A. Firm Information PathWise (the “Advisor”) is a registered investment advisor located in the State of California and become federally registered with the SEC as of June 14, 2021. PathWise was founded in December 2014 and is owned and operated by Chief Executive Officer and Chief Compliance Officer Ryan P. Wells and Chief Investment Officer Arek Puzia, CPA. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by PathWise. B. Advisory Services Offered PathWise offers investment advisory services to individuals, high net worth individuals, pension plans in California and other states (each referred to as a “Client”). Investment Management Services PathWise provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and planning services. PathWise works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. PathWise will then construct a portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. Where appropriate the Advisor will also utilize individual stocks, bonds, and limited partnerships to meet the needs of its Clients. PathWise’s investment strategy is primarily long-term focused, but where appropriate the Advisor will buy, sell, or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. PathWise will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. PathWise evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. On occasion and in meeting with the objectives, PathWise will recommend, redistributing investment allocations to diversify the portfolio. PathWise will recommend specific positions to increase sector or asset class weightings if appropriate for the portfolio. The Advisor shall recommend employing cash positions as a possible hedge against market movement. PathWise can recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Prior to rendering investment advisory services, PathWise will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective[s]. PathWise will provide investment advisory services and portfolio management services and will not provide securities custodial or other administrative services. At no time will PathWise accept or maintain custody of a Client’s funds or securities, except for the authorized deduction of the Advisor’s fees. Page 5 All Client assets will be managed within their designated brokerage account[s] or pension account[s], pursuant to the Client investment advisory agreement. Retirement Plan Advisory Services PathWise offers retirement plan advisory services to pensions and other employee benefit plans, including but not limited to 401k plans, based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Financial Planning Services PathWise will typically provide a variety of financial planning services to individuals and families, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives, and financial situation. Generally, such financial planning services will involve preparing a financial plan or render a financial consultation based on the Client’s financial goals and objectives. This planning can encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for the Client will usually include general recommendations for a course of action or specific actions to be taken by the Client. For example, recommendations could be made that the Client start or revise their investment programs, commence, or alter retirement savings, establish education savings and/or charitable giving programs. PathWise could also

refer Clients to an accountant, attorney, or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. The Advisor typically offers its Clients an ongoing financial planning engagement on a quarterly fee basis. Please see Item 5 for more details. Financial planning recommendations can pose a potential conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Furthermore, it could be in our best interest not to recommend paying down debt that would directly reduce the Assets Under Management that we manage and charge a percentage fee for. We mitigate this conflict by providing an overall plan suitable and in the best interest of the client. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to affect the transaction through the Advisor. Whenever we provide Financial Planning Services we shall: 1. Document the scope of work in an agreement. 2. Prepare a questionnaire to understand the client’s needs. 3. Conduct a reasonable level of due diligence when referring other professionals to the financial planning client. 4. Disclose any and all compensation methods we shall receive. Page 6 5. Conduct reasonable due diligence when recommending or using technologies when providing professional CFP® services to a client. 6. Periodically monitor the CFP Board’s Code of Ethics and Standard of Conduct whenever FIRM makes a recommendation for the Financial Planning client to utilize the services of a third party as mentioned above, FIRM shall:
• Have a reasonable basis for the recommendation or Engagement based on the person’s reputation, experience, and qualifications.
• Disclose to the Client, at the time of the recommendation or prior to the Engagement, any arrangement by which someone who is not the Client will compensate or provide some other material economic benefit to the CFP® professional, the CFP® Professional’s Firm, or a Related Party for the recommendation or Engagement; and
• When engaging a person to provide services for a Client, exercise reasonable care to protect the Client’s interests. 7. When selecting or using and recommending technology FIRM shall document the due-diligence process which will include:
• Exercising reasonable care and judgment when selecting, using, or recommending any software, digital advice tool, or other technology while providing Professional Services to a Client.
• Having reasonable level of understanding of the assumptions and outcomes of the technology employed.
• Having reasonable basis for believing that the technology produces reliable, objective, and appropriate outcomes. The CFP® professionals of FIRM will also review the complete CFP Board Code of Ethics and Standards of Conduct and the Practice Standards to ensure proper implementation within the firm. C. Client Account Management Prior to engaging PathWise to provide investment advisory services, each Client is required to enter into an investment advisory agreement with the Advisor that defines the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services generally include:
• Establishing an Investment Policy Statement – PathWise, in connection with the Client, will assist in developing investment goals and objectives and the strategies to achieve those goals.
• Asset Allocation – PathWise will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – PathWise will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – PathWise will provide investment management and ongoing oversight of the Client’s portfolio and overall account. D. Wrap Fee Programs PathWise does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by PathWise. Page 7 E. Assets Under Management As of December 31, 2022, PathWise manages the following assets: Assets Under Management Assets Discretionary Assets $118,281,000 Non-Discretionary Assets $7,028,000 Total $125,309,000 F. Assets Under Advisement As of December 31, 2022, PathWise advises the following assets: Assets Under Advisement Assets Non-Discretionary $ $72,010,998