A. Description of the Advisory Firm Independence Square Holdings, LLC (hereinafter “INDSQUARE”, “we”, “us”, or “our”) is a Limited Liability Company organized in the Commonwealth of Pennsylvania, and the principal owner is Joseph Black Elliott III. The firm was formed in June 2019 with the goal of assisting our clients with building, managing, and preserving their wealth. We manage accounts on a discretionary basis. Individuals associated with INDSQUARE will provide its investment advisory services. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on behalf of INDSQUARE. Such individuals are known as Investment Adviser Representatives (“IAR”). INDSQUARE may also register an IAR solely as a promoter. A promoter refers clients to the Registered Investment Adviser. In some states, a Promoter is not required to qualify as an IAR by exam, and therefore, promoters may only refer advisory business to an IAR to provide investment advice. Independent Financial Advisors (“IFA”) are licensed Investment Advisor Representatives who are not dually registered with a Broker/Dealer as an agent or broker. B. Types of Advisory Services Portfolio Management Services INDSQUARE offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. We work with you to collect personal information which includes, but is not limited to, income, expenses, taxes, and risk tolerance. We will either construct a portfolio customized to your specific situation, discuss utilizing a third-party asset manager, or recommend a modeled portfolio that fits your needs. 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 INDSQUARE evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. We request discretionary authority from clients to select securities and execute transactions without permission from you prior to each transaction. INDSQUARE seeks to make investment decisions that are in accordance with the fiduciary duties owed to our clients and without consideration of our own economic, investment, or other financial interests. To meet our fiduciary obligations, INDSQUARE attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, INDSQUARE’s policy is to seek fair and equitable allocation of investment opportunities/transactions among our clients to avoid favoring one client over another over time. It is INDSQUARE’s policy to allocate investment opportunities and transactions we identify as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have limited supply among our clients on a fair and equitable basis over time. INDSQUARE may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, we confirm that those other advisers are properly licensed or registered as an investment adviser. INDSQUARE conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings, and review of the third-party adviser's performance and investment strategy. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by the third-party adviser on behalf of INDSQUARE's client. We may also allocate among them one or more private equity funds or private equity fund advisers. We review the ongoing performance of the third-party adviser as a portion of your portfolio. LPL Financial Sponsored Advisory Programs INDSQUARE may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL), a registered investment adviser and broker-dealer. Below is a brief description of each LPL advisory program available to INDSQUARE. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. INDSQUARE will assist clients in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages the client’s assets on a discretionary basis. INDSQUARE provides both initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, clients authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. INDSQUARE assists clients in determining the suitability of OMP for the client and assists the client in setting an appropriate investment objective. INDSQUARE has discretion to select a mutual fund asset allocation portfolio, designed by LPL, consistent with the client’s investment objective. LPL has discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $1,000 and systematic contributions of at least $25 per year are required for OMP. Without systematic contributions, the minimum investment amount is $10,000. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. INDSQUARE has discretion to select the asset allocation model portfolio based on our client’s investment objective. We also have discretion to select third party money managers (PWP Advisors), mutual funds, and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell, on a discretionary basis, mutual funds, ETFs and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. INDSQUARE will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program, and assist the client in setting an appropriate investment objective. INDSQUARE will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio, designed by LPL’s Research Department, that is consistent with the client’s stated investment objective. LPL’s Research Department or third- party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to rebalance their MWP account(s). MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Small Market Solution (SMS) Program Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus (“Fiduciary Selection Services”). The investment options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. If the Plan is subject to ERISA, LPL will be a “fiduciary” and serve as “investment manager” (as that term is defined in section 3(38) of ERISA) in connection with the Fiduciary Selection Services. None of the services offered under SMS other than the Fiduciary Selection Services will constitute “investment advice” under 3(21)(A)(ii) of ERISA, or otherwise cause LPL or INDSQUARE to be deemed a fiduciary. In addition to the Fiduciary Selection Services, the Plan Sponsor may also select from a number of non-fiduciary consulting services available under SMS that are provided by INDSQUARE. These consulting services may include, but are not limited to, general education, and support regarding the Plan and the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, record keepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets, and LPL and INDSQUARE do not act as fiduciaries under ERISA in providing such consulting services. