Smart Portfolios, LLC is an SEC-registered investment advisor, which was founded in April 2005. Its sole shareholder is Shield Holdings, LLC, whose principal owner is Bryce James. As of December 31, 2023, Smart Portfolios managed $183,547,020 on a discretionary basis and $4,399,249 on a non-discretionary basis. Smart Portfolios’ core focus as a Registered Investment Advisor (RIA) is to develop asset allocation strategies and models to apply to and manage the investment accounts of retail clients. In some limited cases, retail clients may receive model recommendations delivered as signals, or choose to have a customized ‘strategy’ solution. Each of Smart Portfolios’ seven asset allocation strategies/models is developed to invest in one or more predetermined universes of securities. This may include, depending on the model, exchange-traded funds, mutual funds and collective investment trusts of insurance companies or TIAA, each with a pre-established risk objective. Client accounts are invested only in accordance with the model(s) selected for the Client. The models developed by Smart Portfolios are based on the application of Dynamic Risk Theory, which uses advanced mathematics to calculate the risk, return, and correlation of securities (the relationships between the price movements of securities) in a portfolio, to create a more real-time efficient frontier through its Dynamic Portfolio Optimization (DPO)™ asset allocation system. The DPO system is used in each of the models. In addition to the models, Smart Portfolios may use fundamental analysis, macro-economic analysis, or technical analysis, in which it charts price movements of securities and adjusts allocation appropriately. Smart Portfolios utilizes the research and model portfolios of iM Global Partner Asset Management as a foundation for their mutual fund based models. The mutual fund models use a combination of asset allocation and fund selection to balance risk and opportunity to achieve long-term investment goals. Each of Smart Portfolios’ advisory services is described briefly below. The models and strategies used in performing these services are described in more detail in Item 8. Types of Services Retail Investment Management Services As a Registered Investment Advisor, Smart Portfolios selects from their developed Strategies and Models based on the Client’s financial position, objectives, and risk tolerance. Strategies and Models are applied to Client’s investment accounts and managed as a portfolio pursuant to discretionary authority. Additionally, some Clients request a customized “Strategy” for their investment solution. Signal Services Smart Portfolios provides signals to subscribers pursuant to signal agreements. The subscriber selects the signal to be provided (based on one of the Smart Portfolios models) and makes all decisions whether and when to use the signal. The subscriber executes all trades. Financial Planning and Consulting Services (Stand-Alone) Smart Portfolios provides financial planning and consulting services, including investment and non-investment related matters, such as estate planning and insurance planning. These services can be included as part of the investment agreement or on a stand-alone separate fee basis. Prior to engaging Smart Portfolios to provide planning or consulting services, Clients are generally required to enter into an agreement with Smart Portfolios setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the Client prior to Smart Portfolios commencing services. Account Restrictions and Tailoring Smart Portfolios does not implement Client restrictions governing investments, such as the type of securities or issuers to be bought or sold. Smart Portfolios will not select models for a Client that are inconsistent with any restrictions imposed by the Client and will not accept the Client if an available model or strategy would be inconsistent with any restrictions. Smart Portfolios does not specifically tailor models for Clients but can offer a custom strategy. Models and strategies are selected for Clients based on a Client’s financial position, objectives and risk tolerance. Important Disclosure Information Limitations of Financial Planning, Non-Investment Consulting and Implementation. As indicated above, to the extent requested by a Client, Smart Portfolios may provide financial planning and related consulting services. Neither Smart Portfolios nor its investment adviser representatives assist Clients with the implementation of any financial plan, unless they have agreed to do so in writing. Smart Portfolios does not monitor a Client’s financial plan, and it is the Client’s responsibility to revisit the financial plan with Smart Portfolios, if desired. Furthermore, although Smart Portfolios may provide recommendations regarding non- investment related matters, such as estate planning, tax planning and insurance, Smart Portfolios does not serve as a law firm, accounting firm, or insurance agency, and no portion of Smart Portfolios’ services should be construed as legal, accounting, or insurance implementation services. Accordingly, Smart Portfolios does not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a Client, Smart Portfolios may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by Smart Portfolios or its representatives. If the Client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not Smart Portfolios, shall be responsible for the quality and competency of the services provided. Client Obligations In performing its services, Smart Portfolios shall not be required to verify any information received from the Client or from the Client’s other professionals and is expressly authorized to rely thereon. Moreover, each Client is advised that it remains their responsibility to promptly notify Smart Portfolios if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Smart Portfolios’ previous recommendations and/or services. Non-Discretionary Service Limitations Clients that determine to engage Smart Portfolios on a non-discretionary investment advisory basis must be willing to accept that Smart Portfolios cannot affect any account transactions without obtaining prior consent to such transaction(s) from the Client. Therefore, in the event that Smart Portfolios would like to make a transaction for a Client’s account (including in the event of an individual holding or general market correction), and the Client is unavailable, Smart Portfolios will be unable to affect the account transaction(s) (as it would for its discretionary Clients) without first obtaining the Client’s consent. Use of Mutual Funds and Exchange Traded Funds Smart Portfolios utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Smart Portfolios’ investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Inverse/Enhanced Market Strategies Smart Portfolios may utilize long and short mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. To the contrary, such funds and/or strategy(ies) can suffer substantial losses. Socially Responsible Investing Limitations Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process.

ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Smart Portfolios), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Smart Portfolios generally relies on the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Portfolio Activity Smart Portfolios has a fiduciary duty to provide services consistent with the Client’s best interest. As part of its investment advisory services, Smart Portfolios will review Client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the Client’s investment objective. Based upon these factors, there may be extended periods of time when Smart Portfolios determines that changes to a Client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Retirement Plan Rollovers – No Obligation A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Smart Portfolios recommends that a client roll over their retirement plan assets into an account to be managed by Smart Portfolios, such a recommendation creates a conflict of interest if Smart Portfolios will earn new (or increase its current) compensation as a result of the rollover. If Smart Portfolios provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Smart Portfolios is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Smart Portfolios, whether it is from an employer’s plan or an existing IRA. ByAllAccounts In conjunction with the services provided by ByAllAccounts, Inc., Smart Portfolios may also provide periodic comprehensive reporting services, which can incorporate all of the Client’s investment assets including those investment assets that are not part of the assets managed by Smart Portfolios (the “Excluded Assets”). Smart Portfolios’ service relative to the Excluded Assets is limited to reporting services only, which does not include investment implementation. Because Smart Portfolios does not have trading authority for the Excluded Assets, to the extent applicable to the nature of the Excluded Assets (assets over which the Client maintains trading authority vs. trading authority designated to another investment professional), the Client (and/or the other investment professional), and not Smart Portfolios, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The Client and/or their other advisors that maintain trading authority, and not Smart Portfolios, shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, Smart Portfolios shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the Client desires that Smart Portfolios provide investment management services (whereby Smart Portfolios would have trading authority) with respect to the Excluded Assets, the Client may engage Smart Portfolios to do so. Cash Positions Smart Portfolios continues to treat cash as an asset class. As such, unless determined to the contrary by Smart Portfolios, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Smart Portfolios’ advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Smart Portfolios may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Smart Portfolios’ advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Smart Portfolios shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Smart Portfolios reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a Smart Portfolios actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Smart Portfolios unmanaged accounts. Cybersecurity Risk The information technology systems and networks that Smart Portfolios and its third-party service providers use to provide services to Smart Portfolios’ clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Smart Portfolios’ operations and result in the unauthorized acquisition or use of clients’ confidential or non- public personal information. Clients and Smart Portfolios are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Smart Portfolios has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Smart Portfolios does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions.