Introduction This Brochure describes the wrap fee program offered by Aura that bundles or “wraps” discretionary investment advisory services, brokerage, custody, clearing and settlement, as well as other administrative services together and charges a single inclusive fee. Aura Finance, doing business as Aura, (“Aura” or “Firm”) provides automated discretionary investment advisory services to Clients via the Aura investment program (the “Program”). Aura helps Clients build smart financial habits and manage wealth by providing financial education, tools guidance, and simplifying the way Clients save and invest. Aura is registered with the United States Securities and Exchange Commission (“SEC”) and provides all investment advisory services exclusively through virtual interaction conducted over the Internet. Aura does not offer tax, accounting, or legal advice. Program Description Aura interacts with Clients primarily through a technology platform developed and maintained by Aura’s parent company, Aura (as defined below), that is available through Aura’s mobile application (“Platform”). The Firm provides automated investment advice and delivers advisory services to Clients exclusively through the Platform. Aura does not provide investment advice in person, over the phone, live chat, or in any other manner other than through the Platform. The Program is an automated, web-based algorithmic system designed to help Clients invest regularly, diversify, and think long-term about their financial futures. Clients are required to input personal information via the Client registration process (“Suitability Questionnaire”), which may include, but is not limited to, information about a Client’s identity, liquidity needs, age, e-mail address, physical address, location, citizenship, financial situation, or other information as requested on the Platform (“Client Information”). The Program provides automated investment advice based solely on Client responses to the Suitability Questionnaire. Aura will periodically remind Clients to review and update their Suitability Questionnaire. Clients agree to promptly update any Client Information provided to Aura that is no longer accurate using the Platform. Based on the information the Client provides on the Platform, Aura uses the Program to provide the Client with automated investment advice with respect to the Firms’ various model portfolios. Each of the models offered through the Program consist of publicly traded single stocks, treasuries, fixed income, municipal bonds, and exchange traded funds (“ETFs”). The models seek to follow an “Aggressive,” “Moderate,” and “Long Term” investing approach. The model recommendation is based solely on Client provided responses to the Suitability Questionnaire. There may be tracking error in the performance of an ESG portfolio as compared to a non-ESG portfolio that is managed to the same risk profile. The Adviser’s model portfolios will not include leverage or derivatives except where such investments are within an ETF that is included in the portfolio. The Adviser anticipates each model portfolio (described below) will consist of a sub-portfolio of individual equities and one or more ETFs. Fixed income allocations will be represented by one or more ETFs. The equity component of any model portfolio will be represented by U.S. and non- U.S. global equities based on criteria established by the Adviser. The Adviser reserves the ability to remove individual stocks that otherwise would be included in its discretion, such as if the ability to trade a particular stock becomes too burdensome in a particular jurisdiction. Although the Platform recommends the model portfolio the algorithm believes is best suited for the Client based on Suitability Questionnaire responses, Clients may opt to invest in a more conservative or more aggressive model than recommended if they choose to do so. Based on the information the Client provides on the Platform, Aura uses the Platform to provide the Client with automated investment advice in the form of (i) discretionary managed accounts utilizing one of the Firm’s model portfolios, and (ii) Financial Counseling Service. Aura, through Atomic Brokerage (“Atomic”), an unaffiliated financial services company that provides technological and operational support to Aura, also offers automated investment portfolios that apply environmental, social and governance (“ESG”) factors to the Client’s chosen model (“Lean-In Portfolios”). The Lean-In Portfolios are built with an index pre-screened to exclude securities of companies that do not meet the Program’s ESG criteria. The Program identifies companies with similar fundamental business and investment characteristics, such as capitalization size, dividends, risk, and industry exposure that meet the applicable ESG criteria. Through the use of algorithmic modeling, a representative sampling process gives a higher investment weight to businesses that display superior ESG characteristics. The Program also spotlights companies with better environmental ratings in multiple sustainability areas, including carbon emissions and water usage. Social responsibility is also gauged by looking at diversity and inclusivity metrics at the employee, management, and board levels. Aura is sub-advised by Helium, LLC, an affiliate to Atomic. The Adviser can enter into consultant or sub-advisory relationships in which it contracts with another third-party registered investment adviser or strategist to provide research, advice, and guidance or investment management services in regard to assets