A. Description of the Advisory Firm Verus Capital Ventures, Inc. DBA Verus Financial Group (hereinafter “VCV”) is a corporation organized in the State of Texas. The group was formed in July 2019 and became a registered investment adviser in October of 2021. The principal owner is Minh Duc Vo. B. Types of Advisory Services Portfolio Management Services VCV offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. VCV creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring VCV evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. VCV will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. VCV seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of VCV’s economic, investment or other financial interests. To meet its fiduciary obligations, VCV attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, VCV’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is VCV’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. VCV may also retain sub-advisors or third-party managers to assist with managing portfolios. Although VCV generally has full discretionary authority to manage client portfolios, services are tailored to the individual needs of each client, and clients may impose restrictions related to the management of their account. Additionally, VCV may direct clients to third party investment managers to manage all or a portion of the client’s assets. Before selecting other advisers for clients, VCV will always ensure those other advisers are properly licensed or registered as an investment adviser. VCV conducts due diligence on any third - party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. VCV then makes investments with a third-party investment adviser by referring the client to the third-party adviser. Private Equity Investments VCV may also allocate among one or more private equity funds or private equity fund advisers. VCV will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. All investors must meet the Qualified Purchaser threshold by having a $5 million net worth outside of primary residence. Robo-Advisory Services We provide portfolio management services through Institutional Intelligent Portfolios™, an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Program” and “SWIA,” respectively). Through the Program, we offer clients a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at SWIA’s affiliate, Charles Schwab & Co., Inc. (“CS&Co”). We are independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, CS&Co or their affiliates (together, “Schwab”). The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios™ Disclosure Brochure (the “Program Disclosure Brochure”), which is delivered to clients by SWIA during the online enrollment process. We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. SWIA’s role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. We have contracted with SWIA to provide us with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that w e w ill recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We do not receive a portion of the wrap fee for our services to clients through the Program. Clients do not pay fees to SWIA in connection with the Program, [but we charge clients a fee for

our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab.] Clients do not pay brokerage commissions or any other fees to CS&Co as part of the Program. Schwab does receive other revenues in connection with the Program, as described in the Program Disclosure Brochure. We do not pay SWIA fees for its services in the Program so long as we maintain $100 million in client assets in accounts at CS&Co that are not enrolled in the Program. If we do not meet this condition, then we pay SWIA an annual fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. Pension Consulting Services VCV offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions.
• providing guidance on various assets classes and investment options.
• recommending money managers to manage plan assets in ways designed to achieve objectives.
• monitoring performance of money managers and investment options and making. recommendations for changes.
• recommending other service providers, such as custodians, administrators, and broker-dealers
• creating a written pension consulting plan.
• may accept responsibility as a (3)21 co-fiduciary to ERISA retirement plans through Accredited Investment Fiduciary® (AIF®) Designees. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Clients will also be given the election to pay fees through a third-party vendor, AdvicePay. Payment using AdvicePay is not required in order to provide financial planning services. The client, if they elect, will be invoiced through and payment made directly within the vendor’s secure site. The client will authorize and direct the fee to be paid to Verus. Verus and AdvicePay are separate entities and there is no material conflict of interest for the use of this service. This service will be offered to current and new Financial Planning clients. AdvicePay does charge a fee for the services, but the client will not bear these costs. Verus will pay all fees associated with the client’s use of this payment vendor. Services Limited to Specific Types of Investments VCV generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds, private equity funds and private placements. VCV may use other securities as well to help diversify a portfolio when applicable. Estate Planning VCV will offer Estate Planning services to clients to assist with general information as it applies to review of existing plans, gathering information needed to provide outside firms in the creation of documents, and updating existing plans for client. Depending on the client’s needs and desires for estate planning document review, preparation, or updates we will engage with a third-party service or estate planning attorneys. Clients are not required to utilize a third-party service that we may recommend, and they may receive similar services from other professionals at a similar or lower cost. Fees associated with the service will be in addition to the fees that clients may already pay and are disclosed in Item 5, and within the Estate Planning Disclosure that clients receive before engaging in this service. Clients will also be given the election to pay fees through a third-party vendor, AdvicePay. Payment using AdvicePay is not required in order to provide estate planning services. The client, if they elect, will be invoiced through and payment made directly within the vendor’s secure site. The client will authorize and direct the fee to be paid to Verus. Verus and AdvicePay are separate entities and there is no material conflict of interest for the use of this service. This service will be offered to current and new Estate Planning clients. AdvicePay does charge a fee for the services, but the client will not bear these costs. Verus will pay all fees associated with the client’s use of this payment vendor. Other Services VCV offers clients the services of Advisor Credit Exchange, LLC. (See Items 8 and 14). VCV also provides periodic educational seminars and workshops to clients. Some seminars and workshops will require a fee to attend. C. Client Tailored Services and Client Imposed Restrictions VCV offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent VCV from properly servicing the client account, or if the restrictions would require VCV to deviate from its standard suite of services, VCV reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. VCV does not participate in any wrap fee programs. E. Assets Under Management VCV has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 96,002,852 $ 4,662,173 February 27, Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.