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell open-end mutual funds and exchange-traded funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of Xulu, Inc., doing business as FutureAdvisor (“FutureAdvisor”), based upon model portfolios constructed by LPL, and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although INDSQUARE will be available to discuss investment strategies, objectives, or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor, and INDSQUARE by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor, or INDSQUARE, do not enter into an advisory agreement with LPL, FutureAdvisor, or INDSQUARE, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. Pension Consulting Services INDSQUARE 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; and/or
• providing guidance on various asset classes and investment options; and/or
• recommending money managers to manage plan assets in ways designed to achieve objectives; and/or
• monitoring performance of money managers and investment options and making recommendations for changes; and/or
• recommending other service providers, such as custodians, administrators, and broker- dealers; and/or
• 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. Financial Planning and Consulting INDSQUARE provides its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment-related matters). These services are tailored to the individual needs of each client. We do not provide legal or tax advice regarding these services and clients are encouraged to seek guidance from their legal or tax representatives. In performing our services, we are not required to verify any information received from you or your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on such information. Certain employees of INDSQUARE include individuals who are licensed insurance agents or registered representatives of an unaffiliated broker-dealer who may implement its recommendations for certain products as part of the overall client portfolio. Clients are advised that a conflict of interest exists if we recommend our own services or those of our employees or affiliates. You are under no obligation to act upon any of the recommendations made by us under a financial planning or consulting engagement or to engage the services of any such recommended professional, including, by INDSQUARE itself. You retain absolute discretion over all such implementation decisions, and you are free to accept or reject any of our recommendations. It remains your responsibility to promptly notify us if there is any change in your financial situation or investment objectives so we can review, evaluate, or if necessary, revise our previous recommendations and/or services. Services Limited to Specific Types of Investments Generally, we limit our investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds, and private placements. In certain cases, we may use other securities or investments, when appropriate, to help diversify a portfolio (please see the section on cryptocurrency, below). Wealth Inc. (“Wealth.com”) INDSQUARE may provide you access to Wealth Inc.’s third-party technology platform, “Wealth.com”. This platform presents financial advisors with the unique opportunity to provide a value-added service to clients by granting them access to estate planning, templated documents. Wealth.com templates include Last Will and Testament, Financial Power of attorney, Advanced Health Care Directives, Guardianship Nominations, Revocable Trust & Pourover Wills. Wealth.com templates are fillable and must be completed by you, not your financial advisor. Neither Wealth Inc. nor Independence Square Holdings, LLC is, or will, provide tax or legal advice. If you are seeking tax or legal advice, please consult with an attorney or a tax professional. Wealth.com templates are available in, all 50 U.S. states and D.C. These documents may not be valid internationally, and if you are considering moving out of the United States, you should consult with an attorney. Templates are generic and do not encompass all situations. Templates are not tailored to your specific needs and therefore, if you have a unique situation or special circumstances, we recommend you discuss these situations with an attorney prior to utilizing Wealth.com templates. If your financial advisor recommends Wealth.com, they may have a financial incentive for doing so, which would be a conflict of interest. Your financial advisor is paying an ongoing licensing fee for access to the Wealth.com platform. Your financial advisor will pay this fee regardless of if you utilize this service or not. Some advisors may charge a one-time fee for the initial creation of these documents, some advisors may charge a monthly fee, while other advisors may not charge a fee at all and only provide this service as a value-added to his/her clients. Prior to utilizing this service, please discuss the fees with your financial advisor and make sure you fully understand the costs. Since each advisor determines their fee structure up to the maximum amounts allowed the presence of a conflict of interest may be different for each advisor. Regardless, it is important to know that if your financial advisor is charging for this service, your financial advisor has a financial incentive to recommend you utilize this provider. Please review section 5(A) for additional information regarding fees for this service. As part of the Master service Agreement between your advisor and Wealth Inc., your advisor is prohibited from participating in the promotion, sponsorship, sale, or otherwise recommend the services of any third-party software-based estate planning or estate document creation services other than Wealth.com. This does not include non-software-based services provided by traditional law firms. Due to this restriction, your advisor has a conflict of interest concerning where they refer you to for software-based estate planning or estate document creation services. Wealth Inc. is not a financial planner, or an investment, financial, tax, or legal advisor. The service is not intended to provide investment, legal, tax, or financial advice. The information provided by Wealth Inc., along with the content of their Service related

