About Vernal Point Advisors, LLC Vernal Point Advisors, LLC (“Vernal Point,” “we,” us”) is a limited liability company formed in 2012 in the State of California. Vernal Point is majority owned by Paul Morelli. Services Offered Vernal Point is a financial advisory firm dedicated to providing personalized, confidential financial planning, investment management, and family office services to our clients. Financial Planning Services Our financial planning services may include an examination of the client’s cash flow, insurance, taxes, investments, retirement and estate planning needs. After one or several meetings and our analysis, the client will be provided with a written plan charting recommendations to be made in the above areas to meet the client’s goals and objectives. Investment Management Services Our investment management services include helping the client clarify his or her investment objectives, goals and time horizons and creating a diversified portfolio based on those needs. We generally provide investment management services on a discretionary basis. If granted discretionary authorization to make trades in client accounts, we will effect transactions without the client’s prior consent. We evaluate investment opportunities in all asset classes and all geographies on behalf of clients and will consider many different investments, including low-cost exchange traded funds, mutual funds, alternative investments, REITs, and others. Vernal Point will also recommend clients invest a portion of their assets with unaffiliated investment advisors, referred to herein as “Managers”. This could be in the form of a separately managed account or an alternative investment which is generally a private placement in a pooled vehicle, e.g. a private fund. Based on the client's individual circumstances and needs, we will perform management searches of various Managers to identify which Manager’s portfolio management process and investment strategy is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, and the investment philosophy of the selected Manager. Clients should refer to the selected Manager’s Firm Brochure and other disclosure documents for a full description of the services offered. On an ongoing basis, we will monitor the performance of the selected Manager(s). If we determine that a Manager is not providing sufficient investment management services to the client or is not managing the client's investment/capital in a manner consistent with the client's policy guidelines, we may suggest that the client contract with a different Manager. Under this scenario, Vernal Point assists the client in selecting a new Manager and/or strategy. Clients may impose restrictions on investing in certain securities or types of securities. All restrictions must be in writing. At least annually, we will meet with the client to review and update, as necessary, the client’s investment guidelines. However, should there be any material change in the client’s personal and/or financial situation, we should be notified immediately to determine whether any review and/or revision of the client’s investment guidelines is warranted. Prior to engaging Vernal Point to provide services, clients are generally required to enter into an agreement with us setting the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee payable. It is the client’s responsibility to promptly notify us if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous recommendations and/or services. In addition to the agreement with Vernal Point, the client may also be required to enter into a written agreement with the Manager(s). In some cases, the Manager may act as a sub- advisor to Vernal Point and no additional agreement will be needed. These agreements will set forth the terms and conditions of the engagement and describe the scope of the services. The client will also receive the written disclosure statements of the selected Manager.

These disclosure statement(s) are in addition to the one from us, which you are currently reviewing. Manager advisory and/or performance based fees are in addition to any advisory fees charged by us. Please see Item 5 below for more information. The client is under no obligation to act on our recommendations. Moreover, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through us or the recommended Managers. Investment Management Service to Retirement Investors When Vernal Point provides investment advice to retirement plan accounts or individual retirement accounts, Vernal Point is 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. The way Vernal Point makes money creates some conflicts with client interests, so Vernal Point operates under a special rule that requires us to act in the client’s best interest and not put our interest ahead of the Client’s interests. Under this special rule’s provisions, Vernal Point must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of client’s interests when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in the client’s best interest;
• Charge no more than is reasonable for our services; and
• Give client’s basic information about conflicts of interest. Family Office Services Family office services provided by us include the organization of a client’s financial information, facilitating family governance, special projects, comprehensive risk management, the development of operational infrastructure, overseeing the establishment and administration of closely held client entities such as trusts and foundations, execution of planning strategies, estate pre-administration, and active vetting and oversight of the client’s other contractors and legal and tax advisors. If requested by the client, we may recommend the services of non-investment professionals. The client is 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 from us. Other Services In addition to financial planning, investment management services and family office services, we may periodically provide custom education curriculum created by us on financial topics for ultra-high net worth clients, often in conjunction with our other services (such as advisor selection, financial planning, and family office services). Amount of Assets Under Management As of January 31, 2024, Vernal Point had discretionary assets under management of $909 million and non-discretionary assets under management of $685 million for a total of $1.6 billion assets under management. Our Policy on Class Action Lawsuits From time to time, securities held in the accounts of clients may be the subject of class action lawsuits. Vernal Point has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. We also have no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, we have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where we receive written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, we will forward all notices, proof of claim forms, and other materials, to the client. Electronic mail is acceptable where appropriate if the client has authorized contact in this manner.