Genesia Investments LLC (“Genesia,” “firm,” “we,” “our,” “us,”) is an investment management firm founded in early 2024 that provides both discretionary and non-discretionary investment sub-advisory services to select independent registered investment advisors (each an “Advisor”). Genesia is wholly- owned by Rafael Villagran. Services Genesia offers several different investment advisory services to other investment advisors. We do not provide our services to individual clients of those Advisors. Discretionary Investment Management Our discretionary investment management takes two forms—V-Signal Portfolios and Strategic Portfolios. V-Signal Portfolios Our V-Signal Portfolios apply a proprietary approach, relying on quantitative signals, to determine asset class allocations – namely, areas to overweight and underweight. Our V-Signal algorithms measure relative performance of asset classes, sub-assets, sectors and select industries, and are intended to provide objective information about shifting market preferences at early stages of potentially long- lasting performance dispersions. Our V-Signal Portfolios are intended to provide enhanced total returns and reduced risk through market cycles. In collaboration with the Advisor, we implement, manage, and monitor portfolios suitable to serve the end client’s objectives within specified risk parameters. Strategic Portfolios Our Strategic Portfolios offer low-cost access to the Efficient Frontier (see Item 8 below for more information). The Strategic Portfolios are available as Core, Tax Aware or Customized Tax Aware variations, with the first used for qualified accounts and the others for taxable accounts. Our portfolios use low-cost exchange-traded funds (ETFs), with the Tax Aware portfolios focused on ETFs holding tax- exempt municipal bonds. These Portfolios are also offered in variations suitable for larger or smaller end client accounts. Our full Portfolios apply our full disaggregated allocation discipline which provides enhanced opportunities for periodic rebalancing and tax loss harvesting. We also provide simplified versions of our Strategic Portfolios suitable for accounts of less than $100,000 in size. Portfolio Management Consulting Our Portfolio Management Consulting services are non-discretionary services. These services are customized to the Advisors’ practice, needs and objectives. We can help refine pre-existing investment disciplines, and consult on portfolio construction, multi-asset class model portfolio development, asset allocation and fund selections. We can also help with communications and publications that contribute to end-client education and business development. We provide consulting support across the spectrum of investment topics and considerations. Our proprietary investment research and Premium Subscriptions are included as part of our Portfolio Management Consulting services. (See Subscription Services section below.) Genesia also consults with Advisors on a non-discretionary basis about trading strategy, rebalancing, and tax optimization as part of its services. Available only as supplementary services for our Portfolio Management Consulting clients, Genesia may also be engaged to provide Implementation & Trading services. These services would include the programming on trading platforms, trade execution, and account maintenance services. at the direction of the Advisor. (See Implementation & Trading Services section below.) For all Consulting Services, the Advisor decides independently whether to accept our recommendations or otherwise implement our advice. Implementation & Trading Services Our Implementation & Trading services are offered only as an add-on for our Portfolio Management Consulting clients. These services support model-based portfolio implementation and management, including periodic rebalancing, tax loss harvesting, and cash management relating to deposits or withdrawals. These are non-discretionary services, and therefore Advisor clients can choose to direct Genesia’s trading of their client accounts, or they can delegate to us subject to predefined tolerances and specific guidelines provided by the Advisor. We can apply advisors’ custom models developed with our Portfolio Management Consulting practice, and/or Genesia’s portfolio models. We can implement and maintain assigned portfolios on an account basis or household level. With household level management, we can support asset location considerations. In addition to periodic tax loss harvesting, we can also implement tax sensitive transitions of non-model holdings. Subscription Services We provide subscription research services, including fundamental research periodicals, which includes a quarterly recommended list of ETFs and open-end mutual funds across asset classes. Our fundamental research commentaries are available through either Standard or Premium Subscription levels, the latter of which provides for client-ready versions customized to the subscribing Advisor’s logo and colors. By subscription, we also provide access to our proprietary V-Signals, as well as quarterly updates of our model portfolios for both our V-Signal and Strategic portfolio disciplines. Advisors who choose to subscribe to our V-Signal newsletter publication will receive updated V-Signal information monthly, which generally coincides with the time we implement those signals on behalf of our discretionary portfolios. Accordingly, there will generally be some delay or timing difference between the time we implement the signals and when subscribers may be able to do so. Usually we would execute trades prior to subscribers being able to do so, but occasionally we may execute after signals are distributed. This could in theory result in significant changes in market prices from the time a signal is triggered and distributed and the time a subscriber is able to make use of it through a market trade. The securities involved are highly liquid and we do not believe that most timing differences will have material impact on pricing, especially over longer investment periods. For all services, we embrace an open architecture whereby investments and funds may be considered from virtually unlimited sources. Unless a fairly specialized attribute is sought from a specific investment allocation, Genesia generally relies on larger highly liquid low-cost funds. Liquidity considerations include the fund’s size and average trading volume. Index funds and ETFs are evaluated regarding their

