Atomi Financial Group, Inc. (“Compound Planning,” “we,” “us,” “our,” or the “Adviser"), is a California corporation and an SEC-registered investment adviser (“RIA”) offering wealth management services. Atomi Financial Group, Inc. operates under numerous DBA's including: Compound Planning, Atomi Asset Management, Atomi Financial Advisors, Atomi Private Client Group, Financial & Insurance Services, H L Dingle & Company, Inc, Hackett Advisory, Hawkes Wealth Management, Life Plan Retirement Partners, Optura Advisors, Inc., RJF Financial, Thomas Advisory Services, Inc., Whitwell & Co., and Winkler Wealth. Compound Planning receives mail at 2261 Market Street, STE 4013, San Francisco, CA 94114. Alternativ, Inc. acquired Atomi Financial Group, Inc. on June 11, 2022. Prior to the acquisition, Atomi Financial Group, Inc. has been operating its advisory business since 2012. On September 22, 2023, the merger between Atomi Financial Group, Inc. dba Alternativ Wealth and Compound Advisers, Inc. (“Compound Advisers”) was completed. Both firms are SEC-registered investment advisers (RIA). The merger was made possible by the acquisition of Compound Financial, Inc. (“Compound Financial”) on September 22, 2023 by Alternativ LLC, the parent company of Alternativ Wealth (the “Merger”). Prior to the Merger, Alternativ LLC was converted into a corporation and was renamed to “Alternativ Inc.” Since the completion of the Merger, both Alternativ Wealth and Compound Advisers continue to operate through Atomi Financial Group, Inc. under the new dba of Compound Planning. On the other hand, as a result of the Merger, Compound Advisers, Inc. ceased operations as an RIA firm and all client accounts are serviced and managed through Compound Planning. In addition, Christian Haigh serves as the Chief Executive Officer (CEO) of Compound Planning and Jeffrey Smith as its Chief Compliance Officer (CCO). Prior to the Acquisition, Compound Advisers’ owners were Jordan Gonen and Jacob Schein, who served as its CEO and Chief Technology Officer (CTO), respectively. The Merger will not affect the level or quality of services provided to the former clients of Compound Advisers and such services shall be maintained and provided by Atomi Financial Group, Inc. dba Compound Planning. Compound Planning offers investment advisory services to financial intermediaries including unaffiliated broker- dealers, unaffiliated registered investment advisers, and affiliated investment adviser representatives (“IAR”) (collectively, “Financial Intermediary” or “Intermediary”), serving as a sub-adviser to the Financial Intermediary. The Adviser's investment advisory services may include assisting the Financial Intermediary with investment policy statement determination, asset allocation, investment selection, portfolio management, billing, and client reporting. The Adviser's investment advisory services are generally provided on a limited discretionary basis. Revision Date: 3/30/2024 Page 5 of 35 Compound Planning may also offer investment advisory services on a non-discretionary basis. For accounts in which Compound Planning does not have discretionary authority, the Adviser will contact the client before making recommendations the Adviser deems to be appropriate for the client. TAMP Services Compound Planning provides Financial Intermediaries with an extensive range of investments and services for use by the said Intermediary with their clients through its Turnkey Asset Management Program (“TAMP”), including access to in-house managed models, third-party models, alternative investments, tax-alpha investments, and other operational support services. Prior to making available any type of investment, Compound Planning will ensure that the investment and its general partner, sponsor, or adviser are properly registered, licensed, or notice-filed with the appropriate regulatory authority. In general, a Financial Intermediary will compile financial and demographic information on their client to help develop an investment strategy that will meet their client’s needs and objectives, investment time horizon, risk tolerance, and any other pertinent factors. Utilizing various tools made available by Compound Planning, the Financial Intermediary will determine the appropriateness, concentration, and strategic asset allocation of one or more investment options made available through the TAMP. In its role as a TAMP provider, Compound Planning is mainly responsible for the implementation, trading activity, and reconciliation (for billing and reporting purposes) of the investment(s) selected by the client and their Intermediary. Under the TAMP Agreement, Compound Planning has the requisite authority to manage and rebalance automatically the client’s assets based on the parameters of the model or investment strategies. Insofar as Compound Planning provides TAMP services to unaffiliated Financial Intermediaries, these Intermediaries and their clients have ultimate discretion over the appropriateness of a particular investment program for that client. Consequently, Compound Planning may operate with lesser responsibility to the end client’s account. Financial Intermediaries have access to