it is managing for clients. Such arrangements might range from the other party providing research ideas that the Adviser may or may not implement, to a sub-advisor having full discretion over the Adviser’s client’s assets. Aura utilizes Atomic to assemble independent reports and other information from business analysts on the ESG practices of corporations in its indices and offers clients the option to exclude corporations that do not meet certain metrics established by Aura/Atomic. While the Program seeks to ensure its Lean-In Portfolios have a similar risk and return profile to the non-ESG model portfolios, they will naturally have some variation in outcome compared to portfolios without these screens. In the current investment ecosystem, information technology companies are more likely to be stewardship leaders, meaning they tend to figure more heavily in the Lean-In portfolios. This proportion will likely fluctuate over time, depending on many factors, including but not limited to, changes in management, technology, and regulation across the investment landscape. Clients may impose reasonable investment restrictions on the management of the Client’s Aura Account. Such restrictions may result in a Client’s Aura Account being concentrated in one or a few sectors, industries, or securities. Concentrated positions typically increase the risk and volatility of the Aura Account and will result in a decrease in portfolio diversification. Clients who implement an investment decision that is outside the scope of the Program recommendations should understand that such a decision may not be appropriate based on the Client’s risk profile and that the Client’s portfolio may underperform over any time horizon than a portfolio designed by the Program. Clients who want to implement the Program’s recommendation and invest utilizing one of the Firm’s model portfolios are required to enter into an investment advisory agreement (“Advisory Agreement”) with Aura and a brokerage agreement (“Brokerage Agreement”) with Pershing LLC (“Pershing”) or Atomic, registered broker-dealers unaffiliated with Aura. The Advisory Agreement discusses the automated advisory services the Client will receive, the fees charged to the Client, and the conditions of the Client’s advisory relationship with Aura. Our advisory relationship begins upon the Firm’s acceptance of the Advisory Agreement. Any preliminary information provided to the Client before the Firm accepts the Advisory Agreement does not constitute investment advice under the Investment Advisers Act of 1940, as amended (“Advisers Act”), and should not be relied on as such. The Brokerage Agreement describes how Pershing and Atomic will act as the clearing brokers and qualified custodians for the Client’s Account. Under the terms of the Brokerage Agreement, the Client authorizes Pershing or Atomic to establish and carry the Client’s Account that holds the Client’s securities and cash and records the Client’s transactions in the Program. Program Limitations Aura does not represent that the Program or the Financial Counseling Service is based on or meant to replace a comprehensive evaluation of any Client’s entire financial circumstances. Recommendations of Aura are generally limited in scope to the questions Aura asks and the information that Clients provide. Aura does not provide comprehensive financial planning, and there may be other relevant factors and financial considerations that Aura does not take into consideration when formulating the advice provided. Any recommendations provided by Aura are not intended to comprise any Client’s complete investment program because Aura is not necessarily aware of the Client’s aggregate investable and invested assets. Furthermore, neither the Program nor the Financial Counseling Service include or account for any assets held within an employee benefit plan subject to the Employee Retirement Income Security Act of 1974, as amended. Dividend Reinvestment The Program automatically reinvests dividends and distributions paid by securities in the model portfolios back into the Client account. This reinvestment will trigger tax liability for Clients without any corresponding payment to offset such tax liability. Clients will either have to pay their tax liability for the dividend reinvestments with separate money or withdraw money from their account to satisfy any applicable tax liability. Clients may opt-out of such reinvestments. Model Portfolios Aura currently offers algorithmic models designed to represent an Aggressive, Moderate and Long-Term investing approach. The Aura portfolios are designed to seek total return through exposure to a diversified portfolio of international and US equities, fixed income, treasuries, ETFs, and municipal bonds. As part of the algorithmic portfolio analysis and review process, the Program may add, remove, re-categorize or replace investments available under the Program. In the event an investment is removed, it will no longer be available for additional investing. In the event an investment is removed and replaced with another substantially similar investment, Aura may liquidate Client positions to cash and reinvest in the replacement Investment. The models are designed to help promote diversification and long-term growth as appropriate within the context of Client-specific age, risk tolerance and investment time horizon, among other factors and information provided in the Client Questionnaire. Rebalancing of Model Portfolios The Program manages Client Accounts in an automated fashion. This means

