A. Description of the Advisory Firm GradSave Planning Services, LLC, DBA “Gradvisor” (hereinafter “Gradvisor” or “Firm”) is a Limited Liability Company registered with the Securities and Exchange Commission (“SEC”). The firm was formed in December 2013 and is a wholly owned subsidiary of College Savings Holding, LLC (“CSH”), with one indirect owner, Marcos Cordero who owns 25% or more of CSH. The Firm offers services on to Clients (“Client”) on an institutional basis (“Institutional Model”), whereby a third-party entity(ies) pay some or all of the fees on behalf of a Client and the Client pays the balance of the fees. B. Types of Advisory Services Gradvisor offers the following services to advisory clients: Gradvisor offers a software-driven financial advisory service that creates an educational investment plan by seeking to identify: 1) the optimal 529 plan in which to invest, 2) the underlying age-based portfolio(s) in which to invest based on the client’s specific risk tolerance and 3) account funding from both client and payroll accounts. Each client also gets their own personal financial advisor (“advisor”) to answer more complex questions. This is currently the only level of service offered. In addition to the Services described above, the Firm may conduct or sponsor both no-cost and paid seminars, conferences or other such events during which Services offered by the Firm are discussed. Selection of Other Advisors Gradvisor may direct clients to third-party money managers. Gradvisor will not be compensated by the advisors to which it directs those clients. The Gradvisor service is geared to select 529 plans for clients and each 529 plan will have its own third party money manager chosen by the site’s 529plan sponsor. Gradvisor will always ensure those other advisors are properly licensed or registered as an investment advisor. Services Limited to Specific Types of Investments Gradvisor

limits its investment advice to the selection of 529 plans and the underlying investment allocation, which are by and large to mutual funds and money market/short term options. C. Client Tailored Services and Client Imposed Restrictions Gradvisor offers the same suite of services to all of its clients. Gradvisor tailors its software driven financial advisor service to the individual needs of each of its clients, and subject to certain product features and account limitations that prospective investors should consider, as described further below in Item 7. Accounts for Clients (“Accounts”) are opened according to a Client Account Agreement (“Account Agreement”). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. To tailor its software based financial advisor services to each Client, Gradvisor uses its advanced algorithms that factor, among others: investor’s risk tolerance, potential tax and fee implications, historical investment performance, and investment horizon (ie. time to college). Gradvisor asks each prospective Client a series of questions to evaluate both the individual’s objective ability to take risk and subjective willingness to take risk. Gradvisor’s Services do not include legal or tax advice. Accordingly, the Client is urged to work closely with the Client’s attorney, accountant, or other professionals regarding the Client’s financial and personal situation D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. Gradvisor does not participate in any wrap fee programs. E. Assets Under Management As part of its business model, Gradvisor does not maintain regulatory assets under management as of December 31, 2022.