Lighthouse: investment adviser

Our goal is to give access to ordinary investors to advanced quantitative strategies that target relatively more aggressive returns with a higher risk appetite. As of December 13, 2024, our interactive website became fully operational and is now providing advisory services to multiple clients beyond the firm's principals. As LightHouse operates through an internet investment adviser model, clients will not be able to directly contact LightHouse for investment advice. Clients may contact LightHouse for technical and customer service issues via email at support@lighthouseinvest.io but not for investment advice.

B. Services Portfolio management services are provided on a discretionary basis. Upon opening an account for clients, LightHouse will ask a series of questions about their financial situation and allow clients to impose restrictions on risk tolerance. Clients will be able to update these on LightHouse's web-based dashboard application. These questions include investment objectives, investment horizon, downturn tolerance, overall risk tolerance, and questions around income and net worth (to determine qualified status). Based on client suitability parameters, LightHouse will restrict certain strategies in client accounts. LightHouse does not capture any additional information not covered in the questionnaire in making its restrictions and providing its investment advice. The type of restriction a client may impose includes the degree of risk level. Once invested in their chosen model portfolios/strategies offered by LightHouse, clients are able to change their investments at any time between portfolios - provided these investments fit within the restrictions. Clients may change their investments between portfolios, but may not choose the assets within a specific portfolio. While onboarding their account with LightHouse, a client must also open a securities brokerage account. Brokerage accounts, agreements, and order processing will be conducted through Interactive Brokers (“IBKR”), an SEC registered broker-dealer that provides brokerage related

services to LightHouse. Using their application program interface (“API”), our web-based dashboard allows clients to create a brokerage account during onboarding. IBKR also provides execution, clearance, settlement, cash transfers, and custody services. The investments in each client’s account are held at IBKR, and not with LightHouse. Clients will not be able to select specific securities or restrict the purchase of specific securities. Certain transactional costs will still be paid by the client, including wire transfer fees, transaction fees for the purchase or sale of securities, expenses related to the use of margin, the fees (including expense ratios) charged to shareholders of mutual funds or ETFs, 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, Automated Customer Account Transfer Service fees, transfer taxes, fees required by law. These fees may be charged by Client’s brokerage account provider, but not charged by LightHouse. A client’s portfolio may be comprised of individual stocks, ETFs, or cryptocurrencies only. Our application 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. However, we do not do any other kind of monitoring or review. The client will receive electronic confirmations from the client’s account custodian after they make changes to their account. 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 LightHouse. As of December 31, 2025, LightHouse managed approximately $241,476 of regulatory assets under management on a discretionary basis and approximately $644,607 on a non-discretionary basis.

LightHouse is currently waiving its Advisory Fee for existing clients. LightHouse may discontinue this waiver for future periods upon notice to clients in accordance with the Investment Advisory Agreement. We deduct fees from the client’s advisory account, monthly. Clients pay the fees even if they do not have any transactions. This means that the fee, when charged, will decrease a client’s assets under management with us. 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 their 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 prorata 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.

LightHouse is currently waiving performance-based fees for existing clients. LightHouse may discontinue this waiver for future periods upon notice to clients in accordance with the Investment Advisory Agreement.

Our advice is limited to the construction and maintenance of the specific products that we offer. In the event an investment is removed and replaced with a substantially similar investment, LightHouse will liquidate client positions to cash and directly initiate a reinvestment in the replacement investment. In the event an investment is recategorized from a suitability standpoint, the investment may be liquidated to cash if the investment is no longer suitable for the client and a new re-investment recommendation will be made to the Client based on the client’s new suitability profile. The suitability questionnaire includes the following questions asked to clients prior to onboarding with LightHouse:

Investment experience: none, limited, good, extensive

Investment objective: High Growth, Growth, Capital Preservation, Income

What is your risk profile: Conservative, Balanced, Aggressive

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)

Annual income

Total net worth

Total liquid net worth

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.

