FINIAT, LLC (“FINIAT”, the “Firm” or the “Adviser”), a is a privately held limited liability company organized under the laws of Florida. FINIAT, as of January 26, 2024, is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC” or “the Commission”). Robert L. Bandy is the founder, owner, Chief Executive Officer (“CEO”) and Chief Investment Officer (“CIO”) of FINIAT. As a SEC-registered investment adviser (or “RIA”), FINIAT is subject to governance by the Commission under all other applicable regulations promulgated under the Investment Advisers Act of 1940 (“Advisers Act”) and is also subject to other federal securities laws, including applicable provisions under the Investment Company Act of 1940, as well as certain state regulations. FINIAT’s registration with the SEC is made pursuant to Rule 203A-2(e) of the Investment Advisers Act of 1940 (“Advisers Act”), or what is commonly known as “the Internet Adviser Exemption.” Under the Internet Adviser Exemption, FINIAT is required to and does perform its proprietary advisory services on behalf of its clients (each a “FINIAT client” and collectively “FINIAT clients”) through an operational interactive website. The term “operational interactive website” means a website or mobile application through which the investment adviser provides digital investment advisory services on an ongoing basis to more than one client (except during temporary technological outages of a de minimis duration)). Further, the term “digital investment advisory service” is defined as investment advice to clients that is generated by the operational interactive website’s software-based models, algorithms, or applications based on personal information each client supplies through the operational interactive website. In accordance with the Interactive Adviser Exemption, FINIAT operates an operational interactive website for which it exclusively furnishes advisory services on behalf of its clients. As of date of this Brochure, FINIAT does not manage any regulatory assets under management (“RAUM”) on a discretionary or non-discretionary basis. Our Firm also does not provide continuous oversight of portfolios for which we render advisory services. FINIAT provides advisory services exclusively for institutional clients, namely RIAs or Turnkey Asset Management Programs (“TAMPs”), through our Firm’s operational interactive website under the terms of a written investment advisory consulting agreement. In this regard, the FINIAT Client is solely responsible for trade execution as FINIAT does not offer that service. RIAs that are not direct clients of FINIAT may otherwise obtain our Firm’s advisory services indirectly upon entering into a separate agreement with an RIA or TAMP that has an existing contractual arrangement with our Firm. In these circumstances, FINIAT does not maintain a direct relationship or agreement with the customers of FINIAT Clients. Access to our Firm’s portfolio models and ongoing allocations, however, is made accessible to customers of FINIAT Clients through the standing agreement between FINIAT and its Client (e.g., RIA or TAMP). The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this Brochure, the words "we," "our," and "us" refer to FINIAT and the words "you," "your," and "Client" refer to you as either a client or prospective client of our Firm. Portfolio Management Services & Types of Investments 5 | P a g e FINIAT Direct FINIAT offers advisory services exclusively through our Firm’s operational interactive website to institutional clients using proprietary signaling algorithms (or “signals”). At the start of the engagement, clients that are part of FINIAT Direct (which encompass our Firm’s portfolio models as described further herein) receive entitlements to our Firm’s operational interactive website enabling them to access our proprietary technology platform. Through FINIAT Direct, which is our Firm’s advisory service that provides customizable strategies that use proprietary algorithms and signal delivery to overlay portfolios, clients generally use this service to manage their firm’s separately managed accounts (“SMAs”) or Wrap Fee Accounts but other advisory program options may applicable also. The clients of FINIAT select a portfolio model initially, which may be classified by our Firm as either a Core Model, which is comprised of a pre-set allocation of ETFs (including Equity- based and/or Fixed income-based) and/or individual common stocks by FINIAT independently, or a Customized Model, which is the same fundamental composition mix as the Core Model but with direct inputs from the client. FINIAT, at this time, does not employ individual fixed income securities into either the Core Model or Customized Model. Clients of FINIAT may select changes to the Core Models, such as, modifications to the established allocation percentages of equities to fixed income ETF rations attendant to an existing Core Model. For Customized Models, the client may specifically determine to exclude certain issuers from