the following investment models and ancillary services discussed further below: In-House Models Compound Planning manages different asset allocation models, each designed to meet a specific investment goal. Security selection within each model may be comprised of load and no-load mutual funds, exchange-traded funds (ETFs), and/or individual securities. Compound Planning uses a number of analytical tools in developing its asset allocation strategies. Among the factors considered in designing these strategies are historical rates of risk and return for various asset classes, correlation across asset classes, and risk premiums. For all programs, the client directly owns the securities purchased within each of the investment strategies. Each model has a Revision Date: 3/30/2024 Page 6 of 35 strategic asset allocation. However, the Adviser may alter a model's actual asset allocation based on a fundamental or technical analysis of the markets, and/or macroeconomic forecasts. The Adviser, acting in a limited discretionary capacity, chooses when to execute any trade. Please note that investment minimums may be waived at the Adviser's sole discretion. Third-Party Models Compound Planning maintains a platform where third-party managers provide investment strategies and models (“Models”) and make them available to Financial Intermediaries for selection on behalf of their clients in accordance with their clients’ needs, objectives, risk profile, and other financial considerations. Typically, a traditional asset manager, a private fund manager, or an index provider (“Sponsor”) provide each Model. Each Sponsor may choose to provide additional content (“Sponsor Content”), which may include a description of investment strategies, commentary on markets and underlying investments, and other information relevant to the Sponsor’s team and Models. Sponsor Content represents the opinions of the Sponsor providing the content and should not be construed as personalized advice. Sponsor Content is subject to change without notice. Compound Planning’s Financial Intermediaries’ Advisers may select third-party managers for clients based on their investment objectives, guidelines, and restrictions. Typically, fees of third-party managers will be in addition to Compound Planning’s fees and any expenses relating to a client’s account with Compound Planning. Intermediary-Directed Models Compound Planning also offers Financial Intermediaries the ability to create and manage their own investment portfolios for clients (an “Intermediary-Directed Model”). For clients using an Intermediary-Directed Model, Compound Planning is providing only administrative services and does not provide any investment advisory services and, therefore, is not responsible for the selection of the specific investment vehicle choices made with respect to an Intermediary-Directed Model. For certain types of Intermediary-Directed Models, Compound Planning may also place trade orders pursuant to the direction of the Intermediary but does not exercise discretion over the client accounts or act as an investment adviser to the client. Alternative Investments Compound Planning makes investment managers of non-traditional, private, or unregistered investment strategies (collectively, “Alternative Investments”) accessible to Financial Intermediaries for use with their clients. Examples of offering structures for an Alternative Investment include private equity (e.g., Regulation D, Regulation A, etc.), public non-traded offerings (e.g., S-1 offerings, intrastate offerings, Business Development Companies [BDCs], non-traded mutual funds, etc.), non-traded Real Estate Investment Trusts (REITs), and/or non-traded oil and gas programs. Some Alternative Investments will require the client to enter into a separate client agreement, via a subscription Revision Date: 3/30/2024 Page 7 of 35 agreement with the Alternative Investment manager, which will contain separate fees, terms and conditions, and disclosures. The Adviser has the obligation to conduct due diligence on all Alternative Investments that are utilized by affiliated Financial Intermediaries. However, as a TAMP, the Adviser only provides administrative services, such as trade processing and reconciliation for billing and reporting purposes. Unaffiliated Financial Intermediaries are responsible for completing their own due diligence as well as ensuring that any security or other product recommended by them is appropriate for that specific client. Alternative Investments will often have minimum investor suitability standards, which are disclosed within an investment’s prospectus or offering circular. More restrictive state or firm-level suitability or concentration standards may also be applicable. While Alternative Investments may offer interval-based (i.e., quarterly), periodic tender offers, or some other form of an early redemption feature, any Alternative Investment, in general, should be considered illiquid. That is, an investor should consider any Alternative Investment as being illiquid and without a secondary market upon which to sell one's investment and thus no opportunity to convert one's investment