1. General Risks It is impossible to describe all possible types of risks which may affect investments. Some general 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 fluctuate. For example, rising interest rates can cause “high quality, relatively safe” fixed income investments to lose principal value. Credit Risk. Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. 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 bonds or notes 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 that 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 are 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. Obligations of the U.S. government are said to be free of default risk. Cybersecurity Risk. There is cybersecurity risk with the increased use of technologies such as the Internet to conduct business. LightHouse 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, LightHouse 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 LightHouse itself may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to LightHouse’s software-based investment advisory service.

2. Specific Risks There are also risks related to recommendation of specific types of securities. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. A description of the types of securities we may recommend and some of their inherent risks are provided below. Mutual Fund and Exchange Traded Fund (“ETF”) Risk. Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on

mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. The returns from the types of securities in which an ETF invests may underperform returns from the various general securities markets or different asset classes. The securities in the underlying indexes may underperform fixed-income investments and stock market investments that track other markets, segments and sectors. Different types of securities tend to go through cycles of out-performance and underperformance in comparison to the general securities markets. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Leverage Risk. Leverage involves the use of borrowed capital, such as margin, to increase the potential return of an investment. While leveraging can amplify gains when investments perform well, it can also magnify losses when investments underperform, leading to a significant increase in the risk of investment loss. For instance, if an investment portfolio uses leverage and the value of its underlying assets decreases, the loss is magnified compared to a non-leveraged position. This can result in the investor owing more than the initial investment. Additionally, leveraging often involves interest costs and other fees, which can reduce overall returns and add to the cost of the investment. Furthermore, in volatile markets, the use of leverage can lead to forced liquidations if the equity in the investor’s account falls below the required maintenance margin, potentially resulting in the investor having to sell assets at an inopportune time. Leverage Risk is particularly relevant for portfolios that take long positions in equities and use margin or borrowing, as changes in market conditions can rapidly affect the value of leveraged positions. It is crucial for investors to understand that while leverage can offer the potential for higher returns, it also introduces a higher level of risk and can lead to substantial losses, including the possibility of losing more than the initial investment.

Cryptocurrency Risk. Cryptocurrency, often referred to as “virtual currency”, “digital currency,” or “digital assets,” operates as a decentralized, peer-to-peer financial exchange and value storage that is used like money. Cryptocurrency operates without central authority or banks and is not backed by any government. Even indirectly, cryptocurrencies may experience very high volatility. Cryptocurrency is also not legal tender. Federal, state or foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing. Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers or malware. Due to its relatively recent launch, bitcoin has a limited trading history, making it difficult for investors to evaluate investments in this cryptocurrency. It is also possible that a cryptocurrency other than bitcoin, including cryptocurrencies in which clients have limited or no exposure to, could become materially popular and have a negative impact on the demand for and price of bitcoin. It is possible that another entity could manipulate the blockchain in a manner that is detrimental to the bitcoin network. Bitcoin transactions are irreversible such that an improper transfer can only be undone by the receiver of the bitcoin agreeing to return the bitcoin to the original sender. Digital assets are highly dependent on their developers and there is no guarantee that development will continue or that developers will not abandon a project with little or no notice. Factor-Specific Risk. Factor investing pertains to the strategy of using specific characteristics or 'factors' that can drive investment returns. Common factors include elements like value, size, momentum, and quality. While factor investing aims to enhance portfolio diversification and target specific drivers of return, it carries its own set of risks. Firstly, the success of factor-based strategies is heavily reliant on the accuracy of the models used to identify these factors. If the models are based on flawed assumptions or incomplete data, the strategy may underperform. Moreover, factors that have worked well in the past may not necessarily yield the same results in the future due to changes in market dynamics or economic conditions. This unpredictability is especially true for proprietary factors that do not have extensive historical data to validate their effectiveness. Additionally, factor investing strategies can become crowded as more investors adopt similar approaches, potentially diminishing the returns associated with these factors. Investors must also be aware of the risk that arises from the timing of factor rotations, as mistiming market shifts can lead to significant underperformance relative to broader markets. Theme-Specific Risk. This risk is inherent in investment strategies that focus on specific macroeconomic or geopolitical themes. Such strategies aim to capitalize on trends or developments in particular areas, like emerging technologies, demographic shifts, or geopolitical events. The risk arises from the possibility that the chosen theme may not unfold as expected, or may take longer to materialize, leading to potential underperformance. Additionally, the analysis and selection of equities within a thematic portfolio are crucial. If the fundamental research identifying these equities is inaccurate or if the quantitative methods used for portfolio optimization do not effectively isolate the specific risks associated with the theme, the portfolio may be exposed to unintended risks. This risk is compounded