to legal matters ("Legal Information"), is provided for your private use, and does not constitute legal advice regardless of whether you specifically solicited the information or otherwise. Wealth Inc. provides a platform for Legal Information and self-help. If you are a user who accesses the Service with a license that allows you to create estate planning documents (“End User”), the Service is intended only to assist you in decision-making in connection with estate planning and asset management based on a finite set of data about you. Options presented are based on certain assumptions and the data we have considered. Your personal financial situation is unique and dependent on many circumstances and factors not captured by the Service, and any information and recommendations obtained through the Service may be given without knowledge of, access to, or consideration of such other circumstances and factors. Additionally, Wealth Inc. does not (i) review any information you provide for legal accuracy or sufficiency, (ii) restrict you from making your own legal conclusions (including your selection of forms), or (iii) apply the law to the facts of your situation by soliciting information from you as an attorney or in-person advisor would. Before you make any final decisions concerning your estate plan or implement any other financial strategy, you should obtain additional information and advice from a licensed attorney, accountant, and other legal and financial advisors who are fully aware of your individual circumstances. The service is not a replacement for personal advice from a licensed attorney, accountant, or other legal and financial advisors. Also, any recommendation we make may have many recommendation components that work together to achieve an optimal result. If you choose not to follow each and every recommendation, the result may not have the desired outcome. Legal Information provided by Company through its Service is not a substitute for legal advice from a qualified attorney licensed to practice in an appropriate jurisdiction. Communications between you, Wealth Inc., and your financial advisor will not be protected as privileged communications under the attorney-client privilege or work product doctrine. You are solely responsible for determining the appropriateness of using, and applicability to you of, any documents, work product, or information produced by the Service. Please review all Terms and Conditions, End User Agreements, Disclosures and Disclaimers, etc. provided by Wealth Inc. prior to employing this service. Cash Management Services INDSQUARE may make available to clients the FICA For Advisors cash management program (“FICA Program”) offered by StoneCastle Network, LLC (“StoneCastle”), an affiliate of StoneCastle Cash Management, LLC. The FICA Program allows customers the ability to protect their money by placing it in deposit accounts at banks, savings institutions, and credit unions (collectively, “Insured Depositories”) in a manner that seeks to maintain full insurance of the funds by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is applicable. Funds will be deposited within StoneCastle’s network of Insured Depositories (“Deposit Network”). StoneCastle requires $100,000.00 minimum deposit to open a FICA Program account. Clients are advised that a conflict of interest exists if we recommend the FICA Program compared to you using your own financial institution, another financial institution, or another cash management program. INDSQUARE and/or your advisor will earn a fee from StoneCastle which is paid by you if you participate in this program (Please review Item 5 – Fees and Compensation for more information regarding this fee). Your advisor will assist clients in signing up for this program and facilitating the transfer of funds between the client’s like-named accounts. You are under no obligation to act upon any of the recommendations made by your Advisor or by INDSQUARE itself. Please make sure to review StoneCastle Network, LLC’s FICA for advisors account application and Terms and Conditions in its entirety prior to engaging in this activity. Johnson, Kendall, and Johnson Inc. (Hereby referred as “JKJ” or “Company”) INDSQUARE may introduce you to JKJ, a privately owned, independent insurance brokerage firm. Over the last 65-plus years, JKJ has grown to be acknowledged as one of the premier insurance brokerage firms in the United States. JKJ’s capabilities have also expanded throughout the world, giving them a global perspective that they apply to their risk management strategy. JKJ works with clients ranging from Fortune 1000 companies to sole proprietorships to families, but their commitment remains the same. INDSQUARE advisors (hereby referred to as the “Broker”) who refer clients to JKJ warrants and represents that he/she is a duly licensed broker or agent pursuant to the laws of the State wherein Broker is located and wherein it conducts business, and desires to effect and/or continues to effect insurance coverages for its clients through the Company, in accordance with the laws and regulations of any state in which Broker operates. JKJ requires the Broker to maintain Errors and omissions (“E&O”) coverage based on JKJ’s Terms of conditions. INDSQUARE may refer clients seeking commercial, personal, or employee benefits insurance coverage to JKJ. INDSQUARE primarily utilizes the Company for employers seeking to establish group health insurance coverage to provide a best-in-class experience for their employees in addition to reducing the long-term costs of insurance. This arrangement creates a conflict of interest as the Broker receives financial incentives for referring you to the Company. In consideration of similar arrangements with other Insurance Brokerage firms, this commission may be higher or lower than what other insurance