being constituents of the portfolio. In providing FINIAT models through our Firm’s operational interactive website, the client receives allocations for the constituents that comprise their respective selected models but does not receive any transactional instructions. Hence, FINIAT clients must determine independent of FINIAT what buy or sell orders need to be exercised to ensure that the allocations remain consistent with our Firm’s allocation signals and subsequently oversee applicable trade executions as well as continued portfolio monitoring. FINIAT, for its part, does not provide any services outside the generation of signals for our clients, including, order/trading activities and/or portfolio management services. FINIAT’s proprietary technology uses a quantitative engine that is a real-time, algorithmic- based signal platform that scores assets daily for holdings within its universe of securities. In doing so, our Firm’s technological platform makes use of great amounts of publicly available data resources to develop quantitative models and ongoing investment signals (i.e. allocations of models) that our clients rely on for portfolio management of their investors’ accounts and/or product offerings. In leveraging data analytics-driven solutions, FINIAT’s use of signals is designed to make timely portfolio adjustments integral to risk mitigation and optimization of long-term returns. Typically, these models are developed in reliance of factors like historical performance, risk metrics, and correlation among asset classes. The selection of asset classes and individual securities is routinely guided by optimization algorithms to achieve desired risk-return profiles. Models offered by FINIAT are usually based on periodic reviews of the model's performance, changes in market conditions, and shifts in the risk-return landscape. Quantitative methods, like time-series analysis and predictive modeling, guide these decisions. FINIAT offers proprietary signaling algorithms to primarily registered investment advisors (“RIAs”) and other asset managers (together, “clients”) through a consulting agreement. Our Firm does not provide discretionary or non-discretionary investment management services to clients. As such, clients of FINIAT have the discretion to accept or reject the signaling algorithms delivered to them only through our Firm’s website. In providing the signals to 6 | P a g e our clients, FINIAT performs these services through a contractual arrangement

in which our Firm maintains a fiduciary obligation to only our clients, namely, RIAs or institutional investors. FINIAT does not obtain any information regarding our client’s customers, which typically include retail investors. Therefore, FINIAT does not provide direct advisory services tailored to customers other than our clients, including retail investors. Clients of FINIAT that enter consulting arrangements with us are required to use the applications from our operational interactive website to select Core and/or Customized Models for their proprietary and/or customer accounts. Where customer accounts of FINIAT clients are involved, the client is solely obligated to select Core and/or Customized Model(s) based upon the customer’s desired risk tolerance, asset mix, and reasonable restriction(s), as applicable. In this process, FINIAT clients may select portfolio models from the suite of available ones already developed using our proprietary technology or, alternatively, clients may be guided in constructing portfolio models through tools and analytics available from our operational interactive website. Such guidance from FINIAT’s technology resources may include risk assessments, portfolio optimization suggestions, and scenario analysis, based on the client's desired characteristics. Regardless of the portfolio model type utilized, it is mandatory for clients of FINIAT to receive ongoing signaling algorithms via our operational interactive website. Clients of FINIAT may use the signals delivered via our Firm’s operational interactive website for a variety of underlying products or advisory programs, including fund offerings, separately managed accounts (“SMAs”), Turnkey Asset Management Platforms (“TAMPs”), Wrap Fee Accounts, and/or other advisory programs. The signals are delivered to clients through our Firm’s operational interactive website and are designed to dynamically position assets to capture upside potential in price movement while mitigating downside volatility. FINIAT’s use of signals is driven based on the proprietary technology employed by our Firm to assist clients with their portfolio management needs, and thus, the signals themselves may vary depending on the applicable criteria and factors used. For example, investment signals may include, on a given trade date, a singular order, or multiple orders as well as combination of purchase and sell instructions. FINIAT, too, can provide clients with portfolio models and ongoing investment signals that may include a combination