Smartasset: investment adviser

It is solely the responsibility of the User to determine whether to meet with and/or retain an Adviser. SmartAsset does not review the ongoing performance of any Adviser, participate in the management of any User’s account by an Adviser, or provide advice regarding specific investments. SmartAsset also does not establish advisory accounts or manage any client assets. The Advisers are responsible for determining and implementing specific investment strategies for the Users. The Service is not a recommendation of any specific investments or any investment strategy. It is the responsibility of the Users, and the Advisers they engage, to determine what types of investments are suitable. Any tax, estate planning, accounting, legal or other advice or services other than as described in this document are beyond the scope of the Service, and SmartAsset makes no representation regarding the Advisers’ ability to perform any of those other services. Except for certain clerical functions performed by SmartAsset, including through the use of voice-assisted technology, such as validation of a User’s phone number, scheduling appointments and appointment follow-up communications, SmartAsset provides investment resources solely through its interactive website. SmartAsset may also provide participating Advisers with technology and related services designed to facilitate communications with Users following a referral, including telephone, text and email communications, meeting scheduling and related referral conversion tools. SmartAsset does not meet with Users at its offices. While our primary focus is connecting Users with Advisers, we recognize that a fiduciary match may not always be immediately available. In such cases, our platform will present the User with information on other services or products that could be of interest. SmartAsset does not manage any assets. As of December 31, 2025, SmartAsset managed $0 on behalf of any clients.

assets, are paid by the Advisers per referral or meeting set, whether or not the User engages any Adviser to whom the User was referred. In some cases, SmartAsset will receive a portion of the ongoing Adviser management fee (which might be an assets under management fee or might be another type of revenue-sharing arrangement). In some cases, SmartAsset receives fees on a subscription basis as part of our Adviser Marketing Platform. However, no portion of the referral fees paid to SmartAsset will be charged to you, and the fees you pay an Adviser will not be increased as a result of this arrangement. Additionally, in some cases, SmartAsset will receive a fixed fee based on the amount of investable assets a User transfers to a referred Adviser. All of the fee arrangements are mutually agreed upon between SmartAsset and the Advisers. In general, the Advisers are not affiliated with SmartAsset. However, certain Advisers to whom SmartAsset makes referrals are minority investors in SmartAsset’s parent company. Advisers that are minority investors in SmartAsset’s parent company participate in the SmartAsset referral program on the same terms as other Advisers. This creates a potential conflict of interest for SmartAsset as SmartAsset would have an incentive to refer Users to minority investors. SmartAsset has taken steps to mitigate this conflict of interest by designing its proprietary rules-based modeling to ensure that SmartAsset does not favor any Adviser over another in the matching process. Advisers may pay SmartAsset different fees based upon, among other factors, the fee arrangement with each Adviser and whether SmartAsset transfers a User directly to an Adviser via telephone or facilitates or sets a meeting for an Adviser, including through the use of voice-assisted technology. Advisers may also have different targeted budgets for consumer referrals with SmartAsset, which will impact the number of potential matches that an Adviser receives. This creates a potential conflict of interest for SmartAsset as SmartAsset could have an incentive to refer clients to Advisers that pay more fees and/or have larger consumer referral budgets. SmartAsset has taken steps to mitigate this conflict of interest, including by designing its proprietary rules-based modeling to avoid favoring Advisers that have a higher budget, by maintaining controls designed to prevent employees involved in consumer outreach from having access to current Adviser fee information maintained in SmartAsset’s internal financial systems and periodically reviewing calls for quality assurance purposes. In addition, Users receive a disclosure statement that describes the relationship between SmartAsset and Advisers and the fact that compensation is paid to SmartAsset. In the event SmartAsset does not match a User to an Adviser, SmartAsset provides the User information about products and/or services offered by third-parties. SmartAsset receives compensation from these third-parties for marketing their products or services, or based on Users purchasing their products or services. SmartAsset’s receipt of such compensation from these third-parties creates a conflict of interest for SmartAsset to provide information about third-parties that provide such compensation. To address this conflict, SmartAsset provides disclosure of its receipt of compensation through its website, where applicable. Compensation SmartAsset has designed compensation programs for certain SmartAsset representatives to include, in addition to base salaries, incentive compensation for transferring a User directly to an Adviser via telephone or setting a meeting for an Adviser. In facilitating these connections, representatives may consider operational factors, including Adviser availability and historical pickup rates, when selecting among otherwise eligible Adviser matches. The use of these technologies does not determine the Adviser matches presented to a User.

