Formulate Financial, LLC (“Formulate”) is an independent registered investment advisor. The firm’s principal are Michael Rosenthal. Formulate provides investment management services to individuals, businesses and retirement plans. Asset Management Services Formulate’s process for individuals begins with discovery conducted through conversations with the client. The conversations help Formulate establish the client’s objectives, risk tolerance and overall goals, both short term, and long term. Formulate then will develop an individualized investment allocation based upon the investment objectives and risk tolerance of the client. Each portfolio will be customized to the client and focuses on creating income streams for retirement and diversification. Formulate acts as a “sounding board” for clients as they make financial decisions to ensure the portfolio remains in line with client goals. Formulate performs portfolio management and asset allocation services primarily on a discretionary basis. This means that while Formulate will continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, Formulate will not seek specific approval of changes to client accounts. Because Formulate takes discretion when managing accounts, clients engaging Formulate will be asked to execute an Investment Advisory Agreement that outlines the scope of the engagement. Retirement Plan Services Formulate offers fee based qualified retirement plan services that provide non-discretionary and discretionary Investment Fiduciary Services to Sponsors and Trustees of qualified retirement plans. Formulate will assist plans in establishing a menu of mutual

funds and / or models to offer to participating employees of the qualified retirement plan. Employees will self-direct the investments of their accounts within the plan. As an ERISA 3(21) Investment Advisor, services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan. Formulate will solely be making recommendations to the Sponsor. Formulate will recommend investments to the plan sponsor, monitor the plan’s investments, suggest replacements as appropriate, develop and monitor risk- based models comprised solely from the plan’s investment menu, and provide participant education. Formulate will provide guidance to the plan sponsor in meeting its fiduciary responsibilities. The Sponsor retains decision making authority and may accept or reject any recommendations. As an ERISA 3(38) Investment Manager, services are designed to allow the plan fiduciary to delegate responsibility for managing, acquiring and disposing of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974 (“ERISA”). If appointed as an ERISA 3(38) Investment Manager, Formulate would have full discretionary authority to select, monitor, and remove the investment options offered in a qualified retirement plan. In either case, whether Formulate is engaged as a 3(21) Investment Advisor or 3(38) Investment Manager, Formulate will charge a fee for services rendered, as described in this Form ADV and the Agreement. Assets Under Management As of the date of this brochure, Formulate is a newly formed business, and as such, Formulate does not yet have any clients or assets under management.