Our Advisory Business Starship Securities is a registered investment adviser with the Securities and Exchange Commission (“SEC”) and is notice filed in all fifty states. Starship was formed on October 2, 2019. Additional information about Starship is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Starship is 306945. The SEC’s website also provides information about any persons affiliated with Starship who are registered, or are required to be registered, as investment adviser representatives of Starship. Starship is a registered investment adviser (“RIA”) that offers a wrap fee program to its advisory clients (each a “Client,” and collectively, “Clients”) through an online web-based application. Starship is a privately held company headquartered in New York, New York. In August 2022, the Firm’s parent company, Brighter Financial, was purchased by Optum Financial, Inc. Information about Starship’s organizational and ownership structure is provided on Part 1 of Starship’s Form ADV, which is available online at http://www.adviserinfo.sec.gov. Services Starship provides web-based discretionary investment advisory services to separately managed accounts of individuals in a program that bundles or “wraps” services together and charges a single fee based on the value of assets under management (the “Program”). The services included in the wrap are advisory, trade execution, clearance and custody and reporting. Starship interacts with its Clients primarily through a software application that is available through mobile platforms, which can be downloaded at https://www.starshiphsa.com/ (the “Application”). The advisory services are delivered solely through the Application. Starship does not provide investment advice in person or over the phone or in any manner other than through the Application. Additional information about Starship’s products and services is provided in Starship’s Form ADV Part 1 available at http://www.adviserinfo.sec.gov. Starship encourages visiting its website, https://www.starshiphsa.com/, for additional information. Clients utilize the Application to access automated, discretionary investment advice from Starship, which seeks to help them meet their financial goals, within their respective investment risk and financial parameters. Each Client inputs their personal information, including age, financial resources, and investment goals and objectives via an interactive questionnaire within the Application. The client will be asked to answer the following questions: What is your investing experience? When will you use your invested dollars? How much investment risk can you handle? What’s your annual income? What’s your total net worth? Starship Securities ADV Part 2A March 2023 Page 5 of 6 What’s your liquid net worth? What’s your employment status? Starship’s algorithm will employ a scoring system using the above information to create a total score for each client. That total score will be used to recommend a portfolio for the client. If the client accepts this portfolio recommendation, the Application will then automatically invest Client assets in the recommended portfolio. Starship offers three different portfolios constructed using low cost, exchange traded funds (“ETFs”). Starship offers three model portfolios - Conservative, Balanced and Growth. Starship provides investment advice only with respect to a limited type of investment, ETFs. Clients should understand the portfolios and software and rely upon the information provided by the Client and Starship does not capture any additional information not covered in the questionnaire in making its risk assessment and providing its investment advice. Starship creates investment portfolios and directly manages accounts for Clients. Starship has the authority to manage Client accounts on a discretionary basis. Clients should understand the Starship Wrap Fee Program is a discretionary investment advisory program, and not a self-directed brokerage service. Unlike self-directed brokerage accounts, Starship Clients do not enter individual buy and sell orders for specific securities to be executed at particular times. Rather, Starship places orders to buy and/or sell securities consistent with the discretionary authority granted to it by Clients, which includes, among other things, the authority to select which securities to buy and sell and when to place orders for the execution of securities. If you want to control the specific time during the day that securities are bought and sold in your account (e.g., you want the ability to “time the market”), you should not use Starship’s service. Starship trades in Client accounts for any number of reasons, including in response to Client actions such as deposits or withdrawals. Starship also trades in order to rebalance Client accounts, to change investment options, or otherwise to further the investment objectives that Clients specify via Starship’s Application. Clients are obligated to update their information through the Application promptly if there are changes to their financial situation, goals, objectives, personal circumstances, time horizon or if other relevant information changes or becomes available. The investments in each Client’s account are held in a separate account, as explained further below, in the name of the Client at an independent custodian, and not with Starship. All accounts managed through the Application are required to use DriveWealth LLC (“DriveWealth”) as the independent custodian, as well as for clearing and execution services. The ETF shares purchased or sold on behalf of a Client and/or held in Client accounts may be either whole shares or fractional shares. Starship enables dollar based investing, whereby Starship can buy a fixed dollar amount rather than whole shares. Starship aggregates all dollar based purchases and places whole share orders for executions.

