A. FIRM DESCRIPTION Claraphi Advisory Network, LLC (“Claraphi” or the “Firm” or “us” or “we”) is a Delaware limited liability company that was founded in October 2012. Claraphi is a SEC registered investment advisor based in Aliso Viejo, California. On or about March 2022, Tradability, LLC acquired full ownership of Pomegranate Holdings, LLC (“Pomegranate Holdings”) from former Chief Executive Officer, Pierre Gallant, who resigned all roles in both Pomegranate and Claraphi in March. Claraphi is a wholly owned subsidiary of Pomegranate Holdings, both of which as of April 29, 2022, are now Delaware limited liability companies. Pomegranate Holdings is now principally owned and controlled by Tradability, LLC with its owner, Mr. Diallo serving as Chairman of Pomegranate Holdings, as well as in various roles with Claraphi. Additional information regarding the ownership of Claraphi and of Pomegranate Holdings, is presented in the Schedules to Claraphi’s Form ADV Part 1 which are available on the SEC’s website at www.adviserinfo.sec.gov. The searchable CRD number for Claraphi is 165868. Claraphi offers a variety of investment advisory and related financial services to our clients. We provide investment advisory services and retirement plan consulting services, all of which are discussed below in further detail. The products discussed throughout this Brochure are all available on a non-wrap fee basis. Our clients consist of individuals, high net-worth individuals, families, business owners and corporations. B. TYPES OF ADVISORY SERVICES OVERVIEW OF SERVICES Our investment advisory services consist primarily of: (1) assessing client needs and goals; (2) financial planning designed to meet those goals; (3) developing an appropriate portfolio asset allocation to achieve the client’s objectives; (4) implementing the asset allocation by recommending or otherwise assisting in the client’s selection of: (a) particular investment strategies (i.e., active, passive, alternative strategies); and (b) specific investment managers or passive investment vehicles that employ those strategies; and (5) reviewing and reassessing the client’s needs and goals, their investment portfolios, and repeating the process on a regular, ongoing basis. Claraphi dedicates itself to understanding the intricacies of each client. For all investment advisory and related services described below, we tailor our products in accordance with the client-specific needs obtained from documented discussions, a financial plan and/ or risk assessment. Before providing investment advisory services, Claraphi takes multiple factors into consideration, including, but not limited to, investment objectives, investment horizon, risk tolerance, as well as any reasonable guidelines and restrictions a client may need or impose. INVESTMENT MANAGEMENT SERVICES We offer discretionary and non-discretionary investment advisory services to individuals, high net worth individuals, and families, based on the specific needs and objectives of such persons and the suitability of products and services. We reserve the right to decline to offer our services to a client or potential client if we deem it to be in the best interest of the client, potential client, or the Firm. For discretionary accounts, we are authorized to perform various functions without further approval from the client, such as the determination of securities to be purchased or to be sold for the client’s account without permission from the client prior to each transaction. For non-discretionary investment advisory services, we will obtain client approval prior to taking any action in the account, including but not limited to, executing trades. We do not act as a custodian of client assets, and the client will always maintain control of their assets. We require an executed investment management agreement (“IMA”) between the client and Claraphi prior to us providing our services to the client. The IMA outlines the services and fees the client will incur pursuant to an agreement with Claraphi. Upon signing the IMA, we will then gather pertinent information on the client about their financial and personal circumstances and objectives. For investments, we will also complete a risk assessment which will help us identify, quantify, and understand our client’s unique risk tolerance. The information gathered in the risk assessment will be used to identify the appropriate investments and portfolio construction and specify any restrictions or prohibitions expressed by the client for their portfolio and / or assets. Claraphi’s investment advisory services include, but are not limited to, the following:
• Investment Strategy
• Asset Allocation
• Regular Portfolio Monitoring
• Personal Investment Policy