brokerage firms may offer for the same type of referral, which could cause the advisor to refer you to the Company over other insurance brokerage firms. Please review Section 5(A) which provides more information regarding the Broker’s commission split. Rocket ProSM TPO INDSQUARE may have some reps who hold a Nationwide Mortgage Licensing System number (“NMLS”) as a Mortgage Loan Originator (“MLO”). The Nationwide Mortgage Licensing System is a centralized online database that mortgage and finance regulatory agencies use to maintain state licensing programs. The database then creates their NMLS numbers, assigning unique identifiers to mortgage loan originators and lending companies. When Congress passed the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (“SAFE Act”), it required states to pass legislation mandating that MLOs be licensed. In addition, the SAFE Act required state agencies to participate in and share licensing information through NMLS. MLOs must complete 20 hours of educational training, pass a national mortgage test, credit report review, and pass an FBI criminal background check to get their license through NMLS. In addition, MLOs must complete 8 hours of continuing education annually to maintain their state license(s). NMLS also has a free, public facing portal (https://NMLSConsumerAccess.org) where anyone can look up any licensed MLO to check their status and credentials. You can see their licenses and where they’re authorized to do business. INDSQUARE advisors who hold an NMLS number may discuss lending products with you. Advisors with an NMLS number can originate Mortgages and some other home loan products. This is accomplished by partnering with Rocket ProSM TPO. The Rocket ProSM TPO application is owned and operated by Rocket Mortgage, LLC, 1050 Woodward Avenue, Detroit, MI 48226. Rocket ProSM TPO provides convenient access to technology, resources, products, and competitive pricing. Advisors who hold an NMLS number may receive additional commissions from Rocket ProSM TPO for their role as an MLO. This may create a conflict of interest for clients, as those advisors will be less likely to refer you to an outside lender in which they will not receive commissions, regardless of whether another lender has lower rates. The Advisor also has a conflict of interest when recommending any refinance of existing loans, as this would generate additional commissions. Commissions generated by this activity are above and beyond any Advisory Fees, Insurance Commissions, or any commissions generated by commissionable securities business. Cryptocurrencies (herein referred to as “Digital Assets”) Cryptocurrency is digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Cryptocurrency is a speculative investment and is not currently defined as a security. The speculative nature of cryptocurrencies notwithstanding, Independent Financial Advisors of INDSQUARE may recommend cryptocurrency exposure for diversification purposes in the portfolios of some of our clients. Investments in cryptocurrencies involve substantial risks and are subject to the potential for liquidity constraints, extreme price volatility, and complete loss of principal. Clients who invest in cryptocurrencies should be prepared to bear a substantial or total loss of capital and there can be no assurance that the investment objectives of any client will be achieved. INDSQUARE may also recommend “Cryptocurrency-related products,” which refers to investment securities that either directly purchase cryptocurrencies or are involved in the cryptocurrency space, such as through mining cryptocurrency, investing in companies that develop and use blockchain technology, etc. Certain cryptocurrency- related products that are approved for use, that do not directly invest in cryptocurrencies, can be purchased in a similar manner as other equities within either brokerage, SAM, or SWM accounts. Cryptocurrency- related products that directly invest in or hold cryptocurrencies as underlying holdings are also available for purchase, but they require additional suitability requirements. Although Cryptocurrencies have not been deemed a “security”, Cryptocurrency-related products containing or related to cryptocurrencies (exchange-traded funds, exchange-traded trusts, equities, etc.) could be deemed a security. Please note that not all Cryptocurrency-related products are approved for use. If you are interested in Cryptocurrency related products, please discuss with your advisor which products are available through our unaffiliated third- party Broker/Dealer. INDSQUARE may direct clients of Independent Financial Advisors to HeightZero, LLC ("HZ"), a third-party technology company that is a fully owned subsidiary of BitGo Holdings, Inc. (hereby referred to as “BitGo”). HZ has developed a proprietary turnkey digital asset management software platform that provides financial advisors, and their clients, access to BitGo’s platform to buy and sell blockchain-based, eligible, digital assets through one convenient dashboard (the "HZ TDAMP"). The HZ TDAMP allows for trading, account monitoring, portfolio management and rebalancing, development, and execution of different trading strategies, and reporting of customer positions and transactions. HZ provides access to one or more third-parties for various services; including, but not limited to, website hosting, web-based security protection, etc. HZ does not provide Anti-Money Laundering (“AML”) or Customer Identification Program (“CIP”) services, investment advice, and/or tax related services. Custody services are provided by BitGo, subject to a separate custodial service agreement, terms and conditions, privacy policy, or other agreement between BitGo and INDSQUARE or INDSQUARE’s customers. Custody of the digital assets purchased for or by clients will be maintained by BitGo pursuant to the written instructions of each of INDSQUARE’s clients. Custody of any cash deposited by such customers will be held in an account for the benefit of INDSQUARE’s client as provided for by BitGo. Neither HZ nor the HZ TDAMP will take custody of customer