FIRM DESCRIPTION Bamboo Robo Advisor Inc. (hereinafter referred to as “Bamboo Robo Advisor”, “we”, “us”, or “our firm”) is a Delaware corporation with its principal office located in New York, NY dba WealthGap in the State of New York. The President and CEO of the company is John Zhang. As a registered investment adviser, we are a fiduciary to you, our client, meaning we have a fundamental obligation to act and provide investment advice that is in your best interest. Should any material conflicts of interest exist that might affect the impartiality of our investment advice, they will be disclosed to you in this Brochure. We urge you to review this Brochure carefully and consider our qualifications, business practices and the nature of our advisory services before becoming our client. As of December 31, 2019, Bamboo has no assets under management. Clients may request more current information at any time by contacting our firm. 4.A Bamboo Robo Advisor sponsors a Wrap Fee Program, WealthGap Management Program, as described in this Wrap Fee Brochure. Our wrap fee accounts are managed on an individualized basis according to the client’s investment objective, financial goals, risk tolerance, etc. Individual investment strategies will be selected based upon the client’s investment goals, objectives, time horizon, liquidity needs, and risk tolerance. Bamboo Robo Advisor will provide recommendations on equities (common stocks and equivalents) and exchange traded fund. Bamboo Robo Advisor may also utilize, where appropriate, options contracts to hedge against risk. WealthGap Management Program accounts are executed through Alpaca Securities LLC. Alpaca Securities LLC provides execution, custody and other brokerage services for accounts established through the WealthGap Management Program. Therefore, you are required to establish brokerage account(s) through Alpaca Securities LLC. Separate accounts are maintained for you, and you retain all rights of ownership of your accounts (e.g., the right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). Bamboo Robo Advisor will manage investments on a discretionary basis exclusively through its proprietary iOS application WealthGap. This means that once the advisor and client enter into an advisory agreement, the designated advisor will make the day-to-day decisions regarding the purchase and sale of securities without obtaining the client’s consent for each individual transaction. The interaction between clients and the advisor is conducted on an interactive Bamboo Robo Advisor Inc. Form ADV Part 2A Appendix 1 5 website. Clients must provide us with written authorization to exercise this discretionary authority. Discretionary authority is limited. We do not have access to client funds and/or securities with the exception of having advisory fees deducted from your account and paid to use by the account custodian. Clients may also place reasonable limitations on the discretionary power granted to us so long as the limitations are specifically set forth or included as an attachment to the client agreement. (Please see Item 16, Investment Discretion, in the separate Bamboo Robo Advisor Disclosure Brochure for additional information concerning discretionary authority.) Our advisory services are managed by certain individuals who have registered with Bamboo Robo Advisor as its investment adviser representatives (“advisors”). Clients should refer to such advisor’s Form ADV Part 2B (the “Brochure Supplement”) for more information about their qualifications. Bamboo Robo Advisor’s advisory services are tailored to the needs of our clients based on their individual investment objectives, risk tolerance, cash or income needs, and any investment restrictions. Although Bamboo Robo Advisor seeks to accommodate any reasonable investment restrictions or guidelines set by our clients, we may decline to accommodate certain investment restrictions that are incompatible with our firms’ investment philosophy or that may have an adverse effect on our ability to manage your account. Bamboo Robo Advisor manages each Client account, via WealthGap, on an individualized basis. Bamboo Robo Advisor enters into formal written agreements with our clients setting forth the terms and conditions under which we will provide our advisory services (the “Investment Management Agreement”). The Investment Management Agreement sets forth the scope of the services to be provided and the compensation we receive from the client for such services. The Investment Management Agreement may be terminated by either party in writing at any time by giving thirty (30) days signed written notice to the other party. 4A. For the Services provided in the Program, you will pay to us an annual asset-based fee (the “Program Fee”) at the rate of 1% (the “Program Fee Rate”) based on the asset value of the account. The Program Fee Rate is nonnegotiable and

payable monthly in arrears. The Program Fee is subject to change from time to time, upon notice to you. Your continued use of our services will constitute your agreement to any such change. The Program Fee is the sum of:
• Investment management fee based on average daily account balance of assets under management; and
• Ancillary services such as brokerage services, trade execution, clearance and settlement of transactions and custody of assets. Bamboo Robo Advisor Inc. Form ADV Part 2A Appendix 1 6 The Program Fee is prorated and charged quarterly, in arrears, based upon the market value of the average daily account balance of the securities portfolio over the preceding quarter. Since the asset-based fee is determined by average daily account balance, if assets are deposited into or withdrawn from an account after the inception of a month, the base fee payable with respect to such assets is adjusted accordingly. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the Investment Management Agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding portion of the fee is charged to the Client. Services Covered by the Program Fee. The primary purpose of the investment management program is to provide you with ongoing fiduciary investment advice and guidance under the terms of the program. The Program Fee you pay covers the Program’s services, including investment advice and guidance under the Program, as well as brokerage and custodial services relating to your account, certain services that are normally be available in certain types of securities (brokerage) accounts will not be available to your account enrolled in the Program, including margin lending, check writing, Visa cards and client order entry. The full amount of the Program Fee payable under the Investment Management Agreement will be charged in accordance with the terms of Investment Management Agreement, regardless of the amount of transactions effected in your account. Termination. The Investment Management Agreement with our clients may be terminated by either party at any time upon thirty (30) days written notice. Upon termination of our status as the client’s investment adviser, Bamboo Robo Advisor will not take any further action with respect to the client’s account(s) unless specifically notified by the client in writing. Clients will be responsible for instructing their custodian and monitoring their account for the final disposition of assets. Upon receipt of a proper notice of termination from the client, as described in the Investment Management Agreement, any earned unpaid fees will be billed on a pro-rata basis based on the amount of work performed by us up to the point of termination. 4.B The WealthGap Management Program allows our clients to pay a specified fee for investment advisory services which includes the cost of execution of transactions. The advisory services may include portfolio management, and the fee is not based directly upon the transactions in the client’s account(s). We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. By participating in our wrap fee program, the WealthGap Management Program, you may end up paying more or less than you would through a non-wrap fee program, where trade execution costs are passed directly to you by the executing broker. Bamboo Robo Advisor Inc. Form ADV Part 2A Appendix 1 7 4.C Fees and Expenses Not Covered by the Program Fee. The Program Fee does not cover:
• Mark-ups, mark-downs, spreads, underwriting fees or selling concessions or other transaction charges with respect to any principal transaction effected by us.
• If applicable, commissions, markups or markdowns in connection with principal transactions effected for your account.
• Transfer taxes.
• ETF fees and expenses.
• Exchange, alternative trading system fees, required SEC fees or similar fees charged by third parties, including issuers.
• Electronic fund, wire and other Account transfer fees.
• Any other charges imposed by law or otherwise agreed to with regard to the account. To fully understand the total costs associated with their investment portfolio, clients should review all the fees charged by exchange traded funds, our firm and others. Clients may incur charges imposed by third parties other than Bamboo Robo Advisor in connection with investments made through the account, imposed by law or otherwise agreed to with regard to the account. 4.D Bamboo Robo Advisor does not recommend or offer the wrap program services of other providers. Our investment advisory representatives receive a portion of the advisory fee that you pay us, either directly as a percentage of your overall fee or as their salary from our firm.