A. Description of the Advisory Firm TIFIN Grow LLC (“TIFIN Grow”), a Delaware limited liability company, was formed on September 12, 2019. TIFIN Grow is registered with the United States Securities and Exchange Commission (“SEC”) under Rule 203A-2(e) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and therefore conducts business solely through an online advisory platform. The indirect parent entity of TIFIN Grow LLC is The TIFIN Group LLC (“TIFIN”), and the direct parent entity is TIFIN WealthTech LLC (“TIFIN Wealth”). TIFIN Grow LLC is a wholly-owned subsidiary of TIFIN WealthTech LLC. TIFIN WealthTech LLC, is, in turn, wholly owned by The TIFIN Group LLC. TIFIN Grow operates as part of the TIFIN Wealth platform. Dr. Vinay Nair is the Chief Executive Officer of TIFIN. B. Types of Advisory Services TIFIN Grow provides sub-advisory services to investment advisers and wealth managers (collectively, “Wealth Managers”) through its interactive web platform. Investment Advice TIFIN Grow combines the principles of positive psychology with modern wealth management to create stronger connections between people, their advisors and their wealth. TIFIN Wealth’s proprietary web-based profiling platform enables Wealth Managers to develop personality and risk profiles for their clients (“WM Clients”) based on responses to profile questionnaires made available on TIFIN Wealth’s platform. Using the personality or risk profile(s), TIFIN Grow recommends model portfolios that seek to reflect each user’s unique profile and/or risk tolerance. TIFIN Grow’s objective is to enable clients to receive personalized investment recommendations and/or analysis of stocks, exchange-traded funds (“ETFs”), and mutual funds that they can use to make investment decisions on behalf of their respective WM Clients. Wealth Managers can utilize TIFIN Wealth’s platform to send profile questionnaires to their WM Clients to generate profiles and make recommendations of investments and/or model portfolios created by third-parties. In addition, Wealth Managers can create and recommend their own model portfolios for WM Clients. Wealth Managers may engage TIFIN Grow to provide sub-advisory services to their WM Clients, as further described below. TIFIN Grow provides portfolio recommendations to Wealth Managers that they may implement on their own. In building personalized portfolio suggestions for WM Clients, TIFIN Grow, through proprietary profile questionnaires, first assesses the preferences and risk profile of the WM Client to determine a recommended allocation and exposure to risk, and further personalizes the recommended portfolios to contain specific themes the WM Client and/or the Wealth Manager have selected. Wealth Managers may also link their WM Client’s external investment accounts to the platform and analyze their holdings according to TIFIN Grow’s algorithm. Sub-Advisory Services When providing sub-advisory services to Wealth Managers, TIFIN Grow generates investment recommendations based on the profiles created for WM Clients. The Wealth Manager can elect to use TIFIN Grow’s recommendation or choose to use their own recommendation that is aligned to each WM Client’s investment objectives, risk tolerance, and other factors (collectively, “Investment

Goals”). Wealth Managers may engage TIFIN Grow to provide discretionary investment advisory services to their WM Clients, in accordance with such Clients’ Investment Goals. Risk Profiling TIFIN Grow, through the TIFIN Wealth platform, provides advanced risk tolerance questionnaire technology which is available to Wealth Managers for a monthly subscription fee. TIFIN Wealth’s proprietary web-based technology allows Wealth Managers to score their client’s risk capacity, risk preference and the portfolio risk of their current portfolio. Using this information, through the use of TIFIN Wealth’s technology, Wealth Managers can help their clients select the portfolio holdings to match their specific risk profile and Investment Goals through a combination of stocks, ETFs, mutual funds or model portfolios maintained by financial institutions that may be registered investment advisers to ETFs, mutual funds or model portfolios (“Third Party Providers”) who may pay TIFIN Wealth and TIFIN AMP LLC a sponsorship fee. Alternatively, Wealth Managers can upload and select their own custom portfolios based on their WM Client’s risk profile and Investment Goals. Models TIFIN Wealth has entered into partnerships with and receives sponsorship fees from Third Party Providers. Under these arrangements, advisers to ETFs, mutual funds or model portfolios (“Sponsored Funds”) pay TIFIN Wealth and TIFIN AMP LLC sponsorship fees in order to enhance the visibility of their Sponsored Funds on TIFIN Wealth’s platform. In addition to Sponsored Funds, TIFIN Grow’s platform includes TIFIN Grow generated models which are determined by a portfolio optimization tool that generates the model based on inputs including: asset classes, asset class constraints, certain market assumptions, correlations between asset classes. C. Client-Tailored Services and Client-Imposed Restrictions Advisory services are tailored to achieve Investment Goals, as informed by the results of one or more profile questionnaires. TIFIN Grow currently provides investment recommendations only with respect to stocks, ETFs and mutual funds that are based on the profiles generated for WM Clients. Unless TIFIN Grow has been engaged to provide discretionary investment advisory services to WM Clients of a Wealth Manager, TIFIN Grow does not have the authority to select which and how many securities and other instruments to buy or sell. Wealth Managers who engage TIFIN Grow to provide discretionary investment advisory services provide TIFIN Grow with the authority to select which and how many securities and other instruments to buy or sell for the WM Clients in accordance with such WM Client’s Investment Goals without consultation with the Wealth Managers or WM Clients on a trade- by-trade basis. Wealth Managers may impose reasonable restrictions on investing on behalf of their WM Clients in certain securities or types of securities, with any restrictions to be provided to TIFIN Grow in writing by the applicable Wealth Manager. D. Wrap Fee Programs TIFIN Grow does not participate in Wrap programs. E. Amounts Under Management TIFIN Grow has the following assets under management as of 12/31/2022: Discretionary Amounts: Non-Discretionary Amounts: Total Firm Assets: $3,939,000 $0 $,3,939,000