Description of Services ADVISORY SERVICES Vesto Advisors, LLC (“Vesto”) is located in New York, New York, and has been in business since February 2023. Vesto provides small and medium sized businesses ("clients") with investment advisory and portfolio management services, with the primary objectives of optimizing near to medium-term liquidity and achieving returns on idle assets. Vesto manages client assets on a purely discretionary basis, but believes in staying close to the needs of our clients as an advisor. Vesto seeks to provide customized short or medium-term oriented investment portfolios which enable our clients to sustainably preserve and/or grow their capital by earning returns in excess of typical bank account yields. Vesto further provides a website and application ("Platform") to make it easy for clients to have transparency into their holdings, as well as automated access to reports and analytics. Vesto does not exercise its discretionary authority to make any investments on its clients' behalf other than investments in one or more of the following asset categories: mutual funds, ETFs, money market, and fixed income. The model portfolios in Vesto's wrap fee program currently consist of fixed income securities such as treasuries, CDs and corporate bonds, as well as fixed income mutual funds and ETFs. Vesto does not offer non-discretionary investment advisory services, retirement planning services, banking services, financial consulting, tax advice or legal advice. Vesto is wholly owned by Vesto Financial, Inc. Benjamin Döpfner, the Chief Executive Officer/Chief Compliance Officer of Vesto, is also the majority owner of Vesto Financial, Inc. Establishing an Advisory Relationship with Vesto To provide its investment advisory services and tailor its investment decisions to each client's specific needs, Vesto meets with clients through one or more consultations to understand their goals and profile in detail. Consultations are offered free to the client and may occur through a phone call, video conference, email, or in person, according to the client's preference. Vesto maintains this information in strict confidence subject to its Privacy Policy, which is provided in the Compliance Manual. Topics discussed with Vesto clients may include (but are not limited to) the below thematic considerations:
• Nature of business and cash flows
• Preferred duration or investment horizons;
• Risk Tolerance
• Banking and treasury management practices and policies;
• Income needs;
• Other holdings, particularly any concentrated holdings;
• Tax situations and preferences;
• Values-based preferences; and,
• Financial goals and plans. Based on the information collected from the client, and after considering a range of macroeconomic and market inputs, Vesto recommends one or more portfolio options to the client. Clients can choose a portfolio Vesto recommends, which includes allocations to preselected financial instruments. Clients can also customize our recommended portfolios by increasing or decreasing portfolio allocations to the financial instruments in our recommended portfolio or by choosing from a list of available instruments and requesting specific allocations to each. Vesto allows clients to restrict Vesto from investing in any specific asset classes, instrument types, or individual securities when designated as such by the client. Vesto's recommendations are dependent on receiving accurate information from clients. While Vesto contacts its clients periodically, clients are encouraged to promptly notify Vesto of any change in their financial situation or investment objectives that might require a review or revision of their portfolio. Vesto aims to provide its clients with various investment options based on their risk tolerance and other factors, including the client's level of idle cash, liquidity needs and return goals. By continuously managing the optimal cash balance, Vesto aims to assist clients with maintaining the liquidity needed to operate their businesses, while investing the rest. Investment Strategies Vesto offers three broad types of investment strategies, which are aligned to our model portfolios and can be further customized to the specific needs of our clients. The strategies are not generally meant to be long-term in nature, and are aimed at achieving near-term and medium-term client objectives on risk-adjusted returns. Fixed income ladder strategy The objective of this strategy is to seek an optimal yield that is consistent with the primary goal of preservation of principal and liquidity. Vesto will typically invest a majority of client cash assets in fully collateralized US government securities, brokered certificates of deposit (CDs), or investment grade corporate bonds. Vesto will typically aim to buy such securities and hold them to maturity. In a ladder strategy, instead of building one large position that will all mature on the same date, Vesto will allocate the principal across multiple positions that mature at staggered future dates. Using a ladder strategy may reduce interest rates risk. By staggering maturity dates, clients avoid getting locked into a single interest rate. A ladder may help smooth out the effect of fluctuations in interest rates because there are positions maturing monthly, quarterly, semi-annually or annually, depending on the number of rungs in the ladder. When a bond matures, clients could reinvest that principal plus interest in a new longer-term bond at the end of a ladder. If interest rates