4 | P a g e portfolio on an ongoing basis. Versant has contracted with SPT to provide Versant with the Platform, which consists of technology and related trading and account management services for the OPP. The Platform enables Versant to make the OPP available to clients online and includes a system that automates certain key parts of its investment process (the “System”). The System includes an online questionnaire that helps Versant determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that Versant will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but Versant then makes the final decision and selects a portfolio based on all the information it has about the client. The System also includes an automated investment engine through which Versant manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Versant charges clients a fee for its services as described below under Item 5, Fees and Compensation. Versant’s fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the OPP. Schwab does receive other revenues in connection with the OPP, which are described below under Item 5. Versant does not pay SPT fees for the Platform so long as it maintains $100 million in client assets in accounts at CS&Co. that are not enrolled in the OPP. If Versant does not meet this condition, then it must pay SPT an annual licensing fee of 0.10% of the value of its clients’ assets in the OPP. This arrangement presents a conflict of interest, as it provides an incentive for Versant to recommend that clients maintain their accounts at CS&Co. Notwithstanding, Versant may generally recommend to its clients that investment management accounts be maintained at CS&Co. based on the considerations discussed in Item 12 below, which mitigates this conflict of interest. Clients enrolled in the OPP are limited in the universe of investment options available to them. For example, the investment options available are limited to ETFs, whereas Versant recommends various other types of securities in its other services. The OPP is designed to provide guidance and professional assistance to individuals who are beginning the process of accumulating wealth. Clients will have access to their accounts and a financial interface online but will also have the opportunity to confer with Versant with respect to their account. Rebalancing The System will rebalance a client’s account periodically by generating instructions to CS&Co. to buy and sell shares of ETFs and depositing or withdrawing funds through the “Sweep Program”, considering the asset allocation for the client’s investment strategy. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an ETF varies by a set parameter established by Versant, (ii) Versant decides to change the ETFs or their percentage allocations for an investment strategy or (iii) Versant decides to change a client’s investment strategy, which could occur, for example, when a client makes changes to their investment profile or imposes or modifies restrictions on the management of their account. Accounts below $5,000 may deviate farther than the set parameters as well as the target allocation of the selected investment profile. Rebalancing below $5,000 may impact the ability to maintain positions in selected asset classes due to the inability to buy or sell at least one share of an ETF. For example, withdrawal requests may require entire asset classes to be liquidated to generate and disburse the requested cash. Sweep Program Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a minimum of 4% of an account’s value to be held in cash, and may be higher, depending on the investment strategy chosen for a client. The Cash Allocation will be accomplished through enrollment in the Sweep Program, a program sponsored by CS&Co. By enrolling in the OPP, clients consent to having the free credit balances in their brokerage accounts at CS&Co. swept into deposit accounts (“Deposit 5 | P a g e Accounts”) at Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep Program is a required feature of the OPP. If the Deposit Account balances exceed the Cash Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be used to purchase securities as part of rebalancing. If clients request cash withdrawals from their accounts, this likely will require the sale of ETF positions in their accounts to bring their Cash Allocation in line with the target allocation for their chosen investment strategy. If those clients have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with CS&Co., Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. Comprehensive Investment Advisory, Financial Planning, and Consulting Services (Wealth Management) and/or Family Office Services Versant also provides comprehensive investment advisory, financial planning, and consulting services on a fee-only basis in accordance with the traditional fee table described in Item 5A, based upon the amount of the assets placed under management and the level and scope of the financial planning and consulting services (see Comprehensive Investment Advisory, Financial Planning, and Consulting Services). Comprehensive wealth management services include investment advice, financial planning, estate planning and administration, succession planning, charitable planning, tax planning, as well as family governance and next-generation education. In the event a client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Versant), Versant may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. In addition to the wealth management services described above, Versant offers Family Office services to high-net-worth individuals and their families. The specific services provided are tailored to the needs and complexities of the client. Financial Planning and Consulting Services (Stand-Alone) To the extent requested by a client, Versant may determine to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Versant’s planning and consulting fees are negotiable, but generally range from $400 to $800 on an hourly rate basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Versant may also provide consulting services on a mutually agreed upon fixed-fee basis. Prior to engaging Versant to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement between the parties, setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Versant commencing services. If requested by the client, Versant may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Versant. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Versant, shall be responsible for the quality and competency of the services provided. It remains the client's responsibility to promptly notify Versant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Versant’s previous recommendations and/or services. 6 | P a g e Retirement Rollovers - No Obligation/Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Versant recommends that a client roll over their retirement plan assets into an account to be managed by Versant, such a recommendation creates a conflict of interest if Versant will earn new (or increase its current) compensation as a result of the rollover. If Versant provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Versant is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to rollover retirement plan assets to an account managed by Versant. ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS Trustee Directed Plans Versant may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby Versant shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Versant will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Versant will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and Versant. Client Retirement Plan Assets If requested to do so, Versant shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, Versant shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Versant’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Versant will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Versant of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by Versant to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Versant calculating its advisory fee. Miscellaneous Planning and Non-Investment Consulting/Implementation Services To the extent specifically requested by the client, Versant may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. We do not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as same. Accordingly, we do not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Versant. