Finn: investment adviser

Through the app, Finn makes recommendations to users on which securities to invest in, based on a suitability and personalization questionnaire it offers in the onboarding process.

Finn also provides financial planning services through the application, including analysis of a client's overall financial position, goals, and cash flow. Clients will not be able to directly contact Finn’s portfolio managers for investment advice. Clients may contact Finn for technical and customer service issues via email at support@getfinn.us but not for investment advice. B.​ Services Portfolio management services are provided on a non-discretionary basis. Clients must authorize each transaction before it is executed. As Finn's app is set up to direct all client trades to a specific broker/dealer, the Firm does have discretionary authority over the brokerage used by the client to purchase or sell securities. Upon opening an account for clients, Finn will ask a series of questions about their financial situations. These questions include investment objectives, investment horizon, downturn tolerance, and overall risk tolerance. Based on client suitability parameters, Finn will restrict certain assets from being bought or sold in Client accounts. ​ Finn offers its services through a free tier and a paid subscription tier. Clients on different tiers receive access to different features, as described in Item 5 below. In providing investment advice and applying restrictions, Finn considers the information a client provides through the questionnaire and, where a client elects to connect external financial accounts, information from those accounts. Once invested in the portfolio, clients are able to change their investments at any time, provided these investments fit within the restrictions. Finn does not provide brokerage services directly. Finn offers its services through brokerage services provided by Alpaca Securities LLC (“Alpaca”), an SEC registered broker-dealer and member FINRA/SPIC, to direct and execute trades on behalf of clients. When creating an investment account with Finn, clients will also be making an account with the brokerage firm. The Firm’s mobile app allows Clients to create an investment transaction instantly through Alpaca. Alpaca will provide execution, clearance, settlement, and custody services for Finn. Cash transfers and custody are also provided by Alpaca. The investments in each Client’s account are held in a separate account in the name of the Client at Alpaca, and not with Finn. Certain transactional costs will still be paid by the Client, including transaction fees for the purchase or sale of securities, expenses related to the use of margin, short-term redemption fees, mark-ups and mark-downs, spreads, odd-lot differentials, paper statement fees, fees charged by regulatory agencies, exchange fees, American Depositary Receipt fees, transfer taxes, fees required by law. These fees may be charged by Client’s brokerage account provider, but not charged by Finn. Finn may charge wire transfer fees. Our application also monitors the client’s accounts quarterly to ensure that they fall within the client’s suitability restrictions. If any changes are needed to the client’s investments, we will recommend the changes to the client through the application. These recommendations may involve selling a security or group of investments and buying others. Other than the quarterly suitability review described above and the monitoring provided to subscribers through the

application, we do not monitor or review client accounts. The client will also receive statements at least quarterly from the client’s account custodian. Our Investment Advisory Agreement outlines the responsibilities of both the client and Finn.

The free tier includes net worth tracking, brokerage access, research tools, and limited access to Finn Chat. Finn Pro additionally includes unlimited access to Finn Chat, automations, and proactive monitoring. Current tiers, features, and pricing are described at getfinn.us/support/pricing. The Subscription Fee is charged monthly and is charged to the payment method the client provides. The Subscription Fee is a flat fee. It does not vary with the size of a client's account, the number of transactions in the account, or the performance of the account. Clients may cancel their subscription at any time through the application. b)​ Advisory Fee Finn charges an Advisory Fee to clients based on a percentage of assets under management. The specific Advisory Fee charged by the Firm for its advisory services will be outlined in each client’s Investment Advisory Agreement. The Advisory Fee charged by Finn is a 0.3% fee on assets under management for the treasury and corporate bond holdings only. Finn charges this fee monthly in arrears and defines assets under management for the fee calculation as the average daily balance of assets over the month for which the fee has accrued. Finn reserves the right to charge a lower amount than this to clients. We deduct fees from the Client’s advisory account, monthly. Clients pay the fees even if they do not have any transactions. Each time a Client uses our advisory services, they reaffirm their agreement that we may charge their account for the specified period. In the event that we cannot charge Advisory Fees to the Client’s account, we reserve the right to terminate a Client’s access to our advisory services. Each Client may also terminate our services at any time, at which any accrued fees that have not been yet charged shall be charged prior to account termination and withdrawal.

