Finhabits Advisors, LLC (“Finhabits”, or “Adviser”) is an online investment adviser registered with the Securities and Exchange Commission (“SEC”) in July 2015. The Adviser is a privately held limited liability company organized under the laws of the state of Delaware in June 2015. Additional information about Finhabits’ products, structure and directors is provided on Part 1 of Finhabits’ Form ADV which is available online at http://www.adviserinfo.sec.gov. We encourage clients to visit our website www.finhabits.com for additional information. Types of Advisory Services Finhabits offers a wrap fee program (“Program”) and a 3(38) (as defined under the Employer Retirement Income Security Act of 1976 (“ERISA”)) investment adviser or manager to its defined contribution plan clients. Wrap Fee Program Finhabits offers a wrap fee program (“Program”) with professional investment advisory services through an online web-based application to individuals and high-net worth individuals. Finhabits’ goal is to provide its clients with an investment management service where they can receive investment advice to help them develop and execute plans that are designed to build and preserve their wealth, and to begin saving and investing for their retirement. Finhabits’ advice is based on the financial profile, age, time horizon, and investment experience of each client. Finhabits will interact with clients using a software application developed by its parent company, Finhabits Inc. Through our website or mobile app (“Sites”), each client enters data and creates a financial goal (“Goal”), which outlines the client’s contributions, timeline and the proposed investment strategy managed by Finhabits. Once the Goal is confirmed and the proposed investment strategy is selected, Finhabits automatically implements the investment strategy and periodically rebalances each client’s portfolio in order to maintain an efficient portfolio in accordance to the Goal. Each client needs to update their personal data through the Sites if their objective, risk tolerance, or life events change. Finhabits will check quarterly with each client to confirm their data remains valid. Although Finhabits requests and captures a wider range of information from clients, the recommendation of the investment strategy is not currently considering that wider range of information. Finhabits’ unique automated investment service is based on modern portfolio theory that makes it possible for anyone to access state-of-the-art portfolio management. Each individualized portfolio is designed to be consistent with the client’s investment objectives and risk tolerances. The investments in the portfolio will primarily consist of exchange traded funds (“ETFs”) and mutual funds (collectively “Funds”). Clients are not able to change the underlying Funds that comprise each portfolio. Using our technology, we can create an investment plan and manage a client’s portfolio by seeking to identify:
• the optimal asset classes in which to invest;
• the most efficient Funds to represent each of those asset classes;
• the ideal mix of asset classes based on the client’s specific risk tolerance; and,
• the most appropriate time to rebalance the client’s portfolio to maintain intended risk tolerance. Each client’s Program account (“Account”) will be held in the client’s name at an independent custodian, and not with us. All Accounts managed through the Sites are required to use Apex Clearing Corporation as the independent custodian (“Custodian”). All clients will receive our Advisory Agreement describing the discretionary authority that a client grants to Finhabits, as well as the services they will receive, fees they will be charged, and the conditions of the relationship. Finhabits does not offer tax, accounting or legal advice. 3(38) Advisory Services Finhabits offers fiduciary service for retirement plans in the United States (each a “Plan”) and will act as a fiduciary and investment manager to the Plan pursuant to 3(38) of ERISA (3(38) Fiduciary). Finhabits will design the investment structure, including updating the investment options (“401k Funds”), consistent with the Plan’s Investment Policy Statement; will monitor the investment options and will have the discretion to change the menu of investment options, pursuant to Finhabits’ agreement with the Plan. Furthermore, when serving as an ERISA 3(38) investment manager, the Plan sponsor is relieved of fiduciary responsibility

for the investment decisions made by Finhabits. Finhabits, as a fiduciary and investment manager, is required to act prudently when it decides to buy or sell securities or make investment decisions on behalf of the Plan. Finally, Finhabits will acknowledge, in writing, that it is a fiduciary with respect to the Plan. Finhabits will not receive any fees from the 401k Funds, including fund distribution fees, revenue sharing, advisory fees, or management fees. Fees and Compensation Finhabits’ clients pay a monthly Subscription Fee for personal use of the Finhabits’ web or mobile application. The Subscription Fee covers advisory services, execution, clearance, custody, account reporting, and exclusive financial education content. The amount of the Subscription Fee depends on your Monthly Account Balance. Currently, Finhabits waives its minimum subscription fee for Accounts that participate in the Washington’s Small Business Retirement Marketplace (“Marketplace”) and have a balance under $1,500. Fees for Finhabits’ 3(38) advisory services to Plans are $2 per month per plan participant regardless of the balance of the participant account. Plans will incur certain charges imposed by unaffiliated parties. Such charges include, but are not limited to, fees paid to the plan’s record keeper or third party administrator or indirect expenses to the 401k Funds. These other fees are not paid to Finhabits. Monthly Account Balance Fee Under $7,500 $3 $7,500 or more $3 per $7,500 of Average Daily Balance The fees shown above are not negotiable. Clients will authorize Finhabits and the Custodian to directly debit the Subscription Fee from the client’s funding account. In the event we cannot deduct the Subscription Fee from a client’s funding account, we reserve the right to withdraw the outstanding minimum subscription due from their Finhabits Account held at the Custodian and/or terminate access to the Program. Clients acknowledge that the $3 Subscription Fee per month for Accounts with a balance of less than $7,500 may equate to a significant fee on a percentage basis, depending on the amount the client has invested. This may potentially be a greater fee than a client would pay to other investment advisers which permit a client to invest such an amount. There are other fees that clients may be charged by other parties. The wrap fee or service fee covers all trade and advisory charges for each Account as part of the Program. However, our fees do not include other related costs and expenses. The Funds recommended by Finhabits have fees that are distinct and separate from the fees paid to Finhabits for its wrap fee program. Clients may also incur certain charges imposed by the Custodian and other third parties, as listed on Schedule A. These include transfer taxes, wire transfers, electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Finhabits client’s might find that the fees from the advisory and other services that comprise the Program may cause a higher advisory cost than if a client purchased the Funds directly. Clients should be aware that this wrap account may cost more or less than someone would pay to have all of the services provided separately to them. Factors that would bear upon the cost of this account in relation to receiving the services separately include the number of different service providers needed to achieve the results, the need for increased coordination and management, and the execution capabilities, speed, and efficiency of the various service providers. Either party may terminate the advisory relationship through our web-based application at any time. If a client wishes to terminate the relationship via email, he or she can contact us at support@finhabits.com. The termination will take effect promptly upon our receipt of the e-mail from the client or the notification from the web-based application. Finhabits may terminate a client’s access to our online service if we believe a client is in breach of the Finhabits Terms of Use and/or Advisory Agreement. Subscription fees are not prorated if we or a client terminates access to the Program intra-monthly. When a Wrap Fee Account is terminated, the securities in the Account will be sold and the cash will be returned to the client’s designated bank account usually within 5 business days. Finhabits reserves the right to reduce or vary any fees associated with the Program at its sole discretion.