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Versant, shall be responsible for the quality and competency of the services 7 | P a g e provided. It remains the client’s responsibility to promptly notify Versant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Versant’s previous recommendations. Variable Products Versant also may render investment advisory services to clients relative to: (1) a variable investment product that they may own, and/or (2) their individual employer-sponsored retirement plans. In so doing, Versant either directs or recommends the allocation of client assets among the various mutual investment alternatives (generally mutually funds) that comprise the variable life/annuity product or the retirement plan. The client assets shall be maintained at either the specific insurance company that issued the variable life/annuity product which is owned by the client, or at the custodian designated by the sponsor of the client’s retirement plan. In the event that Versant is requested to provide advisory services with respect to a variable investment product and/or retirement plan sponsored by the client’s employer, Versant’s advice is limited to the investment alternatives provided by the variable product and/or retirement plan sponsor. Independent Managers Versant may allocate (and/or recommend that the client allocate) a portion of the client's investment assets among unaffiliated independent investment managers in accordance with the client's designated investment objective(s). In such situations, the Independent Manager(s) shall have day- to-day responsibility for the active discretionary management of the allocated assets. Versant shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Factors which Versant shall consider in recommending Independent Manager[s] include the client's designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note: The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, Versant’s advisory fee as set forth in Item 5 below. Non-Discretionary Service Limitations Clients that determine to engage Versant on a non-discretionary investment advisory basis must be willing to accept that Versant cannot affect any account transactions without obtaining prior consent to any such

transaction(s) from the client. Thus, in the event that Versant would like to make a transaction for a client's account, and the client is unavailable, Versant will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Use of Mutual and Exchange Traded Funds Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by Versant independent of engaging Versant as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Versant’s initial and ongoing investment advisory services. Use of DFA and Stone Ridge Mutual Funds Versant utilizes mutual funds and exchange traded funds (ETFs) issued by Dimensional Fund Advisors (“DFA”), and Stone Ridge Funds (“Stone Ridge”). These funds are generally only available through certain registered investment advisers. Thus, if the client was to terminate Versant’s services, and not transition to another adviser who utilizes DFA, Stone Ridge funds, and Elements, restrictions regarding additional purchases, or reallocation among other, of these funds will generally apply. Interval Funds/Risks and Limitations: Where appropriate, Versant Capital Management, Inc. (“Versant”) may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on 8 | P a g e withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short- term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct Versant, in writing, not to employ any or all such strategies for the client’s account. Unaffiliated Private Investment Funds. Versant does not generally recommend private investment funds. However, Versant may introduce, on an extremely limited non-discretionary basis, unaffiliated private investment funds to those clients who express an interest in investing in such vehicles. The description of the private investment fund (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. Versant’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing review and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall not be included as part of “assets under management” for purposes of Versant calculating its investment advisory fee, and shall not be included on any quarterly portfolio reports. Versant’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Versant generally recommends that Schwab or Pershing serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab and Pershing may charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab and Pershing, generally do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that the relevant broker-dealer/custodian will not change their transaction fee pricing in the future. These fees/charges are in addition to Versant’s investment advisory fee at Item 5 below. Versant does not receive any portion of these fees/charges. ANY QUESTIONS: Versant’s Chief Compliance Officer, Elizabeth Shabaker, remains available to address any questions that a client or prospective client may have regarding the above. 9 | P a g e Portfolio Activity Versant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Versant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Versant determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Versant will be profitable or equal any specific performance level(s). Plaid: Account Aggregation Versant, in conjunction with the services provided by Plaid, may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by Versant (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not Versant, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, Versant’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if Versant is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), Versant does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If Versant is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Versant shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Versant provide investment management services for the Excluded Assets, the client may engage Versant to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Versant and the client. Please Note: Cash Positions. Versant continues to treat cash as an asset class. As such, unless determined to the contrary by Versant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Versant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Versant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Versant’s advisory fee could exceed the interest paid by the client’s money market fund. Versant earns an additional 0.10% fee in addition to its advisory fee as outlined in Item 5 below for assets managed through the Cantor Fitzgerald Insured Cash Account Program administered by StoneCastle Network, LLC. Please note: Versant does not manage cash balances held by the Client with the Cantor Fitzgerald Insured Cash Account Program. ANY QUESTIONS: Versant’s Chief Compliance Officer, Elizabeth Shabaker, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Margin Accounts: Risks/Conflict of Interest. Versant Capital Management, Inc. does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities and/or for other non-investment borrowing purposes. The broker/custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. Should a client determine to use margin, Versant Capital Management, Inc. will include the entire market value of the margined assets when computing its advisory fee. Accordingly, Versant Capital Management, Inc.’ fee shall be based upon a higher margined account value, resulting in Versant Capital Management, Inc. earning a correspondingly higher advisory fee. As a result, the potential of conflict of interest arises since Versant Capital Management, Inc. may have an economic disincentive to recommend that the client 10 | P a g e terminate the use of margin. Please Note: The use of margin can cause significant adverse financial consequences in the event of a market correction. ANY QUESTIONS: Our Chief Compliance Officer, Elizabeth Shabaker, remains available to address any questions that a client or prospective client may have regarding the use of margin. Cybersecurity Risk. The information technology systems and networks that Registrant and its third- party service providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Registrant has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Registrant does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Client Obligations. In performing its services, Versant shall not be required to verify any information received from the client or from the client's other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Versant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating or revising Versant’s previous recommendations and/or services. Disclosure Brochure. A copy of Versant’s written Brochure as set forth on Form ADV Part 2A and Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of an Agreement between Versant and the client (i.e., Investment Advisory Service Agreement and/or Comprehensive Investment Advisory Services with Financial Planning Agreement). Section C - TAILORED ADVISORY SERVICES Versant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client's investment objective(s). Thereafter, Versant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time impose reasonable restrictions, in writing, on Versant’s services. Section D - WRAP FEE PROGRAMS Versant does not participate in a wrap fee program. Section E - ASSETS UNDER MANAGEMENT As of December 31, 2023, Versant had a total of $900,479,528 in assets under management. Of this amount, $836,076,215 is managed on a discretionary basis and $64,403,313 is managed on a non-discretionary basis. Section A - COMPENSATION The client can determine whether to engage Versant to provide the following types of advisory