Income Discovery is a fee-based registered investment adviser which provides investment advice to all its clients exclusively through an interactive website. The firm is registered with the SEC pursuant to Rule 203A-2(e)(2) of the Investment Advisers Act of 1940. Our principal place of business is in Liberty Corner, NJ. We have been in business as an investment adviser since 2011, with Manish Malhotra, President and Chief Executive Officer as majority owner of the firm. We do not manage client portfolios and do not have any discretionary or non- discretionary assets under management. Our clients for investment advice are financial institutions and their financial professionals who utilize our analytical software, tools, and digital API services. Retirement Income Strategy Optimization Service Through interactive software, our firm provides consulting services to financial institutions and their financial professionals. Our primary objective is to help these financial professionals analyze different strategies for generating retirement income using a combination of Social Security claim strategies, systematic withdrawal portfolio model allocations, and longevity risk products (“annuities”). Our software helps financial professionals address and demonstrate the dynamic risk - reward tradeoffs. experienced by their clients (“retirees”) during retirement lifestage. Our software evaluates different allocations to Systematic Withdrawal Portfolios, Social Security claim strategies, pension payout options, and annuities to find an optimum one. It does so in a mode that includes tax details, a separate tax type of each account, tax account withdrawal order analysis, and account-by-account glide path strategy analysis. In addition to the optimization capability, the software lets the financial professional analyze a specific allocation (paired with other decision on Social Security and other cash flow analysis, collectively called “retirement income strategy”) and compare the results side-by-side with previously analyzed allocations. The financial professional has discretion in selecting the allocations / retirement income strategies to be shared with their retirees and in determining one of the strategies as proposed. Systematic Withdrawal Portfolios are portfolios of asset classes with uncertain returns from which the retiree makes periodic withdrawals to generate the cash flow needed during retirement. Income, fixed, indexed and variable annuities are also supported in the evaluation process. In addition to interactive software, our firm also provides digital API services, where a financial institution can invoke our services to provide a retirement income analysis. This analysis may be used by a financial professional at the institution in conversations with a retiree or shown directly to retirees via the financial institution’s website. If shown directly to a retiree

online, the retiree will not be able to execute any recommendations through the digital API service. The retiree must separately contact the institution or a representative of the institution to execute a recommendation, as the institution and their financial professionals have the responsibility of collecting and verifying any additional pertinent information before evaluating and implementing the recommendation. Paycheck in Retirement: Our firm offers a Paycheck in Retirement program to financial professionals to provide execution and ongoing management of a retirement income plan for their retiree clients. Our Paycheck capability systematizes the execution of an agreed-upon, selected personalized retirement income plan by collecting all financial information, and tracking cash flows and expenses for inflation adjustments. It then provides disbursal instructions to advisors that encompass a retiree's managed accounts and held-away assets. The Paycheck service also monitors plan safety and recommends income adjustments, if necessary. Services in General: Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and primarily include advice regarding the optimal allocation of different asset classes such as equity, fixed income, and fixed and variable annuity products. Our recommendations are, however, limited by the universe of investment options entered by the financial professional into the optimization program. All investment recommendations are based on the information provided by a financial professional through our interactive application and are tailored to the underlying retiree. Our services that provide the analytics to power any institution’s educational and guidance or advice tools are also based on the information provided by the institution’s financial professionals or by the retiree directly. Our firm does not implement any recommendations. Retirees cannot implement any recommendations online; they must contact a financial professional in order to implement a recommendation. The financial professional utilizing the platform remains solely responsible for collecting account holder suitability information, identifying investment options, as well as for the evaluation and implementation of recommendations derived from our analytical tools. Certain analytical tools we make available to financial professionals and their retirees focus on factors that do not directly involve investment in securities, such as the analysis of when and how to implement claims for Social Security benefits. Although such services may not be subject to regulation under the laws and regulations governing investment advisory firms, we apply our Code of Ethics and procedures to information obtained while providing such services in order to protect any personal information of our clients’ retirees.