A. Description of the Advisory Firm Build Whale, Inc. (“Whale”), is a Delaware limited liability company registered with the SEC under the Investment Advisers Act of 1940 (the “Advisers Act”), that maintains its principal office at 332 S. Michigan Avenue, Suite #121-2234, Chicago, IL 60604. Whale was formed in 2023 and its principal owner and Chief Executive Officer is Arthur Petraglia. Whale is an investment adviser that, as of the date of this Brochure, is relying on the 120-day registration exemption under Rule 203A-2(c), and will subsequently rely on the “Internet Adviser Exemption” under Rule 203A-2 of the Advisers Act. Whale is a fintech platform that will be an “operational interactive website” (the “Whale Application”) provider for renters (the “Client(s)”) with respect to their security deposits (“Investable Deposits”) and any additional funds. As described in more detail below, Whale provides its Clients with two different programs: the Whale Deposit Program and the Whale Grow Program. In addition to the investment advisory services, the programs are also intended to promote financial literacy. B. Types of Advisory Services Whale, as a registered investment adviser, offers discretionary investment advisory services to Clients over the internet via the Whale Application. The Client relationships are established through a written Investment Advisory Agreement (the “Agreement”) executed by both Whale and the Client. Investment opportunities provided by Whale are designed to encourage automated investments and do not provide overall financial planning, tax, accounting, or legal advice. As referenced above, Whale provides two different programs. First, the “Whale Deposit Program” deposits the Investable Deposits in FDIC-insured interest-bearing products provided by the Broker- Dealer (as defined below), enabling Clients to preserve the capital of the Investable Deposits. The rates of interest paid by each program bank will differ. Whale does not guarantee that any Client will receive a specified average or composite interest rate on funds invested through the program. Second, the “Whale Grow Program” entails Whale providing Clients with investment recommendations pursuant to its online or mobile interactive questionnaire (the “Questionnaire”) via the Whale Application, where funds in excess of the Investable Deposits are invested in model portfolios (“Model Portfolio(s)”) consisting of ETF portfolios managed by unaffiliated third-party SEC registered investment advisers. The investment products that embody the Model Portfolios are comprised of publicly traded Exchange Trade Funds (“ETFs”). Whale’s software-based algorithm determines a Client’s recommended initial portfolio by determining the best suited portfolio based on the responses to a Client’s Questionnaire, which incorporates a Client’s financial situation, investment horizon, and risk profile, among other factors. A Client can choose to select the recommended Model Portfolio or override the recommendation by selecting a different Model Portfolio. Whale

reviews and evaluates portfolio allocation determinations periodically, both in conjunction with any material changes or updates to a Client’s investor profile, as well as annually regardless of whether Whale has been notified of any material changes or updates from the Client. Whale recommends that Clients ensure their financial condition, risk tolerance and investment goals are kept current in their investor profile on the Whale Application. As described in more detail below, Whale intends to use Alpaca, a registered broker-dealer and qualified custodian (the “Broker-Dealer” or “Custodian”). Whale plans to offer the Whale Deposit Program in conjunction with Alpaca. As the Clients’ Broker-Dealer, Alpaca will provide, as an 2 ACTIVE/128897685.4 administrative service, a money-market account in which the Investable Deposits are deposited. Whale deems such money-market accounts as cash or cash-equivalents as described in Item 5.F of the ADV Part 1A instructions. Whale has the discretion to change the type of instrument in which the Investable Deposits are deposited, to the extent that such instrument is consistent with the capital- preservation objective such that the Client can fulfill his or her obligations under their lease agreement. Accordingly, Whale deems both the Whale Deposit Program and Whale Grow Program part of its advisory services. Please see Item 11 regarding potential conflicts of interest regarding the Whale Deposit Program. C. Types of Advisory Services As described above, Whale offers the Whale Deposit Program and the Whale Grow Program. Whale tailors its advisory services to the individual needs of the Clients with respect to the Whale Grow Program by providing Clients with investment recommendations pursuant to the Questionnaire via the Whale Application. Such recommendation incorporates a Client’s financial situation, investment horizon, and risk profile, among other factors. A Client can choose to select the recommended Model Portfolio or override such recommendation by selecting a different Model Portfolio. Whale also reviews and evaluates portfolio allocation determinations periodically, both in conjunction with any material changes or updates to a Client’s investor profile. D. Wrap Fee Programs Whale does not participate in wrap fee programs. E. Amounts Under Management As of February 23, 2024, Whale has approximately $0 of assets under management on a discretionary basis and $0 on a non-discretionary basis Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $0 $0 5/15/24 Business Continuity Plan Whale maintains a Business Continuity/Disaster Recovery Plan (the “Plan”) which includes provisions for, among other things: backup of Firm systems and critical data, contact information for employees and key service providers and procedures to be followed in the event that Whale’s physical office location(s) is/are unavailable in the event of a disaster or other business disruption. The Plan requires review and testing no less than annually. 3 ACTIVE/128897685.4