cash, funds, or eligible digital assets at any time. Accounts opened at HZ are established by an individual account level agreement. Clients who utilize HZ will be charged additional fees above the stated advisory fees. Clients are advised that a conflict of interest exists when your advisor recommends this provider. HZ provides a platform in which INDSQUARE and its IFAs can charge an ongoing advisory fee for the management of eligible digital assets. The costs associated with HZ and HZ TDAMP may be higher than other platforms. The costs associated with the HZ TDAMP technology, which includes several types of fees, will be passed on to you, the client. These fees will reduce your overall returns. Your advisor’s management fee will not exceed those of our maximum advisory fee stated in Item 5 Fees and Compensation; however, the total costs associated with the management of this account may exceed that of our maximum advisory fee allowed once all fees are considered for all third-party fees that are passed on to you. Please note that clients can purchase these assets on their own direct through third-party custodians with minimal to no costs. Please review Item 5 – Fees and Compensation for more information regarding these fees that were discussed. Clients should discuss with their advisor alternative options in which the advisor may consult on digital assets that are held by the client at third-party custodians. Assets, in which the advisor consults on, may be considered an asset under advisement vs. regulatory assets under management. The costs associated with consulting on assets held by third-party custodians may reduce your overall costs by eliminating third-party platform fees. Under consulting arrangements, the client is free to accept or reject any recommendation from your advisor, and the client acknowledges that they have the sole authority regarding the implementation, acceptance, or rejection of any recommendation or advice from their advisor. For more information on these services, please review the Financial Planning and Consulting section of this disclosure. Self-Directed Brokerage Accounts (“SDBA”) A self-directed brokerage account (“Self-Directed account”) is an account created by a participant (i.e. the client) of an employer sponsored plan which is then held by the plan administrator, but the participant has, in effect, their own brokerage account in which all transactions are made at their direction. Not all retirement plans permit SDBA programs. SDBA allows the participant to direct the investments in the account or in some cases, to appoint an adviser. Assets held in the SDBA are considered plan assets under ERISA but are not supervised or reviewed by the plan fiduciaries. INDSQUARE may refer clients to third parties to offer advisory services within SDBA programs. INDSQUARE may also act as the Investment Adviser to offer SDBA advisory services through plan sponsors, such as fidelity. Fidelity offers plan participants this service through Fidelity’s BrokerageLink program, in which the participant either directs the investments in the account themselves or they can assign an adviser to their SDBA. In situations where INDSQUARE refers advisory business to a third-party, INDSQUARE will refer SDBA business to either The Pacific Financial Group Inc. (“TPFG”) and/or Absolute Capital Management, LLC. INDSQUARE has no financial benefit in referring advisory business to one of these advisers over the other based on the referral fee paid to INDSQUARE and/or our IARs. INDSQUARE may refer business to one or the other adviser based on agreements that the third-party adviser may have with the plan sponsor for your employer sponsored plan. Although INDSQUARE may not have a conflict of interest between which adviser receives the advisory business based on the referral fee, there could still be a conflict of interest based on business entertainment or gifting. INDSQUARE reduces this conflict of interest by complying with federal regulations to limit potential improprieties among IARS and third parties. In addition to the noted conflict of interest, other conflicts may exist. Among these conflicts is that INDSQUARE and its IARs will receive a referral fee from the third-party adviser. By receiving this compensation, your advisor has a direct financial benefit in you hiring a third party, which will increase your total costs within your employer sponsored plan, and in some cases, these fees can be substantial. For additional fee information please review Item 5 – Fees and Compensation under the Third-Party Adviser fees and the SDBA section. C. Client-Tailored Services and Client-Imposed Restrictions INDSQUARE tailors a program for each individual client. This program will typically include an interview session to get to know your specific needs and requirements and may also include a more formalized plan that will be executed by us on your behalf. You may impose restrictions on investing in certain securities or types of securities in accordance with your values or beliefs. These requests must be made in writing and if the restrictions prevent us from properly servicing your account or would require us to deviate from our standard suite of services, we reserve the right to end our relationship with you. D. Wrap Fee Programs INDSQUARE provides investment management services as the sponsor and manager of the Independence Square Advisors Wrap Program (the “Wrap Program”). Accounts in the Wrap Program are charged a single, bundled (“wrap”) fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. INDSQUARE receives a portion of the wrap fee for its investment management services and participants in the Wrap Program may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. Additional information about the Wrap Program is available in our Wrap Brochure, which appears as Part 2A Appendix 1 of our Form ADV. E. Assets Under Management As of March 27, 2024, INDSQUARE had $1,198,796,129 in regulatory assets under management, all of which are managed on a discretionary basis. As of March 28th, INDSQUARE also had $712,033,706 in assets under advisement.