into cash. Anticipated holding periods will vary depending on the nature and strategy of the Alternative Investment. The Adviser will communicate anticipated holding periods per language provided within each prospectus or offering circular. However, there is no guarantee that a liquidity event will occur within the prescribed timeframe if at all. All Alternative Investments should be considered speculative in nature, subject to a high degree of risk, including the risk of losing one's entire investment. Alternative Investments are not endorsed by FINRA, SEC, or any other regulatory agency. Back-Office Services Compound Planning provides certain back-office functions for Financial Intermediaries that opt into such services. These include: Account reconciliation: Compound Planning uses electronic data feeds from trading, clearing, and custodial firms to streamline the account reconciliation process. It may do so through vendors or directly itself. Reporting: Compound Planning offers data aggregation and reporting services to allow Financial Intermediaries the ability to monitor their clients’ accounts. Intermediaries are able to examine their clients’ holdings, allocation of assets and portfolio performance. Performance reporting is calculated according to industry standards and is applied to each account or combination of several related accounts for a household’s or family’s assets. Billing: Compound Planning automates certain aspects of client billing on behalf of Financial Intermediaries, including invoicing, fee calculation, and fee collection. Software Licensing and Consulting Services Revision Date: 3/30/2024 Page 8 of 35 Compound Planning may license its asset management software program, which is provided through a web- enabled platform (“Platform”), to other Financial Intermediaries, such as investment advisers, broker-dealers, and financial services companies. The Platform is typically customized and private labeled in the name of the applicable Institution. Financial Intermediaries provide the Platform to their financial professionals, who can use the Platform to manage the accounts of their respective clients. The Platform provides Financial Intermediaries the ability to offer their clients a separate account investment advisory program, various asset allocation programs and account reporting services. Compound Planning also allows Financial Intermediaries to combine these programs and services to suit the needs of their clients. Compound Planning may also provide consulting services in relation to is Software Licensing, including implementation support and ongoing maintenance services. Other Services Compound Planning may also provide customized services to certain institutional clients, such as employment retirement plans. These services usually consist of investment policy statement development and documentation, investment due diligence, and plan advice and management services under the Employee Retirement Security Income Act of 1974 (“ERISA”). In addition to providing TAMP services to unaffiliated Financial Intermediaries, Compound Planning also serves as a corporate RIA to affiliated Financial Intermediaries, also referred to as “Investment Adviser Representatives” or “IARs,” who are registered with Compound Planning and are employed either as a 1099 contractor or W2 employee. Affiliated IARs have access to the same investment models and ancillary services as unaffiliated Financial Intermediaries, plus receive operational support and compliance oversight. The relationship between a client and Compound Planning is different when that client is working through an affiliated IAR rather than an unaffiliated Financial Intermediary. In such a case, Compound Planning takes on a fiduciary duty when determining the appropriateness of any investment recommendations and serves its clients on a discretionary basis, that is, the Adviser executes securities transactions for clients without having to obtain specific client consent prior to each transaction. Compound Planning places trades for clients under a limited power of attorney. Discretionary authority is limited to investments within a client's managed account. The Adviser does not act as a custodian of client assets. The client always maintains asset control. Compound Planning’s investment advisory services generally include advice regarding asset allocation, the selection of investments, investment plan implementation, and ongoing investment monitoring. The Adviser relies on the stated objectives of the client and considers the client's risk profile and financial status prior to making any recommendations. Upon entering into an advisory agreement, the Adviser will collect information concerning the client's investment Revision Date: 3/30/2024 Page 9 of 35 goals and experience, risk tolerance, and income needs, as well as financial information such as assets, liabilities, and portfolio statements. Based on the information provided by the client, the Adviser will recommend investment solutions consistent with the client's stated goals and objectives. Financial Planning and Consulting Services to Individual Clients The Adviser offers clients financial planning services, which