General Description of the Company Savvy Financial, Inc. (“Savvy Financial” or “SavvyFi”), a multi-state investment adviser registered with the Securities and Exchange Commission (SEC), was founded in August 2018 and is headquartered in Franklin, Tennessee. Like all registered investment advisers, SavvyFi is required to inform Clients that registration with the SEC does not imply a certain level of skill or training. Description of Advisory Services Offered 529 Plan Services SavvyFi’s objective is to help Clients (“Clients”) plan for their Beneficiary’s (“Beneficiary” or “Student”) anticipated qualified education expenses by using algorithms to attempt to forecast investment returns and, if applicable, college cost growth based on the Beneficiary’s investment horizon. In addition, SavvyFi’s objective is to help Clients better understand the relationship between the Client’s expected contributions and achievement of the Client’s qualified education savings goal. SavvyFi’s advisory services (“Services”) are limited to providing advice to Clients that are saving, or intend to save, for college or existing student debt with a 529 Education Savings Plan (“529 Plan”). Although SavvyFi’s algorithms are focused on college cost savings; SavvyFi’s 529 Plan services include all qualified education expenses. Clients who opt to use our program for K-12 education expenses and/or student loan repayment will be subject to the college saving Enrollment Date algorithms. As a result, the algorithms will use the Beneficiary’s age as the basis for investing, which may not meet the Clients’ particular investment objective. Clients will include individuals and employers who add SavvyFi’s 529 Plan software offering to their benefit plan. The scope of SavvyFi’s Services does not include advice on 529 Prepaid Plans or any other outside education savings vehicles. SavvyFi’s Services generally include the following:
• Assistance with 529 account setup;
• If applicable, projection of future average net price for four-year in-state and private colleges in the United States;
• Tracking and projection of the Client’s future savings based on past and anticipated future savings rates. As a digital investment adviser, SavvyFi administers its Services exclusively through its interactive online software application (“Online Software”), which can be accessed on the firm’s website at www.savvyfi.co (“Site”). This is different from many “traditional” investment advisers that administer advisory services primarily through personal interaction with human investment adviser representatives. Each Client must acknowledge willingness to conduct advisory services with SavvyFi electronically through SavvyFi’s Online Software. In addition to SavvyFi’s Services, SavvyFi gives Clients access to a gift contribution feature (“Gift Feature”) in the Online Software that is intended to help Clients source contributions to their 529 account(s) from third parties, who may or may not also be Clients of SavvyFi. SavvyFi’s Clients also receive access to a cashback rewards feature (“Cashback Rewards Feature”), provided by a third-party vendor, which allows clients to receive cash back when shopping at participating merchants. 5 | P a g e Explanation of Standard (Non-Tailored) Services SavvyFi chooses the Provider and Program Manager who is used for the Client’s 529 Plan accounts. The current 529 Plan Provider is the State-of-Utah-based my529 Plan, and the standard recommended investment option within that plan is Vanguard’s Enrollment Date investment options (“Enrollment Date Option”). Through standardizing the 529 Plan and investment option, SavvyFi

anticipates that significant burdensome complexity will be removed from the Client’s decision process, which will help Clients start their 529 account earlier and maximize their time available to pursue investment growth. To facilitate ease of account signup, each Client must acknowledge and agree to give SavvyFi full power and authority (discretionary authority) to enter into and perform the terms and conditions of Provider’s account agreement in a fiduciary capacity on behalf of the Client. The Client agrees to provide SavvyFi discretionary authority over the 529 Plan accounts established. This includes the ability to invest in certain securities or types of securities or create our own investment models. The investments recommended by SavvyFi are part of the overall investment plan (“Investment Plan”) for the Client. SavvyFi’s Services include advice on 529 Plans, specifically enrollment date investment options. Tuition reimbursement and student loan repayment programs are also services offered. Investing in a 529 plan may offer the Client special tax benefits. These benefits vary depending on the state and the 529 plan. Each Client must acknowledge and agree to the fact that he or she may be sacrificing certain state tax benefits by adopting SavvyFi’s Investment Plan. Prospective Clients may wish to consider whether their or their Beneficiary’s home state provides its taxpayers with favorable state tax or other benefits that may only be available through investment in their home state’s 529 plan. Promissory Note and Offerings In addition to the above mentioned services offered to clients, SavvyFi previously offered convertible promissory notes ("note”) to qualified investors*, the proceeds of which were used for firm development, technology, and staff wages. Neither the Client’s technology fee nor the custodian services fees are increased or decreased by any note offering. This presents a conflict of interest and gives us an incentive to recommend the note investment based on the proceeds received, rather than on a client’s needs. There are currently no open promissory note offerings. All outstanding promissory notes have been converted to preferred equity holders. *Qualified Investors (aka Accredited Investor) in the United States is a person or applicable entity that meets certain financial or sophistication criteria that should, in most cases, allow such an investor to absorb or anticipate a complete loss related to an investment.. SavvyFi does not provide tax or legal advice; the Client is encouraged to seek a tax or legal professional. SavvyFi does not represent that its Services are based on, or meant to replace, a comprehensive evaluation of the Client’s entire financial profile and circumstances. Further, SavvyFi does not represent that its Services are based on a comprehensive evaluation of all education savings options relative to the Client’s specific financial profile and circumstances. Wrap Fee Program SavvyFi does not participate in a wrap fee program; therefore, SavvyFi has no material conflicts of interest to disclose relativ e to wrap fee programs. Supervision and Management of Client Assets SavvyFi has approximately $218,269 in supervised and/or managed assets as of the date of this Brochure. SavvyFi manages assets on a discretionary basis. 6 | P a g e