have risen, clients may choose to benefit from a new, higher interest rate and continue the ladder. If interest rates were to fall, the bonds at the end of the ladder would likely have locked in higher yields already, and clients would have the option to discontinue the ladder. Ladders also provide a predictable cash flow at the onset. Vesto's ladders are entirely customizable and can be designed to return a portion of the invested principal, plus interest, at periodic intervals per the client's liquidity needs. Fixed income funds strategy The objective of this strategy is to seek an optimal yield that is consistent with the primary goal of preservation of principal and liquidity. Instead of directly purchasing and actively managing fixed income securities, Vesto will allocate a majority of client cash assets across multiple diversified mutual funds or ETFs offering exposure to money market instruments such U.S. government treasuries, U.S. government agency and municipal securities, U.S. investment grade corporate bonds, as well as repos and commercial paper. These funds are professionally managed by experienced asset management firms and are selected for their track record of performance and risk management. They may also provide for more daily diversification and liquidity than outright holding securities. Custom multi-asset strategy This strategy offers a client flexibility with regards to choosing the asset classes they would or would not like exposure to, and determining the allocation mix in a manner best suited to their risk tolerance or return expectations. The client's portfolio could be customized to achieve a desired level of current income and/or to seek the possibility of greater capital appreciation than fixed income-only strategies. The strategy may provide better diversification than a typical bond-only portfolio. Vesto does not invest any client assets in Cryptocurrencies and related vehicles, alternative assets or private market vehicles, private placements, and non-registered securities, including any index or fund products providing exposure to the above. Vesto also does not utilize leverage, short positions or derivative products within its strategies. All of Vesto's strategies primarily subject the client's portfolio to bond risks, including interest rate risk, credit risk, income risk, and call risk. The portfolios may also be subject to moderate levels of non- diversification risk and re-investment risk, and a low level of stock market risk. Across all strategies, Vesto lays special emphasis on the quality, maturity, liquidity and diversification of investments when determining the list of assets permissible. For mutual funds and ETFs, Vesto also looks to optimize for performance

by choosing investment options with low expense ratios, and purchasing less expensive share classes within them to the greatest degree possible. Additionally, Vesto will make every effort to ensure invested assets selected remain adherent to any restrictions communicated by the client. Vesto's investment strategies do not typically require frequent trading of securities. However, we expect some buying and selling activity to occur, especially during portfolio review and rebalancing. Vesto does not charge its clients any fee based on the number, nature or size of individual transactions executed during such events. When client portfolios are rebalanced, there is a possibility of incurring capital gains. Vesto assumes no responsibility to its clients for any tax consequences of any transaction, including but not limited to any capital gains that may result from the rebalancing of client accounts. All investment strategies subject clients to a range of risks. The risks are laid out in further detail below in Item 8 of this Brochure. The Investment Process Based on the information collected from the client, and after considering a range of macroeconomic and market inputs, Vesto recommends one or more portfolio options to the client. Clients can choose a portfolio Vesto recommends, which includes allocations to preselected financial instruments. Clients can also customize our recommended portfolios by increasing or decreasing portfolio allocations to the financial instruments in our recommended portfolio or by choosing from a list of available instruments and requesting specific allocations to each. Vesto allows clients to restrict Vesto from investing in any specific asset classes, instrument types, or individual securities when designated as such by the client. Custodian Vesto has appointed Atomic Brokerage LLC (“Atomic” or “the Broker-Dealer”) and Pershing LLC ("Pershing" or "the Custodian"), both members of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation, to serve initially as the broker-dealer and custodian (respectively) to provide custody of the assets in a client's Vesto Account and to execute, clear, and settle trades within the Accounts (the "Custodian"). Vesto may, as it deems necessary or advisable in its discretion consistent with the SEC regulations regarding custody of investment advisory accounts and its fiduciary duties to clients, terminate existing and initiate new relationships with banks, broker- dealers, or other qualified institutions at any time to provide custody, execution, clearance, or settlement services for Vesto Accounts. Vesto may use more than one institution to provide custody, execution, clearance, and/or settlement services. Custody of client assets will be maintained with the Custodian. Although