help clients have a better understanding of: (a) their current financial situation, (b) goals, needs, and risks, and (c) the potential consequences of taking (or not taking) certain actions (“Financial Planning Services”). The Adviser uses either licensed software or other similar proprietary software or services to assist clients with their financial planning needs. Compound Planning also offers clients consulting services that may vary widely in nature, are out of scope of Investment Management Services or Financial Planning Services, and are billed separately. Examples of such consulting services include, but are not limited to researching different tax strategies, assisting with estate transfer or probate matters, serving as trustee, bill pay and other family office services, providing expertise on business growth matters, etc. Depending on the nature of services, fees may be assessed one-time or as an ongoing retainer fee. The scope of services and associated fees are disclosed in a Consulting Services Agreement. Clients may terminate any consulting services at any time via written notice. In these types of services, the Adviser does not and will not supervise, manage and direct any client assets (including cash), and will neither purchase, sell, invest, reinvest, exchange, convert, nor trade any assets or securities. Investment Management Services The Adviser offers its affiliated IARs access to the same investment offerings for the end-clients that are also offered to unaffiliated Financial Intermediaries through its TAMP, including In-House Models, Third-Party Models, Alternative Investments. In some circumstances, provided the affiliated IAR has sufficient knowledge and experience, Compound Planning will allow the IAR to manage Intermediary-Directed Models. All terms, conditions, and disclosures are identical. Externally Managed Investment Management Services The Adviser offers the following Externally-Managed Investment Management Services: Cash Management Program Compound Planning may recommend the usage of a third-party provider to provide a cash management solution designed to enhance return and provide more FDIC insurance protection on large cash balances. The provider has the responsibility and discretionary authority for the selection of program banks and the allocation of deposits Revision Date: 3/30/2024 Page 10 of 35 into selected banks, while ensuring each account's deposits remain at or below the FDIC insurance limit per bank. Clients are federally insured up to $125 million. Accounts have next day liquidity with no transaction fee or redemption gates. The investment minimum guideline for a third-party cash management portfolio is $250,000, however, the Adviser may waive such minimum at its sole discretion. The Adviser does not sponsor nor is a portfolio manager for a wrap fee program, and is not compensated in the program for sponsoring, organizing, or administering a program, or for selecting, or providing advice to clients regarding the selection of other investment advisers in the program. However, depending on which advisory service tier you have agreed upon in your agreement, you may be offered multiple services for single fee. The Adviser provides investment advisory services such as; advice regarding asset allocation and the selection of investments, portfolio design, investment plan implementation, and ongoing investment monitoring, as well as financial planning. As of December 31, 2023 Compound Planning manages approximately $1,395,949,263 in client assets broken down as follows:
• Discretionary: $983,496,721
• Non-Discretionary: $412,452,542 Compound Planning offers investment advisory services specifically tailored to the needs and special circumstances of businesses, including their pension and retirement plans. These services are generally provided in conjunction with other professionals and include investment management services for pension and profit- sharing plans, 401(k) plans, 403(b) plans, SEP IRA plans, SIMPLE IRA plans, non-qualified deferred compensation plans, asset protection plans, executive salary continuation plans, cross-purchase and stock redemption agreements, and employee advisory services. The Adviser also provides general investment advisory services specifically tailored to the needs of a trustee or other fiduciary, including but not limited to, meeting the definition of "fiduciary" under the Employee Retirement Income Security Act of 1974 ("ERISA") or an employee benefit plan subject to ERISA. Compound Planning sometimes hosts educational seminars for various audiences, including clients and prospects, and is sometimes asked to provide speakers for financial educational speaking engagements. Fees Revision Date: 3/30/2024 Page 11 of 35 for such engagements are negotiated on a case-by-case basis. Compound Planning may publish written content in an online manual, periodic newsletters or other channels of communication providing general information on various financial topics. No specific investment recommendations are provided in these communications and the information presented will not purport to meet the specific objectives or needs of any individual.