Our Company & Principal Owner Investment Cards RIA LLC ("ICRIA" or "Company") is a Delaware limited liability company, organized in 2017. Frederick P. Phillips is the sole owner and managing member of ICRIA. Program & Interactive Website Via the Internet Interface, ICRIA offers an internet-based program (the “Program”), which enables qualified participants to establish a cash management account (“CMA”). The CMA has both an FDIC- insured transaction account (“Transaction Account”), accessible by a debit card issued by an unaffiliated bank (the “Bank”), and an investment account (“Investment Account”) maintained by an unaffiliated “broker-dealer” (which term shall refer to the current broker-dealer and any successor broker-dealer selected by ICRIA). Prospective participants complete a profile of their personal and/or business information through an online enrollment process before these accounts are established. Once the CMA has been set up and funded by the participants, participants may opt to move funds from their Transaction Account to their Investment Account or from their Investment Account to Transaction Account at any time. When participants use their debit cards, transactions are funded from their Transaction Account. If a participant’s Transaction Account balance is reduced below the amount necessary to fund transactions, securities positions in the participant’s Investment Account are automatically liquidated and swept back to the Transaction Account to fund payments.[1] ICRIA is the adviser for the Investment Accounts and selects each broker-dealer for the Program. ICRIA selects the limited menu of securities available through the Program. These typically consist of government money market funds, ultrashort bond funds, and short bond funds (which can be mutual funds and/or ETFs). Solely at the direction of participants, participants may move funds from the Transaction Account to the Investment Account to be invested in one or more of the limited menu of securities available through the Program. ICRIA receives participant investment instructions only via the Internet Interface, then communicates them to the broker-dealer for execution through a computer- based process and related APIs. The ICRIA process is wholly technology and web based. The Investment Accounts are self-directed. Participants decide if, when, and how much money to transfer out of their Transaction Account and into the Investment Account (of vice versa), at their discretion. The participant can move funds to a different investment at any time, within the limited menu of investment options available (which ICRIA may modify from time to time as it deems appropriate). It is the participant’s responsibility to review and carefully consider the information available about each of the limited menu of investment options before moving funds into the Investment Account. _____________________________________ [1] Investment Accounts and transactions are subject to securities clearance and settlement requirements of the Custodian and any Clearing Agencies, applicable U.S. laws, and the rules and regulations of applicable federal, state and self-regulatory agencies, including but not limited to, the Board of Governors of the Federal Reserve System

(the “Federal Reserve Board”), the U.S. Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority (“FINRA”), and the constitution, rules, regulations, customs and usages of the exchanges, markets, and clearing agencies where transactions are executed, cleared and settled for the Investment Account (“Applicable Law”). When participants initiate transactions that increase or reduce their Investment Account balance, the Program technology conveys the participant’s purchase or sell request via ICRIA to the broker-dealer. Through the Program technology and via ICRIA, participants direct the broker-dealer to effect all purchases, sales, and other transactions for and on behalf of the account and grant the broker-dealer full authority with respect to the routing and execution of all account transactions, as the broker-dealer deems appropriate. Based on these instructions, the broker-dealer purchases or sells shares of applicable securities at NAV for mutual funds and the prevailing market price for ETFs. Participants’ trades may be aggregated and processed with other participants’ transactions. The broker-dealer issues trade confirmations and makes statements (i.e., records of account activity) available at least quarterly for the participants (unless confirmations are otherwise waived by the participant). ICRIA exercises limited discretion regarding individual investments for participants through selecting and updating the investment menu and making any changes in a participant's holdings when the menu is changed. ICRIA does not actively manage investments for any participating except to sell investments in an amount necessary to replenish the Transaction Account (e.g., as necessary to fund participants’ transactions if there is an insufficient balance in the Transaction Account) and/or to replace, remove, or add investment fund options in the menu of securities available through the Program. ICRIA does not provide continuous, ongoing, individualized investment advice beyond selecting and updating the investment menu. Neither ICRIA, the broker-dealer, nor any of their respective employees, agents, principals, or representatives provide research, advice, or recommendations regarding any security, transaction, or order. None of them handle funds or securities related to orders transmitted to the broker-dealer; and, except for the broker-dealer, none of them effect the execution, clearance, or settlement of trades. Personal Assistance; Technical Support; Participating Advisor Disclosures The SEC’s exemption for internet advisers prohibits ICRIA from providing in-person advice, except for technical support for assistance on using the Internet Interface. ICRIA does not provide in-person advice and ICRIA does not respond to participants’ investment-related questions. During the Program account enrollment process, participants execute an agreement regarding the advisory services to be provided by ICRIA with respect to the Program and any fees to be charged for such services. Wrap Fee Programs ICRIA does not sponsor or manage a wrap fee program. Assets under Management As of March 22, 2024, ICRIA had $ 3,588 assets under management that were managed on a discretionary basis. These assets are considered regulatory assets under management.