HealthEquity Advisors, LLC (“HEA” or “we” or “us” or “our”) is a fee-based SEC-registered investment adviser that is wholly owned by HealthEquity, Inc. (“HQY”), a firm that serves as nonbank custodian of Health Savings Accounts (“HSAs”). We provide investment advice in two ways: first we provide model asset allocation portfolios and portfolio management on both a discretionary and non-discretionary basis through an interactive website for natural person clients who are HSA beneficiaries who hold their HSAs with HQY; second, we provide investment consulting and research services on a non-discretionary basis to HQY and certain unaffiliated third parties (“HQY Partners”) to develop investment lineups comprising open-end mutual funds (each, an “Investment Lineup”). HSA beneficiaries who hold their HSA with HQY may choose to retain HEA to provide either discretionary or non-discretionary recommendations about how to invest in the Investment Lineup made available to them. Typically, an HSA beneficiary will have only one Investment Lineup available to them, although in some circumstances (as more fully described below), an HSA beneficiary is able to select from among two or more available Investment Lineups. Our principal place of business is located in Draper, Utah, and we have been in operation since April 2013. As of January 31, 2024, HEA managed approximately $743,594,305 in discretionary assets and approximately $450,839,717 in non-discretionary assets. Model Asset Allocation Portfolios and Portfolio Management for HSA Beneficiaries HEA is retained by HSA beneficiaries to provide investment recommendations about how to invest in the Investment Lineup made available to them. Recommendations are provided through one of two investment advisory programs: the AutoPilot program and the GPS program, each as described below (collectively, the “Programs”). The Programs are delivered exclusively online through the HEA investment portal, which is available through the HQY website. All investment advisory services provided by HEA to its natural person clients are delivered via the investment portal without any involvement by or interaction with HEA personnel. In the event of extraordinary circumstances where a natural person client needs to access his or her account but cannot do so through the HEA investment portal, the client can contact HEA to facilitate manual instructions to the platform. This process is only available to clients in extraordinary circumstances, such as being hospitalized and being unable to access his or her account to liquidate investments to pay for medical expenses. The specific mutual funds recommended to a client through the Programs depend on the Investment Lineup that is available to the client. A particular Investment Lineup is either developed by HEA (“HEA Investment Lineup”) or by an HQY Partner (“Third Party Investment Lineup”). HEA Investment Lineups include an Investment Lineup developed for HQY (the “Investor Choice Lineup”) as well as Investment Lineups developed for certain HQY Partners. If a client is eligible to invest in an HEA Investment Lineup, as part of its advisory services, HEA will select and monitor the underlying mutual funds in the Investment Lineup to ensure that the mutual funds remain suitable for clients and will recommend model asset allocation portfolios of the funds comprising the HEA Investment Lineup. If a client is eligible to invest in a Third Party Investment Lineup, as part of its advisory HealthEquity Advisors, LLC |Form ADV Part 2A 5 services, HEA recommends model asset allocation portfolios of the funds comprising the Third Party Investment Lineup by means of the AutoPilot and/or GPS service, but in those circumstances HEA will not, either initially or on an ongoing basis, select such funds for inclusion in the Third Party Investment Lineup or monitor the diversification of the assets held by such funds or the investment performance of such funds. The availability of HEA’s services to a client investing in a Third Party Investment Lineup is subject to limitations and is determined on a case by case basis. The HQY Partner is solely responsible for selecting and monitoring the underlying funds in Third Party Investment Lineups. AutoPilot Program In the AutoPilot program, HEA makes discretionary recommendations of model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. The model portfolios consist of mutual funds that are made available to the client’s account in the applicable Investment Lineup. In the AutoPilot program, recommendations are implemented on a discretionary basis, which means that HEA will automatically purchase and sell the funds comprising the recommended model portfolios without seeking approval from clients. Through the HEA investment portal, HEA collects client data using a web-based interactive questionnaire (“Questionnaire”) completed by the client. The Questionnaire establishes a risk profile based on: (1) either (a) the client’s age or (b) the client’s self-identified risk-based preferences; and (2) the client’s short-term economic outlook (the client’s “Risk Profile”). Algorithmic software recommends a risk-weighted model portfolio based on the client’s responses to the Questionnaire. Our algorithmic software is based on modern portfolio theory that emphasizes broad diversification of investment portfolios among the