The qualified custodian agrees to deliver an account statement, at least quarterly, directly to the client, showing all disbursements from the account. The client is encouraged to review all account statements for accuracy. We will receive access to a duplicate copy of the statement that was delivered to the client. For the initial period of portfolio management services, the first period’s fees will be calculated on a pro-rata basis at the beginning of the following month, for the payment in arrears. After signing up, a Client may terminate the agreement through the app at any time.

The securities available on Finn may change over time, and Finn may add or remove securities or change how they are categorized for suitability purposes. If a security a client holds is removed, or is no longer suitable for the client based on their profile, Finn will notify the client through the application and recommend a transaction. Finn will not sell or purchase any security in a client's account without the client's authorization. The suitability questionnaire comprises of the following questions asked to clients prior to onboarding with Finn:

●​ How would you like to invest: Avoid Losses, Balance Risk, Maximize Returns ●​ How would you react to a downturn - I would sell off my holdings, I would wait and see what happens, I would buy more holdings ●​ When will you need your returns - Short-Term (0-2 years), Medium Term (2-5 years), Long Term (5+ years)

Finn does provide proprietary strategies and portfolios to the user. Its strategies are constructed using a combination of systematic rules-based methodologies and proprietary AI systems developed by the Firm and applied to publicly available financial data. Strategy holdings are reviewed and updated periodically. Investing in these strategies involves the risk of loss described below, and there is no assurance that any strategy will achieve its objective. A. Risk of Loss There are always risks to investing. All clients should be aware that all investments are subject to the potential loss of principal that clients should be prepared to bear. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all-inclusive, but should be considered carefully by a prospective client before retaining our services. It is impossible to describe all possible types of risks which may affect investments. Some risks associated with investing include the following: •​ Concentration Risk. To the extent a portfolio is concentrated in assets related to a particular industry or geographic region, the portfolio will be subject to additional volatility risks associated with such industry or region. In addition, concentrating in a single industry or group of industries may be more susceptible to any single economic, market, political or regulatory occurrence affecting that industry or group of industries. •​ Market Risk. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. •​ Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. •​ Interest Rate Risk. Movements in interest rates may directly cause prices of fixed income securities to fluctuate. For example, rising interest rates can cause “high quality, relatively safe” fixed income investments to lose principal value.

•​ Credit Risk. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. For example, if debt obligations held by an account are downgraded by ratings agencies or go into default, or if management action, legislation or other government action reduces the ability of issuers to pay principal and interest when due, the value of those obligations may decline, and an account’s value may be reduced. Because the ability of an issuer of a lower-rated or unrated obligation (including particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain than for an issuer of a higher-rated obligation, lower rated and unrated obligations are generally more vulnerable than higher-rated obligations to default, to ratings downgrades, and to liquidity risk.

•​ Purchasing Power Risk. Purchasing power risk is the risk that an investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. •​ Maturity Risk. The value of fixed-income securities may change from the time of issuance to the time of maturity. Generally speaking, maturity risk increases as the length of time until maturity increases. •​ Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. For example, Treasury Bills are highly liquid, while real estate properties are not. Some securities are highly liquid while others are highly illiquid. Illiquid investments carry more risk because it can be difficult to sell them. •​ Political Risk. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. •​ Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. •​ Risks Related to Investment Term. If the client requires a liquidation of their portfolio during a period in which the price of the security is low, the client will not realize as much value as they would have had the investment had the opportunity to regain its value, as investments frequently do, or had it been able to be reinvested in another security.