There will be occasions when the universe of potential Adviser matches is limited because of the available Adviser budget, and certain Advisers may be included as matches more often because of larger budgets. The data gathered from the Users as part of the matching process is provided to the Adviser matches to assist them in understanding the Users’ financial goals and potential requirements for working with an Adviser. SmartAsset may also receive Users' information through arrangements with third-party websites. These third-party websites may collect basic information from the Users and submit it to SmartAsset through other means, such as direct integrations with our platform. SmartAsset does not control, supervise, monitor, recommend or audit such third parties. SmartAsset reviews Advisers that seek to join SmartAsset’s platform. In determining who to admit to the platform, SmartAsset conducts due diligence reviews of all Adviser applicants. In these due diligence reviews, SmartAsset verifies the identity of all Advisers on the platform with independent email verification and documentary evidence of their identity. Additionally, SmartAsset verifies that each Adviser is registered as a fiduciary, or chartered as such, with a regulatory body in the United States. Further, SmartAsset considers each Adviser applicant’s regulatory history and registration status. SmartAsset does not consider or verify an Adviser’s past investment performance when generating matches, and investors should not rely on past performance, which is not indicative of future results. To be accepted onto SmartAsset’s platform, Advisers must meet SmartAsset’s initial due diligence criteria. Advisers that are accepted onto SmartAsset’s platform are also required to enter into SmartAsset’s Terms and Conditions agreement. Advisers must complete this process prior to being included as a potential match for any User. After the initial onboarding review, SmartAsset conducts regular reviews of the regulatory history and registration status of the Advisers on the platform. SmartAsset may modify or waive criteria for Advisers on a case-by-case basis. Additionally, SmartAsset may, without notice, change the eligibility criteria for Advisers participating on the SmartAsset platform. Notwithstanding the eligibility criteria described above, SmartAsset retains discretion with respect to which Advisers may access the SmartAsset platform. Users visiting www.smartasset.com will be offered access to the interactive platform, whereby, based on the matching criteria described above, the User will be presented with potential Adviser matches by SmartAsset. SmartAsset may contact the User to verify the User’s interest in being connected to one or

more of the Adviser matches presented and, if unable to reach the User, may seek to confirm that the User has submitted working contact information. During the validation process and upon User request, SmartAsset may further tailor the User’s matches based on additional User input. SmartAsset may also offer to connect a User directly to the Adviser via telephone if the functionality has been set up between SmartAsset and the Adviser or schedule a meeting for the User and an Adviser. If a User does not connect with an Adviser, or is dissatisfied with the matches presented, SmartAsset may contact the User to confirm or update the User’s information and preferences and, if applicable, present additional Adviser matches based on the User’s confirmed or updated responses, SmartAsset’s proprietary rules-based modeling and Adviser availability. Prior to engaging SmartAsset for services, each User must complete the online questionnaire and agree to the terms of use. Information that each User provides to SmartAsset about their annual income, net worth, investment knowledge, and other nonpublic information about their account(s) is shared by SmartAsset with the User’s Adviser matches. At the time the matches are presented to a User, SmartAsset provides an electronic link to each Adviser’s disclosure brochure. Users are encouraged to read the disclosure brochures for the matches presented. Following a referral, SmartAsset may facilitate communication between a User and an Adviser through telephone, text, email or other communication technology and may assist with scheduling meetings. SmartAsset may use automated or voice-assisted technology in connection with these communications. Past performance of any Adviser is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each User should understand and be willing to bear. Users are reminded to discuss these risks with the Adviser they select, if applicable. Users should obtain risk disclosures from any Adviser in which they conduct business and fully understand the risks of investing. Advisers, including SmartAsset, face certain operational and technology risks. An externally caused information security incident, such as a cyber-attack, or an internally caused incident, such as a failure to control access to key systems, could materially interrupt business operations or cause unintended disclosure of sensitive information. SmartAsset has adopted an information security program to address and respond to these areas of risk.

The code of ethics is predicated on the belief that SmartAsset’s Users shall be treated with honesty and good faith, and that SmartAsset shall put the interests of its Users ahead of its employees and principals, particularly where SmartAsset’s interests conflict with those of its Users. A copy of SmartAsset’s code of ethics is available upon request for clients. Contact SmartAsset via the website at www.smartasset.com or compliance@smartasset.com. SmartAsset also recommends that Users obtain and review the code of ethics of any Adviser the User engages for products or services. SmartAsset does not recommend or effect transactions in securities in which any related person may have material financial interest. SmartAsset or its affiliated persons do not buy or sell securities for its own accounts that it has also recommended to clients, as recommendations of securities are not made by the firm.