• Security Selection Claraphi’s investment advisory services are designed to offer ongoing management of accounts with defined investment strategies to meet the client’s personal investment goals and objectives. Claraphi is responsible for providing ongoing re-balancing and continuous monitoring of our clients’ securities holdings. MONITORING OF ASSETS HELD AWAY Claraphi provides asset- monitoring services with respect to variable annuity products, plans such as 401(k)s, 403(b)s, mutual funds, and accounts held at custodians with which Claraphi has no direct relationship. Claraphi monitors the investment and reallocation of assets among sub-accounts offered by the insurance company that issues a variable annuity or among investment options in 401(k)s, 403(b)s, mutual funds and other plans or otherwise manages an account held at a custodian in accordance with a confidential client profile, which includes the Client’s investment objectives. The financial advisor will provide investment advice regarding allocations and reallocations among subaccounts or investment options, but the authority to make final investment decisions will remain with the Client. SELECTION OF OTHER ADVISERS We may recommend that you use the services of a third-party money manager ("TPAM") to manage all, or a portion of, your investment portfolio. At this time, After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPAM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPAM's performance, methods of analysis, fees,

your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPAM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. The TPAM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire TPAM(s) and/or reallocate your assets to other TPAM(s) where we deem such action appropriate. RETIREMENT SOLUTIONS Claraphi delivers retirement solutions to plan providers, plan sponsors, and participants through Folio Investments, Inc. and Mid-Atlantic custodial partners. Claraphi may recommend third-party administrators or Clients can select their own. Where Claraphi offers plan participants the option of using our discretionary investment management services, we will enter into a separate agreement with that participant, describing our services and fees for those services. We will also request financial data and other information from the participant that will help us understand their investment objectives and financial goals. In providing our retirement plan services to plan sponsors and participants, we are deemed to be a fiduciary. We may also agree to serve as investment manager as defined in ERISA Section 3(38). Our serving in this capacity requires a separate acknowledgement and agreement between Claraphi and the plan sponsor. ERISA and Individual Retirement Accounts Disclosure When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. CO-FIDUCIARY INVESTMENT MANAGEMENT SERVICES Claraphi provides investment management services to third party registered investment advisors through a co-fiduciary agreement where Claraphi serves as the investment manager. The Firm implements investment strategies as directed by the third party investment advisor for the benefit of the advisor’s client(s) and provides management and administrative services to the client’s accounts. The third party investment advisor shall determine the suitability of the services to be provided by Claraphi based on the client’s investment goals and objectives and instructs Claraphi to implement the chosen investment strategies. Thereafter, Claraphi monitors the selected investment strategies on an ongoing basis unless and until directed otherwise by the third party investment advisor. The services Claraphi provides under this co-fiduciary program are on a discretionary basis only. Claraphi and the third party investment advisor shall share the advisory fees charged to advisory client(s) that participate in this program. FINANCIAL PLANNING SERVICES Claraphi also provides financial planning services to clients. Clients will sign the Claraphi Financial Planning Agreement, and receive information and recommendations regarding investment planning, retirement planning, estate needs, business needs, education planning, life and disability insurance needs, long-term care needs and cash flow/budget planning. Our financial advisers may also conduct due diligence and product review of one or more tax mitigation strategies for clients. However, clients are urged to seek the advice of a tax professional. At the conclusion of our financial planning services, the financial adviser delivers to the client a written financial plan. If a financial plan includes recommendations regarding investments, the client will have the choice of where to implement those recommendations and can use advisors other than Claraphi. You are not obligated to implement any recommendations made by your financial adviser. C. TAILORED RELATIONSHIPS At Claraphi, we offer the same suite of services to all our clients. The advisory services and recommendations offered by Claraphi are based on the individual needs of our clients and the suitability of products and services. Specific client financial plans and their implementation are dependent upon the client’s risk assessment which outlines each client’s current situation (income, objectives, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values and beliefs. Claraphi will make every effort to comply with the wishes of the client but cannot guarantee absolute adherence due to our use of indexed products, funds, and exchange traded funds (“ETF”) that are controlled by custodian and its third-party service providers. D. WRAP FEE PROGRAMS Claraphi does not participate in and is not a sponsor of wrap fee programs. Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and other financial institutions, and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. E. ASSETS UNDER MANAGEMENT When calculating regulatory assets under management, an investment adviser must include the value of any advisory account over which it exercises continuous and regular advisory or management services. As of December 31, 2022, Claraphi reports $ 474,161,524.00 in client assets on a discretionary basis and $0.00 on a non-discretionary basis.