that the algorithm will make trades in the Client’s Account to maintain the target investment allocations within each model portfolio. The Program utilizes software to conduct this trading to invest Client deposits, fund Client withdrawals and perform rebalancing to maintain the target portfolio allocation in each model portfolio. An account will be rebalanced when withdrawals or deposits are made into the account. The Program will also perform rebalancing of Client portfolios if the holdings deviate from the applicable model’s target asset allocation or in certain cases due to harvesting tax losses. In this way, Aura seeks to maintain the client’s target asset allocation through market fluctuation, withdrawals, deposits, and other events that may cause deviations while seeking to minimize the transaction costs of frequent portfolio rebalancing. Rebalancing transactions are automatic, as are dividend reinvestments. The rebalancing and reinvestment processes are automated and not limited in terms of frequency. As a result, the Program may sell over-concentrated ETFs or securities and use the proceeds to buy under-concentrated ETFs or securities to bring Portfolios in line with their target allocations regardless of market or other dynamics. The risks and limitations of the automated process could result in the continued purchase of underperforming ETFs or securities and the sale of better performing ETFs or securities to achieve the targeted allocation. Aura does so on a best-efforts basis and does not take into account individual market or legal circumstances, but does take into account individual tax circumstances, such as tax loss harvesting. In some market conditions, this may create capital gains and potentially other tax liabilities. All transaction costs are rolled into the Aura Fee paid by the customer. Any costs imposed by the manager of the ETF would be expressed through the pricing of the ETF. Client is responsible for logging in to their Account(s) regularly to review performance and access trade confirmations, periodic account statements, and other information available to Clients. If the Client identifies any discrepancies, the Client should promptly report them to Aura by emailing Aura at info@aurafinance.io. Aura Fee Aura charges Clients a Wrap Program Fee based on the total net deposits in their account. For Clients with greater than $10,000 in net deposits, Aura charges a Wrap Program Fee of 100 basis points (1.00%) per year (asset-based fee). The Wrap Program Fee is not based upon transactions in a Client account, but rather is a bundled fee, which includes the costs for advisory services, execution, clearance, custody and account reporting. For Clients who have less than $10,000 in net deposits, Aura charges a Financial Counseling Service Fee (as defined below) of $249 per year (fixed fee). The Wrap Program fee is assessed on a monthly basis at the beginning of each month. The $10,000 net deposit threshold is calculated at the end of the month using net transfers. To be clear, any Aura account with less than $10,000 will not be charged the Aura Fee. On accounts with assets $10,001 and greater, the Aura fee applies to the amount greater than $10,000 only (ie-$1 for an account holding $10,001 in securities and/or cash). The asset-based fee is assessed based on the daily average market value of a Client’s portfolio over the previous month. Aura may from time to time, in its sole discretion, offer lower fees through promotions, referrals and other discounts to some Clients that differ from the Wrap Program Fee stated above. It is per client, not per account. In addition, the wrap fee may be higher or lower than that charged by other sponsors of comparable wrap fee programs. Since the asset-based fee is determined by average daily account balance, if assets are deposited into or withdrawn from an account after the inception of a month, the base fee payable with respect to such assets is adjusted accordingly. For the initial period of an engagement, the Wrap Program Fee is calculated on a pro rata basis. In the event the Advisory Agreement is terminated, the Wrap Program Fee for the final billing period is prorated through the effective date of the termination and the outstanding portion of the Wrap Program Fee is charged to the Client. A wrap fee account may not be in the best interest of a Client with minimal or no trading activity as compared to a non-wrap fee account or brokerage account where the Client would otherwise pay trading costs as incurred but a lower fee in a non-wrap account or no advisory fee in a brokerage account. In that case, Clients would not receive the services provided by Aura, which are designed, among other things, to determine which investments are appropriate for the portfolio and the Client’s account. After the Client’s Aura Account is opened and funded, as applicable, the Aura Fee will be automatically deducted from one of either the Client’s Aura Account or the Client’s Funding Account. The Aura Fees vary as Aura’s services themselves vary. This will result in one Client paying different fees (as applicable) than another Client for similar services. In addition, lower fees for comparable services described may be available from other sources. The Custodian may, as necessary and in its sole discretion, sell securities in the Client’s Aura Account to generate free cash in order to deduct the Aura Fee. The Client authorizes the Aura Fee to be charged by one of the following methods: (i) the Client’s debit or credit card, (ii) deduct the Aura Fee directly from the