Trinary Capital is a privately held investment management company based in Long Beach, CA and organized as a corporation under the laws of Wyoming. Trinary is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”), operating under the Internet Advisers Exemption, and is also registered as a veteran owned business with the Small Business Administration and the Department of Veterans Affairs. Further, Trinary is a registered Service Disabled Veteran Owned Business (SDVOB) with the VA. Jeremy Horton founded Trinary in 2020 and currently owns 51% of Trinary’s voting shares. Trinary currently manages approximately $3,228,737 in client assets. Trinary provides discretionary portfolio management and investment services to retail and institutional clients via its website and online portal located at www.trinarycapital.com. Trinary generally performs advisory services for each client under the terms of an investment advisory agreement with that client. Trinary offers clients a Roboadvisory tool that utilizes a range of investment strategies, which can include stocks, Mutual Funds, ETFs, and other 40 Act Fund vehicles. Pursuant to a client’s stated investment goals, which he or she will provide to Trinary through the account sign-up process and via a detailed questionnaire which generates a risk profile for each investor based on those answers, and consistent with the stated investment objectives, policies and restrictions of any investment strategy or strategies that may best fit that client’s chosen investment goals, Trinary exercises exclusive investment advising discretion regarding the purchase or sale of securities for clients

in accordance with the Internet Advisers Exemption. Additional detail about Trinary’s investment strategies is provided in Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, below. Trinary’s Roboadvisory algorithmic client risk tool bases its advice on information provided by clients through the online questionnaire regarding, among other things, their age, marital and family status, annual income, employment status, liquid net worth, debt and other investments, investment goals and investment experience. The algorithmic risk tool is provided to Trinary through Quartz Partners. Clients should understand that the RoboAdvisory offered by Trinary Capital may not provide clients with an all- encompassing financial plan. Instead, it is intended to advise clients on how to realize their financial goals selected by the client through their answers to Trinary’s online questionnaire. Trinary’s investment recommendations are VERY dependent on clients stating accurate information in response to questions. Should clients answer with inaccurate or incomplete information or fail to update promptly the information provided to Trinary when situations change, the quality and efficacy of Trinary’s recommended financial advice through its Roboadvisory platform could be materially impacted. In addition, there may be other information about a client’s personal financial situation not covered on Trinary’s website questionnaire. Because clients do not generally communicate with Trinary’s advisory team directly and thus cannot update their financial situation without updating their profile on the website or re-taking the questionnaire, clients should take into account these limitation on Trinary’s services, which is a function of Trinary Capital providing automated services/recommendations online through its RoboAdvisory portal.