Herring RIA Sub, LLC ("PB Adviser") is an investment adviser registered with the Securities and Exchange Commission ("SEC"). PB Adviser was registered as an adviser in 2021 and is a wholly owned subsidiary of Herring Labs, Inc. (doing business as "Playbook"). PB Adviser offers an automated investment advisory service that provides portfolio management services and goals-based planning tools exclusively through an online interface and application accessible via mobile devices. PB Adviser‘s automated investment advisory service is an optional benefit that is part of a membership program offered by Playbook (the "Membership Program"). Playbook is not a registered investment adviser. The Membership Program – Standard Features PB Advisor offers two tiers of membership to clients: Playbook Essential and Playbook Plus. Core components and investment strategies of the Membership Program are the same for both tiers and are described below. Additional features of Playbook Plus affect implementation of the investment models and are described in Item 8. Clients may choose to upgrade, or downgrade, their membership level at any time. Clients who choose to upgrade will be charged a pro-rated amount, whereas clients who choose to downgrade will maintain their Plus membership until the next billing date. Membership fees are described in Item 5. Portfolio Management Services PB Adviser uses the Playbook platform (“platform”) to collect certain profile information to help clients determine an appropriate investment strategy. Based on each client‘s stated goals, risk tolerance and time horizon, PB Adviser will calculate a risk score that it will use to match the client with a portfolio of exchange-traded funds ("ETFs") and corresponding asset allocation model (each, an "ETF Model"). The ETF Models offered by PB Adviser seek to use highly liquid, low-fee ETFs. The asset allocation for each ETF Model is determined by PB Adviser based on historical rates of return. Although Playbook will gather additional information to assist with the account enrollment process, the ETF Model allocation is currently based solely on the client’s risk score. Clients may not override the specific ETF choices or place restrictions on the use of certain ETFs. However, clients have the ability to customize their ETF Model by changing their risk score and asset allocation via the risk allocation tool. Clients who wish to invest in the ETF Model will enter into an investment management agreement with PB Adviser and open an advisory account ("Advisory Account"). PB Adviser will have discretionary authority to manage the assets in each client‘s Advisory Account. Neither Playbook, nor PB Adviser, will have investment discretion or authority over any other bank or investment accounts that may be linked through the Playbook platform. Goals-Based Planning Tools Clients participating in the Membership Program are asked to connect their bank and investment accounts, including any Advisory Accounts, through the platform. The platform provides clients with goals-based planning tools to create automatic monthly transfers across a client‘s various accounts with a view towards maximizing contributions to tax advantaged accounts. Based on inputs provided by the client (such as goals, targets, destination accounts, and available monthly budget), PB Adviser will recommend how much money to move into each client account based on the client‘s selected priorities. Clients are not required to transfer assets in accordance with the goals-based plan offered by Playbook. Clients may override or change transfer instructions at any time. Playbook will instruct its payment service provider, Dwolla, to transfer funds on a monthly basis in accordance with the instructions provided by each client through the platform. Playbook will only transfer available cash among linked accounts in accordance with client instructions. As of December 31, 2023, PB Adviser managed regulatory assets totaling

$ 2,170,223 on a discretionary basis. As of December 31, 2023, PB Adviser does not manage any assets on a non-discretionary basis. Investment Strategies - Membership Tiers PB Advisor offers two tiers of membership to clients: Playbook Essential and Playbook Plus. The models offered to clients in either tier is the same, but the implementation will differ. Clients who choose to signup for Playbook Plus will receive the following, additional features: 1. Tax Loss Harvesting: Tax loss harvesting is the process of selling an investment that has experienced a loss in order to offset gains from other investments or income, thus reducing the amount of taxes owed. PB Advisor will monitor clients’ accounts, and when there is an opportunity to rebalance and harvest losses, then PB Advisor will sell the specified tax lots at a loss, and replace those ETFs with slightly different ETFs that can still exhibit similar risk characteristics. Tax Loss Harvesting will typically only occur when portfolios surpass their drift threshold, or when a significant cash flow event occurs in the portfolio. Note that this feature is only available for accounts that meet the minimum account balance of $350 to trigger rebalancing (the Rebalance Minimum). See Item 8 for the important note on account rebalancing and the Rebalance Minimum. 2. Asset Location: Asset location is the practice of strategically placing different types of investments in different types of accounts (such as tax-deferred, taxable, or tax-free accounts) in order to maximize after-tax returns for a given asset allocation. Asset location is important because taxes can have a significant impact on investment returns. By strategically placing different types of investments in different types of accounts, investors can potentially minimize their tax liability and improve their after- tax returns. For clients on Playbook Plus, PB Advisor will seek to implement the given allocation with a focus on tax minimization. This means that income-producing assets that are taxed at normal income tax rates might be placed into tax-advantaged accounts. In addition, asset location can allow a portfolio to be rebalanced with lower realized gains because trades may occur in the tax-advantaged, as opposed to taxable, accounts. 3. “Smart Withdrawals”: "Smart withdrawals" or tax-smart withdrawals are a way of withdrawing money from clients’ investment accounts in a tax-efficient manner. This means that clients strategically withdraw funds from your accounts in a way that minimizes the taxes clients owe on the proceeds. This means that clients withdraw ds from all of their investment accounts, held with Playbook, in a way that is optimized to minimize the tax burden. One example is selling tax lots that are held at a loss, or withdrawing principal from a Roth IRA when the 5-year holding period has passed, among other opportunities. Aside from these features, Essential and Plus function in largely the same manner. Clients may choose to upgrade, or downgrade, their service at any time. Clients who choose to upgrade will be charged a pro-rated amount, whereas clients who choose to downgrade will maintain their Plus membership until the next billing date. PB Advisor offers its clients roboadvising services to conduct 401(k) accounts rollover. PB Advisor has partnered with Beagle Financial Services, Inc. (“Beagle”) for its clients to have an option to rollover their inactive 401(k) account into a Playbook IRA account. The process of transferring funds from one retirement account to another, without incurring any tax consequences, consists of prefiling online questionnaire to determine if the rollover is in the best interest of the advisory client. PB Advisor does not charge an extra fee for such services to its clients. PB Advisor utilizes a third-party platform (currently, APEX Clearing Corporation ("APEX")) and rollover accounts are treated the same way as other IRA accounts with Playbook.