of common stocks, ETFs, fixed income securities, and cash alternatives. As an alternative, clients may, during the onboarding process, select the option that the portfolio model(s) be comprised only of ETFs, for example. Fund Offerings FINIAT offers its proprietary investment strategies as a consulting service to investment managers of exchange traded funds (“ETFs”) and non-registered pooled investment vehicles (or “Private Funds”) that are interested in quantitative models as an integral portfolio management practice. FINIAT offers these services to investment managers of ETFs and Private Funds (e.g., Hedge Funds) through a consulting relationship as our Firm does not offer sub-advisory services. Services pertaining to these fund offering services are administered in a substantially same manner as the above referenced services regarding FINIAT Direct Portfolio Models, including a requirement that investment signals be transmitted through FINIAT’s operational interactive website. For more information, visit our website at https://finiat.com. Advisory Programs 7 | P a g e FINIAT does not serve as a portfolio manager or sponsor of any “Advisory Programs”, including Separately Managed Accounts (“SMAs”) nor wrap fee program (“Wrap Program”). FINIAT, however, may provide advisory services to clients that are portfolio managers and/or sponsors of SMAs and/or Wrap Programs. Investors directly invested in these Advisory Programs should consult their individual investment adviser or financial services representative for additional information about their specific program. Services Limited to Specific Types of Investments FINIAT generally limits its investment advice and/or money management techniques offered to equities, including exchange traded funds (“ETFs”) comprised of equity-based and/or fixed-income constituents, common stocks, master limited partnerships (“MLPs”), and other equities. FINIAT may use other securities as well to help diversify a portfolio where necessary but does not typically include individual fixed income securities as part of the constituents used in the model offerings. Client Tailored Services and Client Imposed Restrictions Due to the nature of FINIAT’s advisory services, which can invest in a number of different securities and security types at any time, the client is able to use our Firm’s operational interactive website to exercise the portfolio model selection but may impose only reasonable investment restrictions and other guidelines or limitations on our Firm in connection the ongoing investment signals for such model(s). Such latitude however may be restricted in situations where FINIAT is engaged with clients to provide investment signals to registered investment companies, such as ETFs that are governed by prospectus requirements and other pooled investment vehicles that are subject to offering documents that set limitations for investors. A restriction, guideline, or limitation request must be communicated through FINIAT’s operational interactive website for consideration and will not be honored if it is fundamentally inconsistent with the applicable investment strategy being pursued. FINIAT shall retain sole discretion as to whether or not to accept such restrictions, guidelines or limitations. Conflicts of Interests Investment Recommendations. Due to inherent differences amongst FINIAT client account objectives, benchmarks, time horizons, platforms, and fees, a conflict exists whereupon the facilitation of investment signals may result in the execution of securities transactions for certain client portfolios that may negatively impact securities values of other client portfolios resulting in varying performance results. Portfolio Composition. FINIAT, through its operational interactive website, provides initial portfolio construction and ongoing investment signals for clients using proprietary technology dependent on data resources and quantitative models developed in-house. As such, a conflict exists in which our Firm’s clients receive advisory services that are limited as they exclude research processes and portfolio management techniques available from external sources. Further, FINIAT’s portfolio models and signaling algorithms have inherent constraints on the universe of securities that may be included mainly for compliance and risk management reasons. 8 | P a g e Incentive Fees. A conflict exists where FINIAT is providing advisory services to clients that may compensate us with an incentive or performance-based fees as our Firm also provides advisory services to clients that do not provide us with performance-based fees. The management of performance-based fee client accounts and non-performance-based fee client accounts (or “side-by-side management”) creates an incentive for our Firm to have preferential treatment for the performance-based fee accounts. To mitigate this conflict, FINIAT maintains policies and procedures governing side-by-side management practices (as also described in Item 6 below).