performance tracking error relative to the targeted index. Actively-managed funds are subject to extensive initial due diligence, as well as subsequent annual reviews. General Information About our Services Where Genesia is acting as a sub-advisor to an Advisor, the Advisor may allocate some or all of its clients’ assets to Genesia. The Advisor retains the responsibility for the relationship with its client, and determines the initial and ongoing investment, risk tolerance, and suitability requirements of its client. The Advisor is also able to relay reasonable restrictions on investments in client portfolios. The Advisor provides this information to Genesia when establishing its client account(s). The Advisor typically provides ongoing oversight of the allocations to Genesia to confirm that the allocations continue to be consistent with the end client’s investment needs and objectives. In the ordinary course of business, Genesia does not interact directly with the Advisor’s end client or otherwise update end-client information except as provided through Advisor. Once an Advisor allocates its clients’ assets to Genesia, Genesia may select, change, or re-allocate such assets among the offered strategies, subject to guidance provided to Genesia by Advisor. Where authorized by the Advisor, Genesia will manage or effect purchases, sales, or other transactions for individual accounts (each, an “Account”) allocated to Genesia by Advisor. This may be accomplished through a discretionary or non-discretionary agreement. In managing the Account on a discretionary basis, Genesia is specifically permitted to retain all or part of the existing investments or to liquidate such investments, in Genesia’s discretion, and consistent with the client profile provided by Advisor. General Conflicts Advisors who subscribe to our V-Signal research services without also hiring us to manage client assets will typically not be able to act on the signals until after we have executed trades for Accounts we manage, though in some cases we may trade after subscribers. This also applies to Advisors who hire us to provide non-discretionary advice. This means the Accounts we manage directly using our discretionary authority have an advantage over non-discretionary Accounts and Accounts managed by V-Signal subscribers to the extent the signal governing our trading leads to better performance when trades are implemented as soon as possible after the signal is created or updated. There is, of course, no guarantee that trading shortly after the signal is triggered leads to greater profitability. We manage the conflict by disclosing it and providing Advisors a choice about the services they hire us for. Account Supervision Where Genesia has discretionary or non-discretionary over Advisors’ client portfolios, Genesia will supervise the Accounts in accordance with what the Advisor has communicated to us about a client’s stated objectives, risk tolerance, as well as tax considerations. Because some strategies involve additional degrees of risk, they will be selected only when consistent with the client’s stated investment objectives, tolerance for risk, liquidity and suitability. Account Customization and Investment Restrictions Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors, which Advisor may relay to Genesia. All transactions effected for an Account will be deemed to be suitable for an Advisor’s client in light of the stated investment objectives and guidelines, unless written notice to the contrary is received by Genesia within ten (10) business days following a client’s receipt of the custodian’s statement reflecting such transactions. In allocating their clients’ assets to Genesia, Advisors agree to contact their clients at least quarterly to notify them they may impose restrictions, and at least annually to determine whether there have been any changes in such clients’ financial situations or investment objectives and whether such clients wish to impose investment restrictions or modify existing restrictions or otherwise amend their investment guidelines. Advisors agree to promptly notify Genesia of any changes. Genesia does not guarantee the future performance of any Accounts, any specific level of performance, the success of any investment decision or strategy, or the success of Genesia’s recommendations in the Accounts. The investment and other decisions made by Genesia for the Accounts are subject to various market, currency, economic, political and business risks, and may result in investment decisions that will not be profitable. Written Agreement Genesia will enter into a written Sub-Advisory Agreement (the “Agreement”) with each Advisor, which describes the nature and extent of Genesia’s services, the terms and conditions applicable to such services, and the fees to be charged. Advisors are responsible for ensuring that their own client agreements provide for Advisor’s discretionary allocation to sub-advisors such as Genesia and for assessment of the fees due to Genesia. The services and fees described in this Brochure may not all be applicable to an Advisor’s specific Agreement. In the event of any difference between the information in this Brochure and the Agreement, the Agreement will control. Advisors will receive a copy of this Brochure prior to the execution of the Agreement. The Agreement may be canceled by either party at any time, for any reason, upon receipt of thirty (30) days’ prior written notice. If the Agreement is terminated, the Advisor will receive a prorated refund of any pre-paid fee, based upon the number of days remaining in the billing period after the termination date. Annual or quarterly minimum fees will also be applied at termination, to the extent applicable. Wrap Accounts Genesia does not offer wrap accounts. A wrap account is structured such that a client pays a single fee, or single percentage fee which covers both investment advisory services and brokerage costs. Disclosure Statement A copy of Genesia’s Brochure will be provided to each Advisor prior to, or contemporaneously with, the execution of the Agreement. The Advisor is responsible for delivering a copy to its own client, if the Advisor determines delivery is necessary to meet Advisor’s obligations to its clients. Assets Under Management As of February 1, 2024, Genesia had approximately $0 million in discretionary and non-discretionary assets under management.