investors” preferring unique portfolio strategies may choose to engage our firm via a performance-based fee that is described in further detail in Items 5 and 6 of this brochure. Only the following who we consider to be “qualified” may be served via our performance-based

fee investment program: a bank, savings and loan association, insurance company, registered investment company, business development company, or small business investment company or rural business investment company an SEC-registered broker-dealer, SEC-or state-registered investment adviser, or exempt reporting adviser a plan established and maintained by a state, its political subdivisions, or any agency or instrumentality of a state or its political subdivisions, for the benefit of its employees, if such plan has total assets in excess of $5 million an employee benefit plan (within the meaning of the Employee Retirement Income Security Act) if a bank, insurance company, or registered investment adviser makes the investment decisions, or if the plan has total assets in excess of $5 million a tax-exempt charitable organization, corporation, limited liability corporation, or partnership with assets in excess of $5 million a director, executive officer, or general partner of the company selling the securities, or any director, executive officer, or general partner of a general partner of that company an enterprise in which all the equity owners are accredited investors 1 The term “assets under management” and rounding per the General Instructions for Part 2 of Form ADV. Page 6 of 27 an individual with a net worth or joint net worth with a spouse or spousal equivalent of at least $1 million, not including the value of his or her primary residence an individual with income exceeding $200,000 in each of the two most recent calendar years or joint income with a spouse or spousal equivalent exceeding $300,000 for those years and a reasonable expectation of the same income level in the current year or a trust with assets exceeding $5 million, not formed only to acquire the securities offered, and whose purchases are directed by a person who meets the legal standard of having sufficient knowledge and experience in financial and business matters to be capable of evaluating the merits and risks of the prospective investment an entity of a type not otherwise qualifying as accredited that own investments in excess of $5 million an individual holding in good standing any of the general securities representative license (Series 7), the investment adviser representative license (Series 65), or the private securities offerings representative license (Series 82) a knowledgeable employee, as defined in rule 3c-5(a)(4) under the Investment Company Act, of the issuer of securities where that issuer is a 3(c)(1) or 3(c)(7) private fund or a family office and its family clients if the family office has assets under management in excess of $5 million and whose prospective investments are directed by a person who has such knowledge and experience in financial and business matters that such a family office is capable of evaluating the merits and risks of the prospective investment. Subscription Services For those interested in our investment strategies but prefer to act on their own (e.g., “self-directed” investors), we offer our online subscription service where our customizable research tools generate digitized reports for clients’ personal use. Retirement Plan Advice and Rollovers As a registered investment adviser, our firm is a fiduciary to every client, meaning that we are obligated to act in our clients’ best interest at all times. In addition to our fiduciary status as an investment advisory firm, when our firm provides advice to retirement investors, such as advice about an employer-sponsored retirement plan, individual retirement account (IRA) or other qualified retirement plan, we may also be considered by the US Department of Labor and the Internal Revenue Service to be acting as a fiduciary under ERISA and the Internal Revenue Code. 2 These fiduciary obligations include requirements that we disclose our services and fees, conflicts of interest, and the reasons our recommendations are in the client’s best interests. After an analysis of the client’s situation and their retirement plan documents, our platform will consider relevant factors including but not limited to the following: alternatives to rolling the employer plan to an IRA, including leaving the money in an employer’s retirement plan (if permitted); rolling the money to a new employer plan if available; or cashing out fees and expenses associated with both the employer’s plan and the rollover IRA (or other alternatives such as noted above) and whether the employer currently pays for some or all plan expenses different levels of services and investments available under the employer plan and the rollover IRA, and other alternatives whether the rollover is appropriate in light of any additional costs and the resultant decrease in the client’s return 2 This Form ADV Part 2A firm brochure serves as our ERISA §408(b)(2) disclosure. Page 7 of 27 treatment of withdrawals under each alternative (e.g., penalties up to age 55 vs. 59½ years old) protection from creditors and legal judgments (unlimited vs. bankruptcy only; federal- and state- specific) required minimum distributions tax implications of rolling shares of employer stock, and impact of economically significant investment features such as surrender schedules and index annuity cap and participation rates (e.g., an employer-sponsored § 403(b) plan account). The affected client will be made aware of conflicts of interest including but not limited to whether our firm will profit from a recommendation through financial planning fees, and whether services we offer are already provided by or available through the current plan, potentially at no additional cost.