•​ Horizon and Longevity Risks. The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time when the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired, or are nearing retirement. •​ Business Risk. Many investments contain interests in operating businesses. Business risks are risks associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of

profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. •​ Financial Risk. Many investments contain interests in operating businesses. Excessive borrowing to finance a business’ operations decreases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. •​ Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. •​ Cybersecurity Risk. There is cybersecurity risk with the increased use of technologies such as the Internet to conduct business. Finn and its service providers are susceptible to operational, information security, and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyber incidents affecting us or our service providers have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, impediments to trading, the inability of clients to transact business, violations of applicable privacy and other law. While both we and our service providers have established business continuity plans in the event of such cyber incidents, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Furthermore, we are unable to control the cyber security plans and systems put in place by our service providers or any other third parties whose operations may affect us and or its clients. As a result, Finn and its clients could be negatively impacted. •​ Robo-adviser Risk. The inherent risk with automated investment advice (or a “robo-adviser”) is that it lacks human judgment and oversight. A robo-adviser might rely on broad assumptions that may not reflect current economic conditions or a clientʼs particular situation. Algorithms may not comprehensively provide personalized recommendations based on a clientʼs overall tax situation, other investments a client may own, and the clientʼs ability or desire to withstand losses. The algorithm might suggest securities to client accounts without regard to market conditions at an inopportune time. The algorithm may not address prolonged changes in market conditions. It is possible that Clients or Finn itself may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to Finn’s software-based investment advisory service •​ Artificial Intelligence Risk. Finn uses artificial intelligence (“AI”) technologies to help analyze financial data, surface insights, and support certain aspects of our advisory process. AI systems rely on rapidly evolving models, algorithms, and large datasets from third-party sources, all of which may contain inaccuracies, delays, or incomplete information. AI tools can generate incorrect, misleading, or “hallucinated” outputs, particularly when confronted with ambiguous, complex, or unfamiliar inputs. The quality of AI-generated output also depends heavily on the

accuracy and completeness of the data or instructions provided by the user. AI models may exhibit embedded historical or dataset-driven biases that could affect the fairness, accuracy, or applicability of their outputs. In addition, technical issues such as system errors, model defects, software bugs, or service outages, may interrupt or impair AI functionality. Certain AI-generated output constitutes investment advice provided by the Firm and is identified as such within the application. Other output is general, educational, or informational in nature and does not constitute a recommendation. Clients should consider AI-generated output in light of their own circumstances and should not rely on it as a substitute for their own judgment.

Finn manages Client accounts in accordance with their risk profile and monitors Client accounts quarterly, only for suitability based on their responses to the suitability questionnaire. Finn does not rebalance or execute trades on behalf of Clients without their direction. On a periodic basis, Finn asks clients to update their profile. Finn will provide investment advice exclusively through its mobile application. Clients will not be able to directly contact Finn’s portfolio managers for investment advice. Clients may contact Finn for technical and customer service issues via email at support@getfinn.us, but not for investment advice.

The Firm’s Code of Ethics specifies and prohibits certain types of transactions deemed to create conflicts of interest (or perceived conflicts of interest), as well as to establish reporting requirements and enforcement procedures relating to personal transactions by its personnel. The Code of Ethics, which specifically deals with professional standards, insider trading, personal trading, gifts and entertainment, and fiduciary duties, establishes the Firm’s ideals for ethical conduct based upon fundamental principles of openness, integrity, honesty, and trust. The Firm will provide a copy of the complete Code of Ethics to any client or prospective client upon request. 1. Proprietary Trading Finn and its representatives are permitted to buy or sell securities for their own accounts that the Firm also recommends to clients, consistent with the Firm’s policies and procedures. This presents a conflict of interest because it may be possible for us or our representatives to receive more favorable prices than our clients. We will always document any transactions that could be construed as a conflict of interest. To mitigate this conflict of interest, we will monitor trading reports for adherence to our Code of Ethics. 2. Participation or Interest in Client Transactions The Firm does not recommend that clients buy or sell securities in which it or a related person may have a material financial interest.

We do not receive client referrals or compensation of any kind from Alpaca or other broker-dealers or other third parties in exchange for using any particular broker-dealer. We do not block trade.