by the fact that thematic investing often involves a concentration in certain sectors or industries, making the portfolio more susceptible to sector-specific downturns or disruptions. Furthermore, themes are often based on forward-looking projections and speculations, which can be highly uncertain and subject to rapid change due to new information or global events. Therefore, while thematic investing can offer opportunities for targeted exposure to potential growth areas, it also requires careful consideration of the uncertainties and specific risks associated with each theme. Complexity Risk. Complexity is among the potential difficulties and dangers associated with understanding and managing sophisticated investment products. This risk is particularly relevant in investment strategies that involve advanced trading methodologies. For instance, in products that use leverage, or are based on nuanced market factors, the inherent complexity can obscure the true risk profile of the investment. Such complexity not only makes it challenging for investors to fully comprehend the potential risks and rewards, but it also complicates the portfolio management process. The valuation of complex investments can be highly sensitive to changes in market conditions, interest rates, or volatility, leading to unexpected performance fluctuations. Moreover, these investments often require specialized knowledge to manage effectively, increasing the risk of mismanagement or errors in judgment. Complexity can also lead to increased operational risks, such as errors in calculating net asset values or mispricing of assets. Additionally, the illiquidity often associated with complex products can further exacerbate risks, as it may become difficult to exit positions without incurring significant losses, especially during periods of market stress. This risk is heightened in times of market turbulence when complex strategies might behave unpredictably. Hence, while complex investment products can offer unique opportunities and diversification benefits, they also demand a higher degree of vigilance and expertise, both from the investors and the portfolio managers, to navigate their intricacies and inherent risks effectively.

LightHouse has a business relationship with Featuremine Corporation, whose CEO Maxim Trokhimtchouk previously provided an endorsement on our website. LightHouse pays Featuremine Corporation $10,000 monthly for software-related services. As of February 15, 2025, we have removed all endorsements from our website, including that of Mr. Trokhimtchouk. LightHouse also provides investment research services to third parties on a consulting basis under the LightHouse name. A recipient of these services may also be or become an advisory client of the Firm. This presents a potential conflict of interest because the Firm receives compensation from such engagements in addition to any advisory relationship. LightHouse addresses this conflict by treating all advisory clients in accordance with its fiduciary duty and by keeping its consulting engagements separate from the advisory services provided through its platform. LightHouse manages client accounts in accordance with their risk profile and uses automated algorithms to monitor client accounts quarterly, only for suitability based on their responses to the suitability questionnaire. On a periodic basis, LightHouse asks clients to update their profile. LightHouse will provide investment advice exclusively through its interactive web-based dashboard application. Clients will not be able to directly contact LightHouse’s portfolio managers for investment advice. Clients may contact LightHouse for technical and customer service issues via email at support@lighthouseinvest.io, but not for investment advice.

Accordingly, LightHouse has implemented extensive policies, guidelines, and procedures that promote ethical practices and conduct by all of the Firm’s personnel. 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 LightHouse 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.

IB Commission per Share — US Stocks, ETFs, ETPs and Warrants

Minimum per Order

Maximum per Order

<= 300,000 Shares

USD 0.0035

USD 0.35

1.0% of trade value

300,001 - 3,000,000 Shares

USD 0.002

USD 0.35

1.0% of trade value

3,000,001 - 20,000,000 Shares

USD 0.0015

USD 0.35

1.0% of trade value

20,000,001 - 100,000,000 Shares

USD 0.001

USD 0.35

1.0% of trade value

> 100,000,000 Shares

USD 0.0005

USD 0.35

1.0% of trade value

We do not receive research or other products or services (i.e., soft dollar benefits) from IBKR or other broker-dealers in exchange for placing trades or processing securities related transactions for clients. We do not receive client referrals or compensation of any kind from IBKR or other broker-dealers or other third parties in exchange for using any particular broker-dealer. We do not block trade.