MIMCO is a registered investment adviser that offers portfolio management services to clients exclusively through an interactive website1. The firm uses an interactive website in which a computer model provides investment advice to clients based on personal information each client supplies through the website. The Meta Investment Management Company Wrap Program (the “Program”) is an investment advisory program sponsored by MIMCO. Prior to MIMCO rendering any of the foregoing advisory services, clients are required to enter into a written agreement with MIMCO setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). MIMCO has been an investment adviser since January 1, 2021 and is owned by Michael Stoynov since January, 1, 2021. As of March 1, 2023, MIMCO has $3,067,807 assets under management, all of which is managed on a discretionary basis. While this brochure generally describes the business of MIMCO, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on MIMCO’s behalf and is subject to the Firm’s supervision or control. Description of the Program The Program is offered as a wrap fee program, which provides clients with the ability to invest in equity, debt, mutual funds, and/or ETF investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account agreement with Shareholders Service Group (“SSG”) or another broker-dealer that MIMCO approves under the Program (collectively “Financial Institutions”). At the onset of the Program, clients complete an investor profile through an interactive website describing their individual investment objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors pertinent to their specific financial situations. After an analysis of the relevant information, MIMCO’s website recommends an appropriate investment portfolio for the client’s assets. Clients’ investment portfolios are managed on a discretionary basis by MIMCO’s investment adviser representatives. MIMCO allocates clients’ assets among the various investment products available under the Program (stocks, bonds, mutual funds, ETFs and/or money market funds), as described further in Item 6 (below). 1 The investment adviser may provide investment advice to fewer than 15 clients through other means during the preceding 12 months in accordance with Rule 203A-2(e) under the Investment Advisers Act of 1940. Investment Management Services MIMCO manages client investment portfolios on a discretionary basis. MIMCO primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, fixed come securities and money market funds in accordance with their stated investment objectives. MIMCO tailors its clients’ investment portfolios to meet the needs of its individual clients risk tolerance, time horizon, goals, objectives, needs, and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Through its interactive website MIMCO assesses a client’s specific risk tolerance, time horizon, liquidity constraints, risk capacity and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify MIMCO if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Fees for Participation in the Program The Program is offered on a fee basis, meaning participants pay a single annualized fee based upon assets under management (“Program Fee”). Investment Management Fees This Program Fee generally varies between 0.50% and 1.50%, in accordance with the following fee schedule: PORTFOLIO VALUE BASE FEE Up to $500,000 1.25% $500,001 - $1,000,000 1.125% $1,000,001 - $10,000,000 1.00% $10,000,001 - $50,000,000 0.875% $50,000,001 - $100,000,000 0.75% $100,000,001 - $500,000,000 0.50% The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by MIMCO on the last day of the

previous billing period. If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Cash and money market funds held in the accounts is charged the same Program Fee. The Firm typically keeps limited cash in accounts, but may have a more significant cash position for a period of time initially (until the cash can be properly invested in an orderly fashion) and where the Firm determines that holding the cash in lieu of investing in securities is in the best interest of the client. Fee Comparison As referenced above, a portion of the fees paid to MIMCO are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios under the Program. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Because the Firm pays for the brokerage fees, the Firm has an incentive to engage in less transactions, or transactions that cost less to the Firm. Fee Discretion MIMCO, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as the householding of related accounts by combining the value of retirement and personal accounts. Other Charges In addition to the advisory fees paid to MIMCO, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges may include fees, attributable to margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund Program Fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and any account closing fees charged by a financial institution. Direct Fee Debit Clients provide MIMCO with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to MIMCO. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to MIMCO’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to MIMCO, subject to the usual and customary securities settlement procedures. However, MIMCO designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charge) and/or tax ramifications. Use of Margin MIMCO may be authorized to use margin in the management of the client’s investment portfolio. In these cases the fee payable will be assessed net of margin such that the market value of the client’s account and corresponding fee payable by the client to MIMCO will not be increased. Compensation for Recommending the Program MIMCO has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation. A person recommending the Program will not earn more compensation than he or she would otherwise receive if a client elected another investment management program.