Vesto may recommend the movement of client assets, Vesto will not have physical custody of any assets in the client's Vesto Account, and only Client will have the ability to authorize any transfer of assets. Clients will be solely responsible for paying any additional/miscellaneous charges of the Custodian, which are separate from Vesto's fees (both are described in detail under Item 5). Clients authorize Vesto to give the Broker Dealer and Custodian instructions for the purchase, sale, conversion, redemption, exchange or retention of any security, cash or cash equivalent or other investment in the client's Vesto Account. At least quarterly, clients will receive directly from the Custodian a statement showing all transactions occurring in the client's Vesto Account during the period covered by the account statement, and the funds, securities and other property in the Vesto Account at the end of the period. Clients are urged to carefully review statements received from the Custodian to ensure the accurate reporting of such information. Investment Discretion Vesto provides discretionary investment management services. Vesto requires discretion over the selection and amount of securities to be bought or sold in client accounts without obtaining prior consent or approval from the client. Clients will grant of such authority by executing the investment management agreement. All discretionary trades made by Vesto will conform to each client's particular investment objectives and goals within the capabilities of Vesto. Other third party partnerships Vesto partners with AtomicVest Inc. ("Atomic"), an unaffiliated financial services company that provides technological and operational support to Vesto, including access to Pershing as executing broker and custodian. For accounts opened on or after March 4, 2024, Brokerage services are provided by Atomic Brokerage, LLC (“Atomic Brokerage”), a registered broker-dealer. Custody and clearing services are provided to Atomic Brokerage by Pershing LLC, a part of the Bank of New York Mellon. Both are members of FINRA and SIPC. For more details about Atomic Brokerage, please see their Form CRS, the Atomic Brokerage General Disclosures, and Privacy Policy. Check the background of Atomic Brokerage on FINRA’s BrokerCheck. Additional technology services may be provided by AtomicVest, Inc. (“AtomicVest”). Neither Atomic Brokerage nor AtomicVest are banks. For accounts opened prior to March 4, 2024, Brokerage services are provided by Pershing Advisor Solutions LLC (“PAS”), a part of the Bank of New York Mellon, and a registered broker-dealer. Custody and clearing services are provided by Pershing LLC, a part of the Bank of New York Mellon. Both are members of FINRA and SIPC. Vesto has a sub-advisory relationship with Atomic Invest LLC ("Atomic Invest"), an SEC-registered investment advisor, to enable access to the PAS and Pershing platforms, and to help execute investments on behalf of its customers. Atomic Invest is not a bank. Atomic Invest does not exercise discretion over the assets of Vesto's clients, and does not provide investment advice or investment management services to Vesto's clients (with the exception of voting of proxies - see item 17). There is no separate fee charged by the Broker-Dealer or the Custodian directly to Vesto's clients; Any and all fees are entirely included within Vesto's Wrap Fee described under Item 5. Client Tailored Services Clients are required to provide Vesto with certain risk tolerance and other financial information. Based on the information provided by the client, Vesto will utilize the information provided as well as the goals and needs of the specific client to determine the best strategy to employ for the client. Vesto may, but is not required to, provide alternative investment strategies to a client if warranted by market and/or economic conditions. In formulating its investment strategies, Vesto does not consider any additional information about the client not disclosed to a Vesto representative, including outside assets, portfolio concentration, debt or other accounts the client may have with any third party. Before becoming a client of Vesto, potential clients should consider this limitation on Vesto's services, which is a function of Vesto providing its investment management services. Client Imposed Restrictions As stated above, Vesto will allocate clients' idle cash among one or more strategies. Vesto and clients will mutually acknowledge the chosen investment strategy and any restrictions communicated by clients in writing through a documented Investment Proposal provided to clients. Once agreed, Vesto will look to adhere to the proposal in good faith. Additionally, clients will be permitted to remove specific positions from their proposed portfolios or live portfolios, by requesting Vesto to do so in writing, with the understanding that doing so may impact the portfolio's make-up and returns. Wrap-Fee Program Vesto manages client assets exclusively through our Wrap-Fee program. We therefore do not manage client accounts differently based on this fact, since all clients accounts are managed under the same program. Details regarding our Wrap-Fee Program and fees can be found in Item 5 - Fees and Compensation of this brochure, and within Vesto's Form ADV 2A Appendix 1. Assets Under Management As of March 23, 2024, we provide continuous management services for $80,019,871 in client assets on a discretionary basis, and $0 in client assets on a non-discretionary basis.