Client’s Funding Account, (iii) deduct the Aura fee directly from the Client’s linked bank account, (iv) or to instruct the Custodian to sell, as necessary, securities in the Client’s Aura Account and to transfer money out of the Client’s Aura Account to pay Aura the Aura Fee and, if any, other fees due under or as described in the Advisory Agreement. The Client agrees and acknowledges that such fee deduction may trigger rebalancing of the Client’s Aura Account, in accordance with Aura’s rebalancing procedures and portfolio management system, including as described in the Advisory Agreement. Fees deducted from the Client’s Aura Account will be reflected in the account statements provided to the Client by the Custodian. The Client agrees and acknowledges that the Client is responsible for paying any and all fees, including, without limitation, the Aura Fee, that the Client owes pursuant to the Advisory Agreement. The Client is responsible for maintaining complete and accurate billing and contact information with Aura. The Client acknowledges that such fees may change from time to time and will be available on the Website and in the Brochure and Relationship Summary. In the event of a change in fees, Aura will provide the Client notice electronically via the Platform. The Client agrees to check the Platform from time to time for updates to the Aura Fees applicable to the Client. Clients should be aware that to the extent the Adviser invests in ETF securities, they will pay two levels of advisory compensation – the advisory fees charged by the Adviser plus any management and other fees charged by the ETF, which is described in the ETF’s offering documents. This will cause a higher investment advisory cost (and lower investment returns) than if a client purchased the ETF directly. Aura does not charge performance-based fees. For the avoidance of doubt, the Financial Counseling Service is a service provided by Aura under the Advisory Agreement and under the Program for all account types, and, accordingly, the Aura Fee as described herein is due upon receiving such services, whether or not the Client elects to open any individual account(s). Impersonal Financial Counseling Service Aura also provides certain educational tools to Clients (“Financial Counseling Service” or “FCS”). The Financial Counseling Service includes a range of financial information, education, and analysis offered on a limited scope basis. The Financial Counseling Service is impersonal in nature, which means that the advice is not tailored to a Client’s, or group of Clients, individual needs and does not purport to meet the objectives or needs of specific Clients or accounts. Consequently, Aura does not rely on Suitability Questionnaire information that the Client inputs into the Platform to provide the Financial Counseling Service. The Financial Counseling Service is available to all Aura Clients. Financial Counseling as a Separate Service The Financial Counseling Service does not include brokerage services for Client assets. In such cases Aura will not place any trades on the Client’s behalf, and the Client is fully responsible for determining whether, when, and by what means to implement any analysis and recommendations made available through the Financial Counseling Service and for making the Client’s own investment decisions. The Client will be responsible for any fees and expenses incurred for such implementation. For the avoidance of doubt, the Financial Counseling Service can be provided to all Aura Clients. Therefore, Clients that open an Aura Account (in addition to any other additional advisory services bundled under the selected subscription plan) under the Program and as such, may receive personalized investment advice, and may also receive the Financial Counseling Service. A limited number of Clients will obtain access to the Financial Counseling Service as it relates to their subscription plan via the Platform after completing the initial registration process described above. Each such Client that elects to open an Aura Account will attain additional Platform entitlements including personalized investment advice, after completing the Suitability Questionnaire and obtaining approval from Aura to open an Aura Account. Clients that are not approved to open an Aura Account may continue to receive the Financial Counseling Service under certain circumstances, as further described in the Advisory Agreement. All other Clients must complete Aura’s entire onboarding process, which includes providing additional Client Information for customer identification and anti-money laundering purposes, the Suitability Questionnaire and receiving approval from Aura to open an Aura Account, prior to obtaining Platform entitlements (including the Financial Counseling Service). FCS Fee The FCS program is a separate offering from Aura’s advisory services and Wrap Program and is $249 per year, paid in advance. Aura reserves the right to waive FCS fees for FCS users. On a limited basis, a select group of FCS users that are offered and elect to only receive the Financial Counseling Service from Aura complete a streamlined registration process and may not complete the Suitability Questionnaire. Such Clients are only required to provide Aura with a name, date of birth, telephone number, home address, and email address, and agree to pay the FCS Fee. Clients that elect to open an Aura Account are required to complete the Suitability Questionnaire, and receive approval from Aura in order to open such accounts and obtain personalized investment advice.