Description of firm Quillu Inc. is a Delaware C Corporation incorporated in 2012. Our principal owners are Rikin Shah and Dharmesh Malam. Quillu Inc. is registering as an investment advisor with the SEC, operating under the name “OctaveWealth”. Description of advisory services offered OctaveWealth provides investment advice to clients through an interactive website in which software-based models provide investment advice based on personal information each client provides through the website. OctaveWealth offers financial advice for retirement plans and their participants (For more information on our clients, see Item 7. Types of Clients.) Using the proprietary investment-tools on our website, https://OctaveWealth.com, we offer investment advice on a non-discretionary and discretionary basis. Our goal is to help Plan Administrators select a diverse set of low-cost investment options to offer in their retirement plan, and to help Plan Participants invest their retirement accounts optimally. Plan Administrators: We seek to recommend the lowest cost investment options that will give plan participants exposure to a broad mix of asset classes across geographic regions. These will make up the Plan’s Investment Menu. We base our recommendations on our proprietary rating system, which takes into account a number of factors including expenses, liquidity, performance and volatility. This will consist primarily of US-Listed ETFs and Index-Tracking mutual funds. We will provide at least three default investment alternatives for your plan. These models will either be an off-the-shelf investment product such as a Target-Date fund, or a custom portfolio made up of the investments from the plan’s investment menu. Any custom portfolio will be built using our proprietary web-based platform, which takes into account among other

things, the return, risk and correlation of investments. Plan Participants: Using the tools on OctaveWealth’s website, the firm assists clients in building a portfolio of investments, which are suitable given different risk factors and the individual’s retirement goals. Using proprietary models, OctaveWealth offers clients a globally diversified portfolio as a starting point. Clients can then make adjustments to that portfolio based on preferences, and view historic performance and simulated future performance. It is important to note that historic performance is not necessarily indicative of future performance, and that neither OctaveWealth nor anyone else can predict the future returns of investments. The OctaveWealth tools will assist clients select a target-portfolio for their retirement funds, by: - Getting clients started with a sensible asset allocation that is diversified across global equity markets; - Allowing clients to incorporate their own views and build a custom portfolio; - Showing historic performance; - Simulating future performance; Once clients have chosen a target-portfolio, OctaveWealth will purchase securities on their behalf to replicate this. On an on-going basis, OctaveWealth will re-balance clients’ accounts to bring it back in line with their target-portfolio, as the value of their holdings change. OctaveWealth will use a broker-dealer who is a “qualified custodian” as defined by the SEC (See Item 12: Brokerage Practices, for more details.) OctaveWealth offers these services on a discretionary basis. Tailoring advisory services OctaveWealth does not tailor its advisory services to the individual needs of Clients beyond taking into account their risk tolerance, age and the number years to retirement. Wrap fee programs OctaveWealth does not participate in wrap fee programs. OctaveWealth currently manages $16,530,000 on a discretionary basis and $0 on a non- discretionary basis.