A. Description of the Advisory Firm Brainvest Wealth Management LLC (hereinafter “Brainvest”) is a limited liability company organized in the State of Florida. The firm was formed in July 2017, and the principal owner is Brainvestor Inc., a Delaware corporation, which in turn is controlled by Mount Rose Ltd., a limited company incorporated under the law of the Republic of Malta. Brainvest utilizes an outsourced chief compliance officer through REYSA, LLC. Catalina Rey is compensated by REYSA, LLC for acting as Chief Compliance Officer for Brainvest. B. Type of Advisory Services Portfolio Management Services Brainvest offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Brainvest creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:
• Investment strategy
• Personal investment policy
• Asset allocation
• Asset selection
• Risk tolerance
• Regular portfolio monitoring Brainvest evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Brainvest is granted discretionary authority by clients, which enables it to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, a copy of which is given to each client. Brainvest also provides services to clients that elect not to grant discretionary authority (non- discretionary). For non-discretionary clients, security selection and execution require the client’s permission. Brainvest seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Brainvest’s economic, investment or other financial interests. To meet its fiduciary obligations, Brainvest attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Brainvest’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Brainvest’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services Brainvest offers consulting

services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker- dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Pooled Investment Vehicles Brainvest acts as the Portfolio Manager or advisory capacity to a variety of U.S. and non-U.S. pooled investment vehicles. These arrangements are disclosed in each fund’s prospectus or offering document in accordance with applicable disclosure requirements. Services Limited to Specific Types of Investments Brainvest generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. Brainvest may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Brainvest will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Brainvest on behalf of the client. Brainvest may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Brainvest from properly servicing the client account, or if the restrictions would require Brainvest to deviate from its standard suite of services, Brainvest reserves the right to end the relationship. D. Wrap Fee A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Brainvest does not participate in any wrap fee programs. E. Assets Under Management Brainvest has the following assets under management: Discretionary Amounts Non-discretionary Amounts Date Calculated $1,104,357,607 $13,556,216 December 2023