Thereafter, Starship allocates the fractional shares to the individual Client accounts. Fractional shares, however, are typically not transferrable outside of a Client’s investing account because the financial system in the United States currently is structured only to accommodate transfers of full shares. As a result, fractional shares may not be marketable Starship Securities ADV Part 2A March 2023 Page 6 of 7 or transferrable to another brokerage account. In the event of a liquidation or transfer of the assets in a Client’s Investing Account to another account, Starship may convert such fractional shares to cash. Clients will receive Starship’s Advisory Agreement, which further details the services Clients will receive, fees charged to Clients, and the conditions of the Starship-Client relationship. Importantly, Starship does not provide overall financial planning services, nor does it provide legal or tax advice. Brighter Financial Inc. offers a Health Savings Account (“HSA”), which enables its Clients to save, spend and invest in their healthcare. Brighter Financial Inc. aims to maximize the growth of its Client funds by providing higher interest rates and automatic investing by Starship in low cost, and reputable ETFs. A Client that wishes to open an investment account (as defined below) with Starship, must select the investment option in the Application. Every Client that selects the investment option in the Application has two accounts with Brighter Financial Inc. - one for savings (the “spending account”) and one for investing (the “investment account”). Funds from a Client’s spending account that meet a designated overflow threshold are added to their investment account and are automatically invested in portfolios of ETFs. Wrap Fee The Adviser sponsors and acts as the portfolio manager for its wrap fee program. Starship exercises discretion over Client accounts or Client assets. Starship automatically invests Client assets in ETF portfolios for clearing and execution through DriveWealth. The Program offers three model portfolios. The Application will suggest a model portfolio for each Client based upon responses to Starship’s investor questionnaire, which includes questions regarding a Client’s investment objectives and risk and financial parameters. For example, more conservative risk scores are typically associated with a portfolio that has a greater percentage of assets allocated to fixed-income and cash asset classes, rather than to the equity asset class. However, more aggressive risk scores are typically associated with a portfolio that has a greater percentage of assets allocated to the equity asset class, rather than to fixed-income and cash asset classes. A Client may select an alternate model and adjust their model selection once per month based on their investment objectives and risk and financial parameters. If a Client wishes to select an alternate model, the Application will generate a prompt to inform them that the portfolio chosen was not recommended based upon their responses to the investor questionnaire in the Application. Starship Securities ADV Part 2A March 2023 Page 7 of 8 A Client is required to acknowledge the risk of selecting an alternate model before the change is affected in the Application. If Starship recommends a Conservative portfolio to a Client, and the Client selects the Growth portfolio, they will receive a prompt which indicates that the selected portfolio has greater risk than the portfolio that was recommended based on the Client’s investment objectives and risk and financial parameters. The Client will be prompted to review and amend their response to the investor questionnaire in order to select the Conservative portfolio. If a Client amends their responses to the investor questionnaire, then their risk tolerance and model recommendation will be recalculated. If the newly recommended portfolio is the Balanced or Growth portfolio, then the Client’s requested change will be processed. However, if the Conservative portfolio remains the recommended portfolio, then the Client’s selection will not be processed. The ETFs that comprise Client portfolios are selected via Starship’s internal selection criteria and the model portfolios are rebalanced no less than quarterly by Starship. The securities included in each Client portfolio have been researched and approved by Starship’s Investment Committee. As of the date of this Brochure, Starship’s Investment Committee is comprised of Scott Resnick, Adam Pruden, Andy Germann, Claire Hames, and Michael Koch. Starship has engaged Hubbell Strickland Wealth Management, LLC (HSW) to provide investment consulting services to the Firm’s Investment Committee. HSW’s services include reviewing, assessing, and monitoring the investment options offered in the Application. HSW will only offer advice on the investment plan level and no investment advisory services will be offered by HSW to the individual participants. All investment decisions are solely the responsibility of the Committee. Starship’s internal selection criteria includes, but is not limited to, assessing an ETF’s exposure to a given asset class or sector, its performance relative to peer(s), its tracking differential relative to any applicable benchmark(s), its management fee, and its liquidity characteristics. ETFs themselves are managed by the relevant fund manager/sponsor. Starship does not manage, control or receive compensation from ETF or other managers. Rebalancing and initial investments are only performed during specific hours each day. There are inherent risks to the use of model portfolios which may result in loss of capital. Each Client’s account performance will be calculated through a time-weighted return. The Firm does not offer accounts that are not managed in a non-wrap program. Assets Under Management As of December 31, 2022, Starship had $1,050,795 assets under management all of which are managed on a discretionary basis.