mutual funds available to the client in the applicable Investment Lineup. Each client portfolio is managed based on the model portfolio's objectives that have been determined to be suitable for the client by the program’s algorithms based on the client’s Risk Profile, and investments are implemented to match the applicable model portfolio. The client’s portfolio is managed and rebalanced automatically through the algorithmic software. Clients retain individual beneficial ownership of all securities. To ensure that the client’s portfolio continues to be suitable based on the client’s Risk Profile and that the client's account continues to be managed in a manner that is consistent with the applicable model portfolio, we maintain client suitability information in each client's file. Clients that elect to receive a weekly performance summary through our interactive website are reminded in each performance summary of their Risk Profile. We also contact clients through our interactive website on a quarterly and annual basis to request updated information regarding each client's Risk Profile. GPS Program In the GPS program, HEA makes non-discretionary recommendations of model asset allocation portfolios based on a client’s responses to the Questionnaire. The Questionnaire establishes a risk profile based on: (1) either (a) the client’s age or (b) the client’s self-identified risk-based preferences; and (2) the client’s short- term economic outlook. The algorithmic software recommends a risk-weighted model portfolio based on the client’s responses to the Questionnaire. Our algorithmic software is based on modern portfolio theory that emphasizes broad diversification of investment portfolios among the mutual funds available to the client in HealthEquity Advisors, LLC |Form ADV Part 2A 6 the applicable Investment Lineup. The model portfolios consist of mutual funds that are made available to the client’s account in the applicable Investment Lineup. In the GPS program, investment portfolio recommendations are generated, but not implemented, by our algorithmic software. Clients can elect to implement some or all (or none) of the recommendations on their own through the investment portal. Investment Consulting and Research Services HEA provides investment consulting and research services on a non-discretionary basis to HQY and to certain HQY Partners by selecting and monitoring HEA Investment Lineups made available to HSA beneficiaries via the HEA investment portal. In selecting and monitoring HEA Investment Lineups, HEA does not consider the individual investment objectives or financial circumstances or determine whether any investment product is suitable or in the best interest of any particular HSA beneficiary, and no investment advisory relationship is established between an HSA beneficiary and HEA (unless the HSA beneficiary is eligible, and elects, to participate in the HEA AutoPilot or GPS program and thereby becomes an HEA client). HEA’s relationship with certain HQY Partners creates certain conflicts of interest, which are summarized below and described in the custodial agreements entered into between the applicable HSA beneficiaries and HQY. The following are the HQY Partners that have engaged HEA, and potential conflicts of interest that impact HSA beneficiaries: HQY Partner Potential Conflicts of Interest Teachers Insurance and Annuity Association of America (“TIAA”) HEA is compensated by TIAA to select and monitor an Investment Lineup (the “TIAA RPP Investment Lineup”) for a co-branded HSA administered by HQY. HEA has agreed with TIAA to use reasonable efforts to consider selecting investment products for the TIAA RPP Investment Lineup that are advised and/or sponsored by Nuveen Fund Advisors, LLC (“Nuveen”) or one of its affiliates (“Nuveen Funds”). Nuveen is an affiliate of TIAA. This arrangement creates a potential conflict of interest for HEA because HEA is incentivized to select Nuveen Funds for inclusion over funds from other fund families. Investments in Nuveen Funds will generate compensation for Nuveen and, as a result, generate indirect compensation for TIAA. To mitigate this conflict of interest, HSA beneficiaries referred to HQY by TIAA have the opportunity to choose between the TIAA RPP Investment Lineup or the Investor Choice Lineup. Generally speaking, HSA beneficiaries referred to HQY by HQY Partners where the applicable Investment Lineup is a Third Party Investment Lineup have the opportunity to choose between the applicable Third Party Investment Lineup or the Investor Choice Lineup. Services in General Investment Lineups, including HEA Investment Lineups and Third Party Investment Lineups, consist only of open-end mutual funds, and thus our investment recommendations are limited to advice regarding open-end mutual funds. HealthEquity Advisors, LLC |Form ADV Part 2A 7 AutoPilot and GPS While our model portfolios vary depending upon the applicable Investment Lineup, they are not individualized for each client. Nevertheless, we seek to ensure that our investment recommendations are suitable for clients, and the model portfolios that we recommend for a client are based on information the client provides in response to the Questionnaire and the Risk Profile generated as a result. The algorithms used in the AutoPilot program and the GPS program are the same algorithms. As discussed below under